Text

License Amendment Request to Adopt TSTF-286, TSTF-471, TSTF-571-T
	ML25076A032
Person / Time
Site:	Braidwood, Byron
Issue date:	03/14/2025
From:	Steinman R; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RS-25-016
	Download: ML25076A032 (1)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-25-016 0DUFK , 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

License Amendment Request to Adopt TSTF-286, TSTF-471, and TSTF-571-T

References:

1.

TSTF-286, Revision 2, "Define 'Operations Involving Positive Reactivity Additions'," dated on July 6, 2000 (ML20106F133) 2.

TSTF-471, Revision 1, "Eliminate Use of Term CORE ALTERATIONS in ACTIONS and NOTES," dated December 7, 2006 (ML19101A215) 3.

TSTF-571-T, Revision 0, "Revise Actions for Inoperable Source Range Neutron Flux Monitor," dated March 14, 2018 (ML18221A561) 4.

NRC NUREG-1431, "Westinghouse Standard Technical Specification (STS) in NUREG," Revision 5, dated September 2021 (ML21259A159)

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood); Renewed Facility Operating License NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron). CEG requests adoption of TSTF-286, Revision 2, "Define 'Operations Involving Positive Reactivity Additions'," (Reference 1), TSTF-471, Revision 1, "Eliminate Use of Term CORE ALTERATIONS in ACTIONS and NOTES," (Reference 2) and TSTF-571-T, Revision 0, "Revise Actions for Inoperable Source Range Neutron Flux Monitor," (Reference 3) into the Braidwood and Byron Technical Specifications (TS). The proposed amendment is being requested to align site-specific TS more accurately, as technically practical, with the Westinghouse Standard Technical Specification (STS) in NUREG-1431, Revision 5 (Reference 4).

0DUFK, 2025 U.S. Nuclear Regulatory Commission Page 2 provides a description and assessment of the proposed changes. Attachments 2 and 3 provide the existing TS pages marked-up to show the proposed TS changes.

Attachments 4 and 5 provide TS Bases pages marked up to show the associated TS Bases changes and are provided for information only.

The proposed changes have been reviewed by the Braidwood and Byron Plant Operations Review Committees, in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests approval of the proposed license amendments by 0DUFK, 2026. The Braidwood and Byron implementation will occur within 90 days from approval.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Mrs. Danii Gantt at (779) 231-6227.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the th day of 0DUFK2025.

Respectfully, Rebecca L. Steinman Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1.

Evaluation of Proposed Changes 2.

Proposed Technical Specifications Changes (Mark-up), Braidwood Station, Units 1 and 2 3.

Proposed Technical Specifications Changes (Mark-up), Byron Station, Units 1 and 2 4.

Proposed Technical Specifications Bases Changes (Mark-up) - For Information Only, Braidwood Station Units 1 and 2 5.

Proposed Technical Specifications Bases Changes (Mark-up) - For Information Only, Byron Station, Units 1 and 2

Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2025.03.14 15:47:24 -05'00'

0DUFK, 2025 U.S. Nuclear Regulatory Commission Page 3 cc:

NRC NRR Project Manager - Braidwood / Byron NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station Illinois Emergency Management Agency - Division of Nuclear Safety Evaluation of Proposed Changes Page 1 of

Subject:

License Amendment Request to Adopt TSTF-286, TSTF-471, and TSTF-571-T 1.0 Summary Description 2.0 Detailed Description

2.1 Background

2.2 Proposed Changes 2.3 Variations 3.0 Technical Evaluation 3.1 System Descriptions 3.2 Accident Analysis 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions 5.0 Environmental Consideration 6.0 References Evaluation of Proposed Changes 1.0 Summary Description In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood); Renewed Facility Operating License NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron). CEG requests adoption of TSTF-286, Revision 2, "Define 'Operations Involving Positive Reactivity Additions'," (Reference 6.1), TSTF-471, Revision 1, "Eliminate Use of Term CORE ALTERATIONS in ACTIONS and NOTES," (Reference 6.2) and TSTF-571-T, Revision 0, "Revise Actions for Inoperable Source Range Neutron Flux Monitor,"

(Reference 6.3) into the Braidwood and Byron Technical Specifications (TS). The proposed amendment is being requested to align site-specific TS more accurately, as technically practical, with the Westinghouse Standard Technical Specification (STS) in NUREG-1431 (Reference 6.11), Revision 5.

2.0 Detailed Description

2.1 Background

The proposed change will adopt three Technical Specification Task Force (TSTF) Travelers into the Braidwood and Byron site-specific TS. The combination of these three Travelers results in added flexibility and removes operator burden associated with current requirements that do not provide a corresponding safety benefit. The proposed changes would also align the Braidwood and Byron TS more closely with the STS described in NUREG-1431 (Reference 6.11).

TSTF-286 revises TS LCO Actions and Notes that require suspension of operations involving positive reactivity additions or preclude reduction in boron concentration by placing a limit on positive reactivity addition to within the TS required shutdown margin (SDM) limit. The Actions that prohibit positive reactivity changes and/or reduction in boron concentration ensure either no power increases, or continued margin to core criticality operations. During conditions in which these Actions may be required, RCS inventory must be maintained, and RCS temperature must be controlled. These activities involve additions to the RCS of cooler water (a positive reactivity effect in most cases) and may involve inventory makeup from sources that are at boron concentrations less than the RCS concentration. These activities should not be prevented if the worst-case overall effect on the core would still assure SDM (or the required refueling boron concentration) is maintained. The TSTF changes permit operators to control RCS inventory and temperature while maintaining positive control of core reactivity.

As part of the adoption of TSTF-51 (Reference 6.8), a new definition of RECENTLY IRRADIATED FUEL (i.e., fuel that has occupied part of a critical reactor core within the previous 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) was added to the TS definitions as part of License Amendment No.147 for Byron and License Amendment No. 140 to Braidwood (Reference 6.9). As part of the addition of the term RECENTLY IRRADIATED FUEL and the partial adoption of TSTF-51, CEG has previously committed to the applicable provisions of Nuclear Utilities Management and Resources CounFil (NUMARC) 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3.

Page 2 of 12 Evaluation of Proposed Changes TSTF-471 eliminates the defined term CORE ALTERATIONS from the TS. CORE

ALTERATIONS is defined in the TS as, "CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position." The Byron and Braidwood UFSAR Section 15.7.4, "Fuel Handling Accidents (FHA)," defines a FHA as the drop of a spent fuel assembly onto the spent fuel pool floor or the core, resulting in the postulated rupture of the cladding of all the fuel rods in one assembly. Suspension of CORE ALTERATIONS, except for suspension of movement of LUUDGLDWHGIXHO, will not prevent or impair the mitigation of a fuel handling accident. A boron dilution accident is initiated by a dilution source which results in the boron concentration dropping below that required to maintain the SHUTDOWN MARGIN. With the exception of suspending movement of LUUDGLDWHGIXHO assemblies, there are no design basis accidents (DBAs) or transients that are initiated by, or mitigation affected by, suspension of CORE ALTERATIONS. If all Required Actions that require suspension of CORE ALTERATIONS also require suspension of movement of LUUDGLDWHGIXHO, suspension of CORE ALTERATIONS provides no safety benefit.

