Text

Issuance of Amendment Nos. 332, 355, and 315 Regarding the Revision of Technical Specifications to Adopt TSTF-566-A and TSTF-580-A, Rev. 1
	ML23205A213
Person / Time
Site:	Browns Ferry
Issue date:	09/08/2023
From:	Kimberly Green; Plant Licensing Branch II
To:	Jim Barstow; Tennessee Valley Authority
	Green K
References
	EPID L-2023-LLA-0035
	Download: ML23205A213 (40)
	v • d • e

September 8, 2023 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 ISSUANCE OF AMENDMENT NOS. 332, 355, AND 315 REGARDING THE REVISION OF TECHNICAL SPECIFICATIONS TO ADOPT TSTF-566-A, REVISE ACTIONS FOR INOPERABLE RHR SHUTDOWN COOLING SUBSYSTEMS, AND TSTF-580-A, REVISION 1, PROVIDE EXCEPTION FROM ENTERING MODE 4 WITH NO OPERABLE RHR SHUTDOWN COOLING (EPID L-2023-LLA-0035)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 332, 355, and 315 to Renewed Facility Operating Licenses Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, respectively. These amendments are in response to your application dated March 10, 2023.

The amendments revise the technical specification (TS) actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable and provide a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

J. Barstow A copy of the Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 332 to DPR-33

2. Amendment No. 355 to DPR-52

3. Amendment No. 315 to DPR-68

4. Safety Evaluation cc: Listserv

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 332 Renewed License No. DPR-33

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Tennessee Valley Authority (the licensee) dated March 10, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 332, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by David David J. J. Wrona Date: 2023.09.08 Wrona 22:54:11 -04'00' David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: September 8, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 332 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 BROWNS FERRY NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-259 Replace the following pages of the Renewed Facility Operating License and Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License DPR-33 License DPR-33 Page 3 Page 3 TSs TSs 3.4-18 3.4-18 3.4-19 3.4-19

-- 3.4-19a 3.4-21 3.4-21 3.4-22 3.4-22

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 332, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 332

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystem inoperable. removal is available.

AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

BFN-UNIT 1 3.4-18 Amendment No. 234, 249, 332

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated RHR shutdown cooling Completion Time of subsystem to OPERABLE Condition A not met. status.

C. Two required RHR C.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems removal is available for AND inoperable. each inoperable RHR shutdown cooling Once per 24 subsystem hours thereafter D. Required Action and -------------------NOTE----------------- Immediately associated LCO 3.0.3 and all other LCO Completion Time of Required Actions requiring a Condition C not met. MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

(continued)

BFN-UNIT 1 3.4-19 Amendment No. 234, 332

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown E.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown operation. cooling subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

E.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND E.3 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 1 3.4-19a Amendment No. 234, 332

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action restore RHR Immediately associated Completion shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

BFN-UNIT 1 3.4-21 Amendment No. 234, 332

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 1 3.4-22 Amendment No. 234, 332

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 355 Renewed License No. DPR-52

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated March 10, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-52 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 355, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by David David J. J. Wrona Date: 2023.09.08 Wrona 22:54:41 -04'00' David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: September 8, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 355 RENEWED FACILITY OPERATING LICENSE NO. DPR-52 BROWNS FERRY NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-260 Replace the following pages of the Renewed Facility Operating License and Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License DPR-52 License DPR-52 Page 3 Page 3 TSs TSs 3.4-18 3.4-18 3.4-19 3.4-19

-- 3.4-19a 3.4-21 3.4-21 3.4-22 3.4-22

sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 355, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 253. For SRs that existed prior to Amendment 253, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 253.

3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 355

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystem inoperable. removal is available. AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

BFN-UNIT 2 3.4-18 Amendment No. 253, 286, 355

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem to OPERABLE met. status.

C. Two required RHR C.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems inoperable. removal is available for each inoperable RHR AND shutdown cooling subsystem.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter D. Required Action and ------------------NOTE------------------ Immediately associated Completion LCO 3.0.3 and all other LCO Time of Condition C not Required Actions requiring a met. MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

(continued)

BFN-UNIT 2 3.4-19 Amendment No. 253, 355

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown E.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown operation. cooling subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

E.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND E.3 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 2 3.4-19a Amendment No. 253, 355

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

BFN-UNIT 2 3.4-21 Amendment No. 253, 355

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 2 3.4-22 Amendment No. 253, 355

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 315 Renewed License No. DPR-68

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated March 10, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 3

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-68 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 315, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by David David J. J. Wrona Date: 2023.09.08 Wrona 22:55:08 -04'00' David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: September 8, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 315 RENEWED FACILITY OPERATING LICENSE NO. DPR-68 BROWNS FERRY NUCLEAR PLANT, UNIT 3 DOCKET NO. 50-296 Replace the following pages of the Renewed Facility Operating License and Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License DPR-68 License DPR-68 Page 3 Page 3 TSs TSs 3.4-18 3.4-18 3.4-19 3.4-19

-- 3.4-19a 3.4-21 3.4-21 3.4-22 3.4-22

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 315, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 212.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 315

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystem inoperable. removal is available. AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

BFN-UNIT 3 3.4-18 Amendment No. 212, 244, 315

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem to OPERABLE met. status.

C. Two required RHR C.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling method of decay heat subsystems inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 subsystem. hours thereafter D. Required Action and ------------------NOTE------------------ Immediately associated Completion

Time of Condition C not LCO 3.0.3 and all other LCO meW. Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore one RHR shutdown cooling subsystem to OPERABLE status.

(continued)

BFN-UNIT 3 3.4-19 Amendment No. 212, 315

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown E.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown operation. cooling subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

E.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND E.3 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 3 3.4-19a Amendment No. 212, 315

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may not be in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

BFN-UNIT 3 3.4-21 Amendment No. 212, 315

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in circulating by an alternate discovery of no operation. method. reactor coolant circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature and pressure.

BFN-UNIT 3 3.4-22 Amendment No. 212, 315

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 332, 355, AND 315 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-33, DPR-52, AND DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296

1.0 INTRODUCTION

By Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4|letter dated March 10, 2023]] (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23069A100), the Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (Browns Ferry or BFN), Units 1, 2, and 3. The amendments would revise technical specification (TS) actions for inoperable residual heat removal (RHR) shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation (LCOs), and would provide a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

The proposed changes are based on Technical Specifications Task Force Traveler (TSTF)-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystem (ML18019B187), and TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling (ML21025A232). The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation (SE) approving TSTF-566, Revision 0, on February 21, 2019 (ML19028A287), and TSTF-580, Revision 1, on July 11, 2021 (ML21188A227).

The licensee has proposed variations from the TS changes described in TSTF-566, Revision 0, and TSTF-580-A, Revision 1. The variations are described in section 2.3 of this SE and are evaluated in section 3.3.

2.0 REGULATORY EVALUATION

2.1 System Description Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to less than or equal to 212 degrees Fahrenheit

(°F). This decay heat is removed by the RHR shutdown cooling system in preparation for Enclosure 4

performing refueling or maintenance operations, or for keeping the reactor in the hot shutdown condition or cold shutdown condition.

The RHR system has two loops with each loop consisting of two motor-driven pumps, two heat exchangers, and associated piping and valves. There are two RHR shutdown cooling subsystems per RHR system loop. Both loops have a common suction from the same recirculation loop. The four redundant, manually controlled shutdown cooling subsystems of the RHR system provide decay heat removal. Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via the associated recirculation loop. The RHR heat exchangers transfer heat to the RHR service water system. Any one of the four RHR shutdown cooling subsystems can provide the required decay heat removal function.

Technical Specification 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, is applicable in Mode 3 with reactor steam dome pressure lower than the RHR low pressure permissive pressure. Technical Specification 3.4.8, Residual Heat Removal (RHR)

Shutdown Cooling System - Cold Shutdown, is applicable in Mode 4. They both require two operable RHR shutdown cooling subsystems and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem in operation.

2.2 Licensees Proposed Changes The licensee proposed to revise TS actions for inoperable RHR shutdown cooling subsystems in the RHR shutdown cooling system LCOs, consistent with TSTF-566, Revision 0, and TSTF-580, Revision 1. The proposed changes would revise TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, and TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, for Browns Ferry. The proposed changes are described below.

2.2.1 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of Browns Ferry TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, require the operators to initiate action to restore RHR shutdown cooling subsystem(s) to operable status (Required Action A.1) immediately, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.2) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and be in Mode 4 (Required Action A.3) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

In accordance with NRC staff-approved TSTF-566 and TSTF-580, the licensee proposed changes that would revise TS 3.4.7, for Browns Ferry, as follows:

Condition A is changed to be limited to a single inoperable subsystem by revising it to state: One required RHR shutdown cooling subsystem inoperable. Accordingly, a conforming change is proposed to current Required Action A.2.