TSTF-571-T comes after a letter from the NRC to the TSTF dated November 7, 2013, (Reference 6.4) described NRC staff concerns with the subject travelers. The NRC staff clarified their concern with the Required Actions in the Nuclear Instrumentation specification when one source range monitor (SRM) is inoperable. The SRMs are used during refueling operations to monitor the core reactivity condition. These detectors are located external to the reactor vessel and detect neutrons leaking from the core. The detectors monitor the neutron flux and provide continuous visual indication in the control room and an audible alarm to alert the operators.

In MODE 6, the SRMs must be operable to determine changes in core reactivity. There is no other direct means available to monitor core reactivity levels. During movement of fuel assemblies, sources, and reactivity control components with one SRM inoperable, there is the potential for the operable SRM to become effectively decoupled from the core reactivity condition. Therefore, the changes made in TSTF-286 and TSTF-471 may create a situation in which an increase in neutron flux might go undetected. In a letter dated October 4, 2018 (Reference 6.5), it was concluded that adoption of TSTF-571-T would resolve the concern discussed above.

2.2 Proposed Changes TS 1.1 CORE ALTERATIONS definition will be deleted.

A Note will be added before Required Action G.1 and H.1 in TS 3.3.1 that reads "Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM".

Letter a. of the Note for TS 3.4.5, 3.4.6, and 3.4.7 will be changed from "No operations are permitted that would cause reduction of the RCS boron concentration; and" to "No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and".

Page 3 of 12 Evaluation of Proposed Changes Letter a. of the Notes for TS 3.4.8 will be changed from "No operations are permitted that would cause a reduction of the RCS boron concentration;" to "No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1;".

Required Action A.1 of TS 3.4.6, 3.4.7, 3.4.8 and Required Action C.1 of TS 3.4.6 and TS 3.4.8 will be changed from "Suspend all operations involving a reduction in RCS boron concentration" to "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1".

Required Action B.1, C.2, F.2 of TS 3.4.5 and Required Action D.1 of TS 3.4.7 will be changed from "Suspend all operations involving a reduction of RCS boron concentration" to "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1".

LCO 3.4.18 a of TS 3.4.18 will be changed from "required SDM boron concentration of the unisolated portion of the RCS;" to " boron concentration required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1";

SR 3.4.18.2 of TS 3.4.18 will be changed from "the required SDM boron concentration of the unisolated portion of the RCS" to " boron concentration required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1".

For TS 3.8.2, 3.8.5, 3.8.8 and 3.8.10 Required Action A.2.1 "Suspend CORE ALTERATIONS" will be deleted and subsequent Required Action numbers will be changed. The updated Required Action A.2.2 will be changed from "Initiate action to suspend operations involving positive reactivity additions." to "Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration".

For TS 3.8.2, Required Action B.1 "Suspend CORE ALTERATIONS" will be deleted and subsequent Required Action numbers will be changed. The updated Required Action B.2 will be changed from "Initiate action to suspend operations involving positive reactivity additions." to "Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration".

For TS 3.9.1 and 3.9.2 Required Action A.1 "Suspend CORE ALTERATIONS" will be deleted and subsequent Required Action numbers will be changed.

For TS 3.9.2 Condition A NOTE will be changed from A.3 to A.2.

For TS 3.9.3, Required Action A.1 "Suspend CORE ALTERATIONS" will be replaced with "Suspend positive reactivity additions." Required Action A.2 "Suspend positive reactivity additions will be replaced with a Note stating, "Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition" followed by Required Action A.2 "Suspend movement of fuel, sources, and reactivity control components within the reactor vessel".

For TS 3.9.5, the Note for LCO 3.9.5 will change from " reduction of the Reactor Coolant System boron concentration." to " introduction of coolant into the Reactor Coolant System with Page 4 of 12 Evaluation of Proposed Changes boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1".

For TS 3.9.5, Required Action A.1 "Suspend operations involving a reduction in reactor coolant boron concentration." will be replaced with "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1".

For TS 3.9.6, Required Action B.1 "Suspend operations involving a reduction in reactor coolant boron concentration." will be replaced with "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1".

2.3 Variations The changes in TSTF-286 for TS 3.3.9 will not be adopted into Braidwood and Byron's TS changes because Braidwood and Byron depend on a combination of alarms, indicators, procedures and controls and will rely on manual operator actions in accordance with the previously NRC approved amendment, but the STS version of 3.3.9 depends on two channels of source range instrumentation to automatically initiate protective actions. Due to the uncertainties associated with the indication of a true neutron flux doubling by the source range nuclear instrumentation, the mitigation effectiveness of the Boron Dilution Protection System (BDPS) may be unreliable. Discussion of this can be found in the NRC Information notice 93-32, "Non-conservative Inputs Fix Boron Dilution Event Analysis" (Reference 6.10). These changes were approved by the NRC in 2001 with the issuance of Amendment No. 111 to Braidwood and Amendment No. 117 to Byron (Reference 6.12).

TS 3.4.5 Required Action F.2 in Braidwood and Byron's TS is a variation from TSTF-286 Condition D change for TS 3.4.5. For Braidwood and Byron, 3.4.5 is separated into three conditions resulting in changes to TS 3.4.5 Required Actions B.1, C.2 and F.2.

3.0 Technical Evaluation 3.1 System Descriptions Reactor Trip System (RTS) Instrumentation (TS 3.3.1)

The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during Anticipated Operational Occurrences (AOOs) and to assist the Engineered Safety Functions (ESF) Systems in mitigating accidents. In Modes 1 and 2 when critical, SDM is ensured by complying with TS 3.1.4, Rod Group Alignment limits, TS 3.1.5, Shutdown Bank Insertion Limit, and TS 3.1.6, Control bank Insertion Limit. When the SDM is maintained, the Required Action to suspend operations involving positive reactivity additions is unnecessarily restrictive to plant operations.

Allowance for limited plant cooldown or boron dilution adds to plant operation flexibility without compromising plant safety.

Page 5 of 12 Evaluation of Proposed Changes RCS Loops-MODE 3 (TS 3.4.5) / MODE 4 (TS 3.4.6) / MODE 5, Loops Filled (TS 3.4.7) /

MODE 5, Loops Not Filled (TS 3.4.8) / Isolated (TS 3.4.18)

In MODE 3 and MODE 4, the primary function of the reactor coolant is removal of decay heat and transfer of this heat, via the Steam Generator (SG), to the secondary plant fluid. A secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and transfer this heat either to the SG secondary side coolant via natural circulation or the component cooling water via the RHR heat exchangers. While the principal means for decay heat removal is via the RHR System, the SGs via natural circulation are specified as a backup means for redundancy. Even though the SGs cannot produce steam in this condition, they are capable of being a heat sink due to their large, contained volume of secondary water. If the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat generated in the fuel, and the transfer of this heat to the component cooling water via the RHR heat exchangers. The SGs are not available as a heat sink when the loops are not filled. Changes to the TS permits operation of the plant if the changes are accounted for in the SDM calculation rather than restricting all plant changes that may change the boron concentration. If the coolant added is at boron concentrations greater than required to assure that LCO 3.1.1 is maintained, plant operations can continue and there is no consequence to safe operation.

AC Sources (TS 3.8.2), DC Sources (TS 3.8.5), Inverters (TS 3.8.8) and Distribution Systems (TS 3.8.10)

If a required train of electrical power (AC, DC, Inverters, or Distribution Systems) is inoperable, the current Required Actions create an operational burden by diverting the operator's attention from safety significant issues to an administrative control that is not credited in the accident analyses. Operators are required to track the operability of equipment that is not needed during CORE ALTERATIONS which is purely an administrative function. The administrative burden of tracking operable equipment and responding to the loss of that equipment is not justified for an activity that has no impact on the safety analyses. The action to suspend CORE ALTERATIONS provides no safety benefit and is not needed. Additionally, allowing plant operations to continue provided any positive reactivity additions do not result in a loss of required SDM or boron concentration provides flexibility rather than restricting all plant changes that may change the SDM or boron concentration in any capacity.

Boron Concentration (TS 3.9.1)

The boron concentration TS is concerned with a boron dilution accident, as SDM has no bearing on a fuel handling accident. Note that the Required Action to suspend positive reactivity additions would also prohibit adding fuel assemblies to the reactor, which could reduce the SDM. The requirement to suspend positive reactivity additions is the only action needed to mitigate a boron dilution event. If CORE ALTERATIONS are being performed during Mode 6 (the Applicability for TS 3.9.1), they must be suspended if the required boron concentration is not maintained however, CORE ALTERATIONS would not mitigate a boron dilution event. This can create an operational burden by diverting the operator's attention from safety significant issues to an administrative control that is not credited in the accident analyses by requiring operators to track a boron concentration that is not needed during CORE ALTERATIONS, which is an administrative function. The administrative burden of tracking the boron concentration is not justified for an activity (CORE ALTERATIONS) that has no impact on the safety analyses.

Page 6 of 12 Evaluation of Proposed Changes Unborated Water Source Isolation Valves (TS 3.9.2)

If one or more unborated water source isolation valves are not secured in the closed position, CORE ALTERATIONS must be suspended, and actions taken to secure the valve in the closed position. The purpose of this TS is to prevent a boron dilution accident. CORE ALTERATIONS have no effect on a boron dilution accident, either as an initiator or as mitigation. Suspending CORE ALTERATIONS when a valve is not secured does not provide compensation or reduce the probability of the event. The action to suspend CORE ALTERATIONS provides no safety benefit and is not needed.

Nuclear Instrumentation (TS 3.9.3)

The source range neutron flux monitors are used during refueling operations to monitor the core reactivity condition. The installed source range neutron flux monitors are part of the Nuclear Instrumentation System (NIS). These detectors are located external to the reactor vessel and detect neutrons leaking from the core. The TS requires that two source range neutron flux monitors be OPERABLE to ensure that redundant monitoring capability is available to detect changes in core reactivity. Required Actions A.1 and A.2 ensure that positive reactivity is not inadvertently added to the reactor core while the source range neutron flux monitor is inoperable. If CORE ALTERATIONS are being performed during Mode 6 (the Applicability for this TS), they must be suspended if the required nuclear instrumentation is determined to be inoperable. This can create an operational burden by diverting the operator's attention from safety significant issues to an administrative control that is not credited in the accident analyses by requiring the operators to track the operability of equipment that is not needed during CORE ALTERATIONS.

Residual Heat Removal (RHR) and Coolant Circulation-High Water Level (TS 3.9.5) / Low Water Level (TS 3.9.6)

The RHR System in MODE 6 is to remove decay heat and sensible heat from the RCS. If the reactor coolant temperature is not maintained below 200 degrees Fahrenheit, boiling of the reactor coolant could result. This could lead to a loss of coolant in the reactor vessel. In addition, boiling of the reactor coolant could lead to a reduction in boron concentration in the coolant due to boron plating out on components near the areas of the boiling activity. The loss of reactor coolant and the reduction of boron concentration in the reactor coolant would eventually challenge the integrity of the fuel cladding, which is a fission product barrier.

Updating the TS permits operation of the plant if the changes are with coolant at boron concentrations greater than required to assure the RCS boron concentration does not challenge LCO 3.9.1 rather than restricting all plant changes that may change the boron concentration in any capacity.

3.2 Accident Analysis The minimum required SDM is assumed as an initial condition in the safety analysis. The safety analysis establishes a SDM that ensures specified acceptable fuel design limits are not exceeded for normal operation and Anticipated Operational Occurrences (AOOs), with the assumption of the highest worth rod stuck out on a reactor trip.

The acceptance criteria for the SDM requirements are that specified acceptable fuel design limits are not exceeded. This is done by ensuring the reactor can be made subcritical from all operating conditions, transients and Design Basis Accidents (DBAs); The reactivity transients associated with postulated accident conditions are controllable within acceptable limits (Departure from Nucleate Boiling Ration (DNBR)), fuel centerline temperature limits for AOOs; Page 7 of 12 Evaluation of Proposed Changes and the reactor will be maintained sufficiently subcritical to preclude the inadvertent criticality in the shutdown condition.

The proposed changes are not altering the acceptance criteria for the SDM TS 3.1.1 and the limits referenced in LCO 3.1.1 remain unchanged. The changes being made to the technical specifications in this LAR have no impact to any assumptions or inputs to the Byron and Braidwood safety analyses. All current safety analyses remain valid and unchanged with the introduction of these changes; therefore, these changes are acceptable.

4.0 Regulatory Analysis 4.1 Applicable Regulatory Requirements/Criteria The regulatory requirements associated with this amendment application include the following:

10 CFR 50.36, "Technical specifications," details the content and information that must be included in a station's Technical Specifications (TS). In accordance with 10 CFR 50.36, TSs are required to include (1) safety limits, limiting safety system settings, and limiting control settings; (2)limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5)

administrative controls.