The Required Action A.1 is moved to new Condition B (as Required Action B.1) and Required Action A.3 is deleted. The LAR also proposed to add a recurring completion time (CT) to current Required Action A.2 of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. The proposed changes also renumber current Required Action A.2 as A.1 since Required Actions A.1 and A.3 are removed from Condition A.

A new Condition B is added to address the potential situation where, The Required Action and associated Completion Time of Condition A are not met. New Condition Bs Required Action B.1 is moved from current Required Action A.1 and requires operators to initiate action to restore the RHR shutdown cooling subsystem to operable status immediately. Because Condition A is proposed to be revised to address a single inoperable RHR shutdown cooling subsystem, Required Action B.1 also only addresses a single RHR shutdown cooling subsystem.

A new Condition C is added which addresses two RHR shutdown cooling subsystems inoperable with a Required Action C.1 to verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem. The new Condition C Required Action has a CT of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

A new Condition D is added to address situations where new Required Action C.1 and associated CT are not met. New Required Action D.1 requires action be initiated to restore one RHR shutdown cooling subsystem to operable status immediately. Required Action D.1 is modified by a note that states that LCO 3.0.3 and all other LCO Required Actions requiring a mode change to Mode 4 may be suspended until one RHR shutdown cooling subsystem is restored to operable status.

Existing Condition B and associated Required Actions are renumbered as E, E.1, E.2, and E.3, respectively, as a result of new Conditions B, C, and D.

2.2.2 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, require the operators to verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.1) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

The licensee proposed a new Condition B for when the required action and associated CT of Condition A are not met which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

Because new Condition B is being added, current Condition B and its required actions are renamed C, C.1, and C.2, respectively.

2.3 Variations from TSTF-566 and TSTF-580 In addition to the changes proposed consistent with the travelers discussed in section 1.1, the licensee proposed the following variations.

2.3.1 Editorial Variations The licensee noted that Browns Ferry TSs have different numbering than the standard technical specifications (STSs). Specifically, STS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, correlates to Browns Ferry TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, and STS 3.4.9, Residual Heat Removal

(RHR) Shutdown Cooling System - Cold Shutdown, correlates to Browns Ferry TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown.

2.3.2 Plant-Specific Variations The Browns Ferry design is different than the model plant assumed in the STSs, but the TSTF-566 and TSTF-580 justification and the NRC staff's related SEs are still applicable.

The licensee states in the LAR:

TSTF-580-A, Revision 1 describes two Residual Heat Removal Service Water (RHRSW) subsystems that are required to be operable per NUREG-1433 TS 3.7.1, [Residual Heat Removal Service Water (RHRSW) System] and that having both RHRSW subsystems inoperable drives a shutdown Required Action if one subsystem cannot be restored in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . BFN TS 3.7.1 requires four RHRSW subsystems to be Operable per TS 3.7.1 and having three or more RHRSW subsystems inoperable drives a shutdown Required Action if one subsystem cannot be restored in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The distinction is that the NUREG-1433 reference plant has two separate RHRSW subsystems for each unit. BFN has a shared RHRSW of four subsystems between the three units.

2.3.3 Other Variations TSTF-566-A revises the Actions for TS 3.4.8, RHR Shutdown Cooling System - Hot Shutdown. TSTF-580-A makes further changes to the Actions of TS 3.4.8 that were revised by TSTF-566-A. TSTF-580-A states, Adoption of this change is dependent on previous adoption of TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems. The variation is that 566-A has not been adopted, and adoption of both TSTF 566-A and TSTF 580-A are proposed simultaneously.

2.4 Regulatory Review Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include in the application proposed TSs.

The regulation at 10 CFR 50.36(a)(1) states, in part: A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

The regulation at 10 CFR 50.36(b) requires:

Each license authorizing operation of autilization facilitywill include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The regulation at 10 CFR 50.36(c)(2) requires that TSs include LCOs. Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of

equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation at 10 CFR 50.40(a) states, in part, that the TSs shall provide reasonable assurance that the health and safety of the public will not be endangered.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, September 2021 (ML21272A357 and ML21272A358, respectively), as modified by NRC-approved travelers.

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown The licensee proposed to modify TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown. The technical evaluation of each change follows.

3.1.1 Evaluation of Changes to Condition A The licensee proposed to add a recurring CT to current Required Action A.2 of once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. Current Required Action A.2 requires verification that an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The NRC staff finds this change is acceptable because it requires continuous verification of alternate methods of decay heat removal every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , provides assurance of continued heat removal capability, and is consistent with the changes found acceptable in TSTF-566.

The licensee also proposed to delete current Required Action A.3, which requires the plant to be in Mode 4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one or two RHR shutdown cooling subsystems are inoperable.

Current Required Action A.3 requires operators to reduce the reactor coolant system temperature to the point where Mode 4 is entered, due to the potentially reduced reliability of the alternate methods of decay heat removal. However, if there is no operable RHR shutdown cooling subsystem and the plant is in a period of high decay heat load, it may not be possible to reduce the average reactor coolant system temperature to the Mode 4 entry condition (less than or equal to 212 °F) within the CT. In addition, in a typical boiling-water reactor (BWR) design, the RHR shutdown cooling system has a heat rejection capability many times greater than alternate methods available. Therefore, for periods in which there is high decay heat load, the BWR design does not include any system which can satisfy Required Action A.3. The NRC staff finds the deletion of current Required Action A.3 acceptable because, below the RHR cut in permissive pressure, the remaining required action will ensure that fission product decay heat and other residual heat from the reactor core is transferred at a rate such that the specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded. This change is consistent with the changes found acceptable in TSTF-566.

Condition A is changed to be limited to a single inoperable subsystem by revising it to state:

One RHR shutdown cooling subsystem inoperable. Accordingly, a conforming change is made to proposed Required Action A.1. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-580 are applicable because Browns Ferry is a BWR design plant, and the NRC staff approved the TSTF-580 changes for BWR designs.

This change is consistent with the changes found acceptable in TSTF-580.

Current Required Action A.2 is renumbered as A.1, since Required Actions A.1 and A.3 are removed from Condition A. The NRC staff finds this change is acceptable since it provides the correct number sequence. This change is consistent with the changes found acceptable in TSTF-566.

3.1.2 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A are not met. New Condition Bs required action, B.1, is moved from current Required Action A.1 and requires operators to initiate action to restore RHR shutdown cooling subsystems to operable status immediately. The NRC staff finds that relocating the required action from A.1 to new Required Action B.1 is acceptable because other ways of removing decay heat are available, such as natural circulation, the spent fuel pool cooling system, the reactor water cleanup system, and an inoperable, but functional, RHR shutdown cooling subsystem. This change is consistent with the changes found acceptable in TSTF-566.

New Condition B addresses situations when Required Action A.1 and associated CT are not met. Because Condition A now addresses a single inoperable RHR shutdown cooling subsystem, conforming changes were made to Required Action B.1 (formerly Required Action A.1) to address a single RHR shutdown cooling subsystem. This change is consistent with the changes found acceptable in TSTF-580.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem to operable status. The CT term immediately is defined in Section 1.3 of the Browns Ferry TSs as, the Required Action should be pursued without delay and in a controlled manner. New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B, with its Required Action B.1, provides an appropriate terminal action for when an alternate method cannot be established within the CT established in Condition A. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal. This change is consistent with the changes found acceptable in TSTF-566.

3.1.3 Evaluation of New Condition C A new Condition C is added which addresses two RHR shutdown cooling subsystems inoperable with a Required Action C.1 to verify that an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem. The new Condition C Required Action has a CT of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-580 are applicable because Browns Ferry is a BWR design plant, and the NRC staff approved the TSTF-580 changes for BWR designs. This change is consistent with the changes found acceptable in TSTF-580.

3.1.4 Evaluation of New Condition D A new Condition D is added to address situations when new Required Action C.1 and associated CT are not met. New Required Action D.1 requires action be initiated to restore one RHR shutdown cooling subsystem to operable status immediately. Required Action D.1 is modified by a note that states that LCO 3.0.3 and all other LCO Required Actions requiring a mode change to Mode 4 may be suspended until one RHR shutdown cooling subsystem is restored to operable status.

In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-580 are applicable because Browns Ferry is a BWR design plant, and the NRC staff approved the TSTF-580 changes for BWR designs. In the SE for TSTF-580, the NRC staff concluded that TSTF-580 changes to STS 3.4.7, Residual Heat Removal (RHR)

Shutdown Cooling System - Hot Shutdown, are acceptable because, without an operable RHR shutdown cooling subsystem and in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition within the CT.