Appendix A to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), General Design Criteria (GDC) 61, "Fuel storage and handling and radioactivity control," requires that fuel storage systems be designed to assure adequate safety under normal and postulated accident conditions. The criticality safety evaluation demonstrates continued conformance with GDC 61. No administrative or physical changes are proposed that affect the ability to perform inspections, testing, shielding for radiation protection, confinement and filtering of potential effluents, or decay heat removal, nor is there any impact on assumed fuel storage coolant inventory under accident conditions.

4.2 Precedent A submittal to adopt TSTF-286 was approved on June 8, 2011, by the NRC for R.E. Ginna Nuclear Power Plant. (Reference 6.6) based on the required minimum SDM of LCO 3.1.1 and boron concentration of LCO 3.9.1 being maintained after proposed changes are made.

A submittal to adopt TSTF-471 and TSTF-571-T was approved on April 1, 2022, by the NRC for Prairie Island Units 1 and 2. (Reference 6.7) based on the changes being consistent with the STS and would not compromise the required minimum SDM of LCO 3.1.1 and boron concentration of LCO 3.9.1.

4.3 No Significant Hazards Consideration CEG has evaluated whether a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Page 8 of 12 Evaluation of Proposed Changes Page 9 of 12

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

CORE ALTERATIONS are not an initiator of any accident previously evaluated except a fuel handling accident. Those revised Specifications which protect the initial conditions of a fuel handling accident also require the suspension of movement of LUUDGLDWHGIXHO assemblies. This Required Action protects the initial conditions of a fuel handling accident and, therefore, suspension of CORE ALTERATIONS is not required.

Suspension of CORE ALTERATIONS does not provide mitigation of any accident previously evaluated. CORE ALTERATIONS do not affect the initiators of the accidents previously evaluated and suspension of CORE ALTERATIONS does not affect the mitigation of the accidents previously evaluated.

Additionally, the TSs addressed by changes related to TSTF-286 prevent inadvertent addition of positive reactivity which could challenge the SDM of the reactor core. The intent of the change is to allow small, controlled, and safe insertions of positive reactivity that are now categorically prohibited to allow operational flexibility. The proposed change does not permit the SDM to be reduced below that required by TS. The flexibility to operate the plant is maintained by limiting additions that do not challenge the SDM LCO and boron concentration LCO to assure safe shutdown. While the proposed changes will permit changes in discretionary boron concentration above the TS requirements, this excess concentration is not credited in the safety analysis. Because the initial conditions assumed in the safety analysis are preserved, no increase in the consequences of an accident previously evaluated would occur.

The restrictions prohibiting fuel movement when an SRM is inoperable, addressed in TSTF-571, ensure no changes in core reactivity have the potential to be unmonitored both ensure safe operation. The proposed changes mentioned do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a significant change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements.

The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and allow for minor plant operational adjustments without adversely impacting the safety analysis required SDM.

The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated and does not involve any change to plant equipment or the SDM requirements in the TS.

Evaluation of Proposed Changes

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change related to TSTF-471 removes CORE ALTERATION from Section 1.1, Definitions. Only two accidents are postulated to occur in the plant conditions in which CORE ALTERATIONS may be made: a fuel handling accident and a boron dilution accident. Suspending movement ofLUUDGLDWHGIXHO assemblies prevents a fuel handling accident. Also requiring the suspension of CORE ALTERATIONS is an overly broad, redundant requirement that does not increase the margin of safety. CORE ALTERATIONS have no effect on a boron dilution accident. Core components are not involved in the creation or mitigation of a boron dilution accident and the SHUTDOWN MARGIN limit is based on assuming the worst-case configuration of the core components. CORE ALTERATIONS have no effect on the margin of safety related to a boron dilution accident and changes to the flexibility in plant operations during fuel movement is required to be maintained within the SDM LCO and the boron concentration LCO.

Additionally, the proposed changes related to TSTF-286 will permit reductions in the discretionary SDM only within limits of the TS, thereby maintaining the margin of safety within the accident analysis.

Finally, proposed changes related to TSTF-571 requiring no fuel movements when an SRM is inoperable ensures no changes in the core reactivity go undetected. The proposed changes do not involve a significant reduction in a margin of safety.

CEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion These changes revise actions that either require suspension of operations involving positive reactivity additions, preclude reduction in boron to a concentration less than that of the RCS, or remove the operational burden previously required by CORE ALTERATIONS. The proposed changes limit the introduction into the RCS of reactivity more positive than that required to meet the required SDM or refueling boron concentrations, as applicable. The operational flexibility allowed in the proposed license amendment will be performed under administrative controls in order to limit the potential for excess positive reactivity additions. Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed changes will not be inimical to the common defense and security or to the health and safety of the public.

5.0 Environmental Consideration A CEG review has determined that the proposed change would alter a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed Page 10 of 12 Evaluation of Proposed Changes Page 11 of 12 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). In accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 References 6.1 TSTF-286, Revision 2, "Define Operations Involving Positive Reactivity Additions',"

dated July 6, 2000 (ML20106F133) 6.2 TSTF-471, Revision 1, "Eliminate Use of term CORE ALTERATIONS in ACTIONS and NOTES," dated December 7, 2006 (ML19101A215) 6.3 TSTF-571, Revision 0, "Revise Actions for Inoperable Source Range Neutron Flux Monitor," dated March 14, 2018 (ML18221A561) 6.4 U. S. Nuclear Regulatory Commission letter to Technical Specification Task Force (TSTF), "Potential Issues with Plant-Specific Adoption of Travelers TSTF-51, Revision 2, "Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations,"TSTF-286, Revision 2, "Operations Involving Positive Reactivity Additions,"

and TSTF-471, Revision 1, "Eliminate Use of Term Core Alterations in Actions and NOTES", dated November 7, 2013 (ML13246A358) 6.5 U. S. Nuclear Regulatory Commission letter to Technical Specification Task Force, "Plant-Specific Adoption of Travelers TSTF-51, Revision 2, "Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations," TSTF-471, Revision 1, "Eliminate Use of Term Core Alterations in Actions and NOTES," and TSTF-286, Revision 2, "Operations Involving Positive Reactivity Additions", dated October 4, 2018 (ML17346A587) 6.6 Letter from D. Pickett (U.S. NRC) to J. Carlin (R.E. Ginna Nuclear Power Plant, LLC),

"Amendment RE: Technical Specification Task Force (TSTF)-286, 'Operations Involving Positive Reactivity Additions'," dated June 8, 2011 (ML110980569) 6.7 Letter from R. Kuntz (U.S. NRC) to C. Domingos (Prairie Island Nuclear Generating Plant), "Issuance of Amendments: TSTF-471, REVISION 1 Eliminate Use of Term CORE ALTERATIONS IN Actions and NOTES, and TSTF-571-T, Revise Actions for Inoperable Source Range Neutron Flux Monitor, and Changes to Technical Specification" Section 5.0, dated April 1, 2022 (ML22061A206) 6.8 TSTF-51, Revision 2, "Revise containment requirements during handling irradiated fuel and core alterations," dated November 1, 1999 (ML040400343)

Evaluation of Proposed Changes Page 12 of 12 6.9 Letter from R. Kuntz (U.S. NRC) to C. Crane (CEG), " Byron Station, Unit Nos. 1 and 2, And Braidwood Station, Unit Nos. 1 and 2-Issuance of Amendments RE: Alternative Source Term," dated September 8, 2006 (ML062340420) 6.10 NRC Information Notice No. 93-32, "Nonconservative Inputs for Boron Dilution Event Analysis," dated April 21,1993 (ML031070505) 6.11 NRC NUREG-1431, "Westinghouse Standard Technical Specification (STS) in NUREG,"

Revision 5, dated September 2021 (ML21259A159) 6.12 Letter from M. Chawla (U.S. NRC) to O. Kingsley (Exelon Nuclear), "Byron and Braidwood-Issuance of Amendments," dated April 6, 2001 (ML011010180)

ATTACHMENT 2 Proposed Technical Specifications Changes (Mark-up)

. Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 1.1-2 3.3.1-5 3.4.5-1 3.4.5-2 3.4.5-3 3.4.6-1 3.4.6-2 3.4.7-1 3.4.7-2 3.4.7-3 3.4.8-1 3.4.8-2 3.4.18-1 3.4.18-2 3.8.2-2 3.8.2-3 3.8.5-2 3.8.8-2 3.8.10-3 3.9.1-1 3.9.2-1 3.9.3-1 3.9.5-1 3.9.6-2

Definitions 1.1 BRAIDWOOD UNITS 1 & 2 1.1 2 Amendment 207 1.1 Definitions CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or TEST (COT) actual signal into the channel as close to the sensor as practicable to verify the OPERABILITY of required alarm, interlock, display, and trip functions. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints so that the setpoints are within the required range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Unit operation within these limits is addressed in individual Specifications.

delete

RTS Instrumentation 3.3.1 BRAIDWOOD UNITS 1 & 2 3.3.1 5 Amendment 231 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One Intermediate Range Neutron Flux channel inoperable.

F.1 Reduce THERMAL POWER to P-6.

OR F.2 Increase THERMAL POWER to ! P-10.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours G. Two Intermediate Range Neutron Flux channels inoperable.

G.1 Suspend operations involving positive reactivity additions.

AND G.2 Reduce THERMAL POWER to < P-6.

Immediately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months H. One Source Range Neutron Flux channel inoperable.

H.1 Suspend operations involving positive reactivity additions.

Immediately I. Two Source Range Neutron Flux channels inoperable.

I.1 Open Reactor Trip Breakers (RTBs).

Immediately J. One Source Range Neutron Flux channel inoperable.

J.1 Restore channel to OPERABLE status.

OR J.2.1 Initiate action to fully insert all rods.

AND J.2.2 Place the Rod Control System in a condition incapable of rod withdrawal.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months (continued)

Note------------------

imited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

Note------------------

imited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

delete delete

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

RCS Loops-MODE 3 3.4.5 BRAIDWOOD UNITS 1 & 2 3.4.5 1 Amendment 98 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Loops-MODE 3 LCO 3.4.5 Two RCS loops shall be OPERABLE, and either:

a.

Two OPERABLE RCS loops shall be in operation when the Rod Control System is capable of rod withdrawal; or b.

One OPERABLE RCS loop shall be in operation when the Rod Control System is not capable of rod withdrawal.

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

All reactor coolant pumps may be removed from operation for

! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a.

No operations are permitted that would cause reduction of the RCS boron concentration; and b.

Core outlet temperature is maintained 10#F below saturation temperature.

APPLICABILITY:

MODE 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required RCS loop not in operation with Rod Control System capable of rod withdrawal.

A.1 Place the Rod Control System in a condition incapable of rod withdrawal.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

RCS Loops-MODE 3 3.4.5 BRAIDWOOD UNITS 1 & 2 3.4.5 2 Amendment 98 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

No required RCS loop in operation with Rod Control System not capable of rod withdrawal.

B.1 Suspend all operations involving a reduction of RCS boron concentration.

AND B.2 Initiate action to restore one RCS loop to operation.

Immediately Immediately C.

Two required RCS loops not in operation with Rod Control System capable of rod withdrawal.

OR Required Action and associated Completion Time of Condition A not met.

C.1 Initiate action to place the Rod Control System in a condition incapable of rod withdrawal.

AND C.2 Suspend all operations involving a reduction of RCS boron concentration.

AND C.3 Initiate action to restore RCS loop(s) to operation.

Immediately Immediately Immediately D.

One required RCS loop inoperable.

D.1 Restore required RCS loop to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

RCS Loops-MODE 3 3.4.5 BRAIDWOOD UNITS 1 & 2 3.4.5 3 Amendment 165 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and associated Completion Time of Condition D not met.

E.1 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F.

Two required RCS loops inoperable.

F.1 Initiate action to place the Rod Control System in a condition incapable of rod withdrawal.

AND F.2 Suspend all operations involving a reduction of RCS boron concentration.

AND F.3 Initiate action to restore one RCS loop to OPERABLE status.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify each required RCS loop is in operation.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

delete

RCS Loops-MODE 4 3.4.6 BRAIDWOOD UNITS 1 & 2 3.4.6 1 Amendment 98 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops-MODE 4 LCO 3.4.6 Two loops consisting of any combination of RCS loops and Residual Heat Removal (RHR) loops shall be OPERABLE, and one OPERABLE loop shall be in operation.

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

1.

All Reactor Coolant Pumps (RCPs) and RHR pumps may be removed from operation for ! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a.

No operations are permitted that would cause reduction of the RCS boron concentration; and b.

Core outlet temperature is maintained 10#F below saturation temperature.

2.

No RCP shall be started with any RCS cold leg temperature ! 350#F unless the secondary side water temperature of each Steam Generator (SG) is 50#F above each of the RCS cold leg temperatures.

APPLICABILITY:

MODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

No required loop in operation.

A.1 Suspend all operations involving a reduction in RCS boron concentration.

AND A.2 Initiate action to restore one loop to operation.

Immediately Immediately (continued)

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

RCS Loops-MODE 4 3.4.6 BRAIDWOOD UNITS 1 & 2 3.4.6 2 Amendment 165 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

One required loop inoperable.

B.1 Initiate action to restore a second loop to OPERABLE status.

AND B.2

NOTE---------

Only required if RHR loop is OPERABLE.

Be in MODE 5.

Immediately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C.

Two required loops inoperable.

C.1 Suspend all operations involving a reduction of RCS boron concentration.