Under this condition, remaining in Mode 3 allows fission product decay heat and other residual heat from the reactor core to be transferred at a rate such that the specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary will not be exceeded. The CT reflects the importance of restoring a normal path for heat removal.

Therefore, the NRC staff finds that proposed new Condition D, including its associated Required Action A.1 and CT, is acceptable because it continues to meet the requirements of 10 CFR 50.36(c)(2)(i), by providing remedial actions and shutting down the reactor if the remedial actions cannot be met. This change is consistent with the changes found acceptable in TSTF-580.

3.1.5 Evaluation of Changes to Existing Condition B Current Condition B and its required actions were renamed E, E.1, E.2, and E.3, respectively, since new Conditions B, C, and D were added. The NRC staff finds this change is acceptable since it provides the correct number sequence. These changes are consistent with the changes found acceptable in TSTF-566 and TSTF-580.

3.1.6 Conclusion of Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown The NRC staff concludes the proposed changes are acceptable since the TS continues to meet the requirements of 10 CFR 50.40(a) because it provides reasonable assurance that the health and safety of the public will not be endangered. The proposed changes also continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and are consistent with the changes previously found acceptable in TSTF-566 and TSTF-580.

3.2 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown The licensee proposed to modify TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown. The technical evaluation of each change follows.

3.2.1 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT term immediately is defined in Section 1.3 of the Browns Ferry TSs as, the Required Action should be pursued without delay and in a controlled manner. New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B with its Required Action B.1 provide an appropriate terminal action for when an alternate method cannot be established within the CT established in Condition A. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal. This change is consistent with the changes found acceptable in TSTF-566.

3.2.2 Evaluation of Changes to Existing Condition B Current Condition B and its required actions were renamed C, C.1, and C.2, respectively, since new Condition B was added. The NRC staff finds this change is acceptable since it provides the correct number sequence. This change is consistent with the changes found acceptable in TSTF-566.

3.2.3 Conclusion of Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown The NRC staff concludes the proposed changes are acceptable since the TS continues to meet the requirements of 10 CFR 50.40(a) because it provides reasonable assurance that the health and safety of the public will not be endangered. The proposed changes also continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and are consistent with the changes previously found acceptable in TSTF-566.

3.3 Additional Proposed TS Changes 3.3.1 Editorial Changes The licensee noted that Browns Ferry TSs have different numbering than the STS. The NRC staff finds that the different TS numbering changes are acceptable because they do not substantively alter TS requirements.

3.3.2 Plant Specific Variations The Browns Ferry design is different than the model plant assumed in the STSs, but the TSTF-580 justification and the NRC staff's SEs are still applicable. The staff has reviewed the site-specific differences described in section 2.3.2 of this SE and finds that TSTF-580-A is still applicable to Browns Ferry because the TSTF-580-A requirement that at least one RHR shutdown cooling subsystem be operable before a required unit entry into Mode 4 is maintained with the Browns Ferry design configuration.

3.3.3 Other Variations TSTF-566-A revises the Actions for TS 3.4.8, RHR Shutdown Cooling System - Hot Shutdown. TSTF-580-A makes further changes to the Actions of TS 3.4.8 that were revised by TSTF-566-A, which is consistent with the staff's approval of TSTF-580-A. TSTF-580-A states, Adoption of this change is dependent on previous adoption of TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems. The staff finds that adoption of both travelers simultaneously as proposed in the LAR satisfies this TSTF 580-A requirement because the changes included in TSTF 566-A will be adopted and the adoption of both travelers simultaneously is, therefore, acceptable.

3.4 TS Change Consistency The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with Chapter 16.0 of the SRP and are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Alabama State official was notified of the proposed issuance of the amendments on July 18, 2023. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The NRC has previously issued a proposed finding that the amendments involve no significant hazards consideration in the Federal Register on May 16, 2023 (88 FR 31285), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the

amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: J. Wilson, NRR Date: September 8, 2023

ML23205A213 OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/LA NRR/DSS/STSB/BC NAME TSierra RButler VCusumano DATE 7/24/23 7/28/23 7/17/23 OFFICE OGC - NLO NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME STurk DWrona KGreen DATE 9/1/23 9/8/23 9/8/23

v t e Letter Sequence Approval
EPID:L-2023-LLA-0035, TSTF-566, TSTF-580 (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other: ML23257A123
MONTHYEAR2023-09-22 [Table View]

ML23205A213

Text

SUBJECT:

Dear Mr. Barstow:

Enclosures:

Attachment:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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