AND C.2 Initiate action to restore one loop to OPERABLE status.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side narrow range water level is 18% for each required RCS loop.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

delete

RCS Loops-MODE 5, Loops Filled 3.4.7 BRAIDWOOD UNITS 1 & 2 3.4.7 1 Amendment 98 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops-MODE 5, Loops Filled LCO 3.4.7 One Residual Heat Removal (RHR) loop shall be OPERABLE and in operation, and either:

a.

One additional RHR loop shall be OPERABLE; or b.

The secondary side water level of at least two Steam Generators (SGs) shall be ! 18%.

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

1.

The RHR pump may be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a.

No operations are permitted that would cause reduction of the RCS boron concentration; and b.

Core outlet temperature is maintained ! 10#F below saturation temperature.

2.

One required RHR loop may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

3.

No reactor coolant pump shall be started with any RCS cold leg temperature 350#F unless the secondary side water temperature of each SG is 50#F above each of the RCS cold leg temperatures.

4.

All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.

APPLICABILITY:

MODE 5 with RCS loops filled.

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

RCS Loops-MODE 5, Loops Filled 3.4.7 BRAIDWOOD UNITS 1 & 2 3.4.7 2 Amendment 98 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

No required RHR loop in operation.

A.1 Suspend all operations involving a reduction in RCS boron concentration.

AND A.2 Initiate action to restore one RHR loop to operation.

Immediately Immediately B.

One required RHR loop inoperable.

B.1 Initiate action to restore required RHR loop to OPERABLE status.

Immediately C.

One or both required SG secondary side water level(s) not within limits.

C.1 Initiate action to restore required SG secondary side water level(s) to within limits.

Immediately (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

RCS Loops-MODE 5, Loops Filled 3.4.7 BRAIDWOOD UNITS 1 & 2 3.4.7 3 Amendment 183 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Two required RHR loops inoperable.

OR Required RHR loop inoperable and one or both required SG secondary side water level(s) not within limits.

D.1 Suspend all operations involving a reduction of RCS boron concentration.

AND D.2.1 Initiate action to restore one RHR loop to OPERABLE status.

OR D.2.2 Initiate action to restore required SG secondary side water level(s) to within limits.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify SG secondary side narrow range water level is ! 18% in required SGs.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.3 Verify correct breaker alignment and indicated power are available to each required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

delete

RCS Loops-MODE 5, Loops Not Filled 3.4.8 BRAIDWOOD UNITS 1 & 2 3.4.8 1 Amendment 98 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5, Loops Not Filled LCO 3.4.8 Two Residual Heat Removal (RHR) loops shall be OPERABLE and one OPERABLE RHR loop shall be in operation.

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

1.

All RHR pumps may be removed from operation for ! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

a.

No operations are permitted that would cause a reduction of the RCS boron concentration; b.

The core outlet temperature is maintained 10#F below saturation temperature; and c.

No draining operations are permitted that would further reduce the RCS water volume.

2.

One RHR loop may be inoperable for ! 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY:

MODE 5 with RCS loops not filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

No required RHR loop in operation.

A.1 Suspend all operations involving a reduction in RCS boron concentration.

AND A.2 Initiate action to restore one RHR loop to operation.

Immediately Immediately (continued)

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

RCS Loops-MODE 5, Loops Not Filled 3.4.8 BRAIDWOOD UNITS 1 & 2 3.4.8 2 Amendment 183 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

One required RHR loop inoperable.

B.1 Initiate action to restore RHR loop to OPERABLE status.

Immediately C.

Two required RHR loops inoperable.

C.1 Suspend all operations involving reduction in RCS boron concentration.

AND C.2 Initiate action to restore one RHR loop to OPERABLE status.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated power are available to each required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.8.3 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

delete

RCS Loops-Isolated 3.4.18 BRAIDWOOD UNITS 1 & 2 3.4.18 1 Amendment 98 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.18 RCS Loops-Isolated LCO 3.4.18 Each RCS isolated loop shall remain isolated with:

a.

The hot and cold leg loop stop isolation valves closed if boron concentration of the isolated loop is less than the required SDM boron concentration of the unisolated portion of the RCS; and b.

The cold leg loop stop isolation valve closed if the cold leg temperature of the isolated loop is 20F below the highest cold leg temperature of the unisolated portion of the RCS.

APPLICABILITY:

MODES 5 and 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Isolated loop hot or cold leg isolation valve open with boron concentration requirement not met.

A.1 Close hot and cold leg isolation valves.

Immediately B.

Isolated loop cold leg isolation valve open with temperature requirement not met.

B.1 Close cold leg isolation valve.

Immediately boron concentration required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1

RCS Loops-Isolated 3.4.18 BRAIDWOOD UNITS 1 & 2 3.4.18 2 Amendment 98 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.18.1 Verify cold leg temperature of isolated loop is 20F below the highest cold leg temperature of the unisolated portion of the RCS.

Within 30 minutes prior to opening the cold leg isolation valve in the isolated loop SR 3.4.18.2 Verify boron concentration of isolated loop is greater than or equal to the required SDM boron concentration of the unisolated portion of the RCS.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to opening the hot or cold leg isolation valve in the isolated loop boron concentration required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1.

AC Sources-Shutdown 3.8.2 BRAIDWOOD UNITS 1 & 2 3.8.2 2 Amendment 98 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to restore required qualified circuit to OPERABLE status.

AND A.2.5 Declare affected Low Temperature Overpressure Protection (LTOP) feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately (continued)

A.2.1 A.2.2 A.2.3 A.2.4 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AC Sources-Shutdown 3.8.2 BRAIDWOOD UNITS 1 & 2 3.8.2 3 Amendment 98 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

Required DG inoperable.

B.1 Suspend CORE ALTERATIONS.

AND B.2 Suspend movement of irradiated fuel assemblies.

AND B.3 Initiate action to suspend operations involving positive reactivity additions.

AND B.4 Initiate action to restore required DG to OPERABLE status.

AND B.5 Declare affected LTOP feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately B.1 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

B.3 B.4 B.2

DC Sources-Shutdown 3.8.5 BRAIDWOOD UNITS 1 & 2 3.8.5 2 Amendment 193 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to restore required DC electrical power subsystem to OPERABLE status.

AND A.2.5 Declare affected Low Temperature Overpressure Protection feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately (continued)

Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.1 A.2.3 A.2.4 delete A.2.2

Inverters-Shutdown 3.8.8 BRAIDWOOD UNITS 1 & 2 3.8.8 2 Amendment 193 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to restore required inverters to OPERABLE status.

AND A.2.5 Declare affected Low Temperature Overpressure Protection feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and breaker alignment to required AC instrument buses.

In accordance with the Surveillance Frequency Control Program A.2.1 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.3 A.2.4 delete A.2.2

Distribution Systems-Shutdown 3.8.10 BRAIDWOOD UNITS 1 & 2 3.8.10 3 Amendment 98 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate actions to restore required AC, DC, and AC instrument bus electrical power distribution subsystem(s) to OPERABLE status.

AND A.2.5 Declare associated required residual heat removal train(s) inoperable and not in operation.

AND A.2.6 Declare affected Low Temperature Overpressure Protection feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately Immediately A.2.1 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.3 A.2.4 A.2.5 A.2.2

Boron Concentration 3.9.1 BRAIDWOOD UNITS 1 & 2 3.9.1 1 Amendment 165 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System, the refueling canal, and the refueling cavity shall be maintained within the limit specified in the COLR.

APPLICABILITY:

MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Boron concentration not within limit.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend positive reactivity additions.

AND A.3 Initiate action to restore boron concentration to within limit.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit specified in the COLR.

In accordance with the Surveillance Frequency Control Program A.1 A.2 delete

Unborated Water Source Isolation Valves 3.9.2 BRAIDWOOD UNITS 1 & 2 3.9.2 1 Amendment 98 3.9 REFUELING OPERATIONS 3.9.2 Unborated Water Source Isolation Valves LCO 3.9.2 Each valve used to isolate unborated water sources shall be secured in the closed position.

APPLICABILITY:

MODE 6.

ACTIONS

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

Separate Condition entry is allowed for each unborated water source isolation valve.

CONDITION REQUIRED ACTION COMPLETION TIME A.

NOTE---------

Required Action A.3 must be completed whenever Condition A is entered.

One or more valves not secured in closed position.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Initiate actions to secure valve in closed position.

AND A.3 Perform SR 3.9.1.1.

Immediately Immediately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.1 A.2 A.2

Nuclear Instrumentation 3.9.3 BRAIDWOOD UNITS 1 & 2 3.9.3 1 Amendment 102 3.9 REFUELING OPERATIONS 3.9.3 Nuclear Instrumentation LCO 3.9.3 Two source range neutron flux monitors shall be OPERABLE.

APPLICABILITY:

MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required source range neutron flux monitor inoperable.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend positive reactivity additions.

Immediately Immediately B.

Two required source range neutron flux monitors inoperable.

B.1 Initiate action to restore one source range neutron flux monitor to OPERABLE status.

AND B.2 Perform SR 3.9.1.1.

Immediately Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Suspend positive reactivity additions.

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

Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition.

A.2 Suspend movement of fuel, sources, and reactivity control components within the reactor vessel.

delete delete

RHR and Coolant Circulation-High Water Level 3.9.5 BRAIDWOOD UNITS 1 & 2 3.9.5 1 Amendment 98 3.9 REFUELING OPERATIONS 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation-High Water Level LCO 3.9.5 One RHR loop shall be OPERABLE and in operation.

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

The required RHR loop may be removed from operation for

! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause reduction of the Reactor Coolant System boron concentration.

APPLICABILITY:

MODE 6 with the water level 23 ft above the top of reactor vessel flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

RHR loop requirements not met.

A.1 Suspend operations involving a reduction in reactor coolant boron concentration.

AND A.2 Suspend loading irradiated fuel assemblies in the core.

AND A.3 Initiate action to satisfy RHR loop requirements.

AND Immediately Immediately Immediately (continued) introduction of coolant into the Reactor Coolant System with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

RHR and Coolant Circulation-Low Water Level 3.9.6 BRAIDWOOD UNITS 1 & 2 3.9.6 2 Amendment 183 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

No RHR loop in operation.

B.1 Suspend operations involving a reduction in reactor coolant boron concentration.

AND B.2 Initiate action to restore one RHR loop to operation.

AND B.3 Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere.

Immediately Immediately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating reactor coolant at a flow rate of ! 1000 gpm.

In accordance with the Surveillance Frequency Control Program SR 3.9.6.2 Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program SR 3.9.6.3 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

delete

ATTACHMENT 3 Proposed Technical Specifications Changes (Mark-up)

. Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 1.1-2 3.3.1-4 3.4.5-1 3.4.5-2 3.4.5-3 3.4.6-1 3.4.6-2 3.4.7-1 3.4.7-2 3.4.7-3 3.4.8-1 3.4.8-2 3.4.18-1 3.4.18-2 3.8.2-2 3.8.2-3 3.8.5-2 3.8.8-2 3.8.10-3 3.9.1-1 3.9.2-1 3.9.3-1 3.9.5-1 3.9.6-2

Definitions 1.1 BYRON UNITS 1 & 2 1.1 2 Amendment 213 1.1 Definitions CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or TEST (COT) actual signal into the channel as close to the sensor as practicable to verify the OPERABILITY of required alarm, interlock, display, and trip functions. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints so that the setpoints are within the required range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Unit operation within these limits is addressed in individual Specifications.

delete

RTS Instrumentation 3.3.1 BYRON UNITS 1 & 2 3.3.1 4 Amendment 232 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One Intermediate Range Neutron Flux channel inoperable.

F.1 Reduce THERMAL POWER to P-6.

OR F.2 Increase THERMAL POWER to ! P-10.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours G. Two Intermediate Range Neutron Flux channels inoperable.

G.1 Suspend operations involving positive reactivity additions.

AND G.2 Reduce THERMAL POWER to < P-6.

Immediately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months H. One Source Range Neutron Flux channel inoperable.

H.1 Suspend operations involving positive reactivity additions.

Immediately I. Two Source Range Neutron Flux channels inoperable.

I.1 Open Reactor Trip Breakers (RTBs).

Immediately (continued)

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

delete

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

RCS Loops-MODE 3 3.4.5 BYRON UNITS 1 & 2 3.4.5 1 Amendment 106 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Loops-MODE 3 LCO 3.4.5 Two RCS loops shall be OPERABLE, and either:

a.

Two OPERABLE RCS loops shall be in operation when the Rod Control System is capable of rod withdrawal; or b.

One OPERABLE RCS loop shall be in operation when the Rod Control System is not capable of rod withdrawal.

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

All reactor coolant pumps may be removed from operation for

! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a.

No operations are permitted that would cause reduction of the RCS boron concentration; and b.

Core outlet temperature is maintained 10#F below saturation temperature.

APPLICABILITY:

MODE 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required RCS loop not in operation with Rod Control System capable of rod withdrawal.

A.1 Place the Rod Control System in a condition incapable of rod withdrawal.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

RCS Loops-MODE 3 3.4.5 BYRON UNITS 1 & 2 3.4.5 2 Amendment 106 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

No required RCS loop in operation with Rod Control System not capable of rod withdrawal.

B.1 Suspend all operations involving a reduction of RCS boron concentration.

AND B.2 Initiate action to restore one RCS loop to operation.

Immediately Immediately C.

Two required RCS loops not in operation with Rod Control System capable of rod withdrawal.

OR Required Action and associated Completion Time of Condition A not met.

C.1 Initiate action to place the Rod Control System in a condition incapable of rod withdrawal.

AND C.2 Suspend all operations involving a reduction of RCS boron concentration.

AND C.3 Initiate action to restore RCS loop(s) to operation.

Immediately Immediately Immediately D.

One required RCS loop inoperable.

D.1 Restore required RCS loop to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

RCS Loops-MODE 3 3.4.5 BYRON UNITS 1 & 2 3.4.5 3 Amendment 171 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and associated Completion Time of Condition D not met.

E.1 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F.

Two required RCS loops inoperable.

F.1 Initiate action to place the Rod Control System in a condition incapable of rod withdrawal.

AND F.2 Suspend all operations involving a reduction of RCS boron concentration.

AND F.3 Initiate action to restore one RCS loop to OPERABLE status.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify each required RCS loop is in operation.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

delete

RCS Loops-MODE 4 3.4.6 BYRON UNITS 1 & 2 3.4.6 1 Amendment 106 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops-MODE 4 LCO 3.4.6 Two loops consisting of any combination of RCS loops and Residual Heat Removal (RHR) loops shall be OPERABLE, and one OPERABLE loop shall be in operation.

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

1.

All Reactor Coolant Pumps (RCPs) and RHR pumps may be removed from operation for ! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a.

No operations are permitted that would cause reduction of the RCS boron concentration; and b.

Core outlet temperature is maintained 10#F below saturation temperature.

2.

No RCP shall be started with any RCS cold leg temperature ! 350#F unless the secondary side water temperature of each Steam Generator (SG) is 50#F above each of the RCS cold leg temperatures.

APPLICABILITY:

MODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

No required loop in operation.

A.1 Suspend all operations involving a reduction in RCS boron concentration.

AND A.2 Initiate action to restore one loop to operation.

Immediately Immediately (continued)

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

RCS Loops-MODE 4 3.4.6 BYRON UNITS 1 & 2 3.4.6 2 Amendment 171 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

One required loop inoperable.

B.1 Initiate action to restore a second loop to OPERABLE status.

AND B.2

NOTE---------

Only required if RHR loop is OPERABLE.

Be in MODE 5.

Immediately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C.

Two required loops inoperable.

C.1 Suspend all operations involving a reduction of RCS boron concentration.

AND C.2 Initiate action to restore one loop to OPERABLE status.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side narrow range water level is 18% for each required RCS loop.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

delete

RCS Loops-MODE 5, Loops Filled 3.4.7 BYRON UNITS 1 & 2 3.4.7 1 Amendment 106 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops-MODE 5, Loops Filled LCO 3.4.7 One Residual Heat Removal (RHR) loop shall be OPERABLE and in operation, and either:

a.

One additional RHR loop shall be OPERABLE; or b.

The secondary side water level of at least two Steam Generators (SGs) shall be ! 18%.

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

1.

The RHR pump may be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a.

No operations are permitted that would cause reduction of the RCS boron concentration; and b.

Core outlet temperature is maintained ! 10#F below saturation temperature.

2.

One required RHR loop may be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

3.

No reactor coolant pump shall be started with any RCS cold leg temperature 350#F unless the secondary side water temperature of each SG is 50#F above each of the RCS cold leg temperatures.

4.

All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.

APPLICABILITY:

MODE 5 with RCS loops filled.

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1; and

RCS Loops-MODE 5, Loops Filled 3.4.7 BYRON UNITS 1 & 2 3.4.7 2 Amendment 106 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

No required RHR loop in operation.

A.1 Suspend all operations involving a reduction in RCS boron concentration.

AND A.2 Initiate action to restore one RHR loop to operation.

Immediately Immediately B.

One required RHR loop inoperable.

B.1 Initiate action to restore required RHR loop to OPERABLE status.

Immediately C.

One or both required SG secondary side water level(s) not within limits.

C.1 Initiate action to restore required SG secondary side water level(s) to within limits.

Immediately (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.

RCS Loops-MODE 5, Loops Filled 3.4.7 BYRON UNITS 1 & 2 3.4.7 3 Amendment 189 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Two required RHR loops inoperable.

OR Required RHR loop inoperable and one or both required SG secondary side water level(s) not within limits.

D.1 Suspend all operations involving a reduction of RCS boron concentration.

AND D.2.1 Initiate action to restore one RHR loop to OPERABLE status.

OR D.2.2 Initiate action to restore required SG secondary side water level(s) to within limits.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify SG secondary side narrow range water level is ! 18% in required SGs.

In accordance with the Surveillance Frequency Control Program SR 3.4.7.3 Verify correct breaker alignment and indicated power are available to each required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

delete

RCS Loops-MODE 5, Loops Not Filled 3.4.8 BYRON UNITS 1 & 2 3.4.8 1 Amendment 106 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5, Loops Not Filled LCO 3.4.8 Two Residual Heat Removal (RHR) loops shall be OPERABLE and one OPERABLE RHR loop shall be in operation.

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

1.

All RHR pumps may be removed from operation for ! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

a.

No operations are permitted that would cause a reduction of the RCS boron concentration; b.

The core outlet temperature is maintained 10#F below saturation temperature; and c.

No draining operations are permitted that would further reduce the RCS water volume.

2.

One RHR loop may be inoperable for ! 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY:

MODE 5 with RCS loops not filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

No required RHR loop in operation.

A.1 Suspend all operations involving a reduction in RCS boron concentration.

AND A.2 Initiate action to restore one RHR loop to operation.

Immediately Immediately (continued)

No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1; Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

RCS Loops-MODE 5, Loops Not Filled 3.4.8 BYRON UNITS 1 & 2 3.4.8 2 Amendment 189 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

One required RHR loop inoperable.

B.1 Initiate action to restore RHR loop to OPERABLE status.

Immediately C.

Two required RHR loops inoperable.

C.1 Suspend all operations involving reduction in RCS boron concentration.

AND C.2 Initiate action to restore one RHR loop to OPERABLE status.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated power are available to each required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program SR 3.4.8.3 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.

delete

RCS Loops-Isolated 3.4.18 BYRON UNITS 1 & 2 3.4.18 1 Amendment 106 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.18 RCS Loops-Isolated LCO 3.4.18 Each RCS isolated loop shall remain isolated with:

a.

The hot and cold leg loop stop isolation valves closed if boron concentration of the isolated loop is less than the required SDM boron concentration of the unisolated portion of the RCS; and b.

The cold leg loop stop isolation valve closed if the cold leg temperature of the isolated loop is 20F below the highest cold leg temperature of the unisolated portion of the RCS.

APPLICABILITY:

MODES 5 and 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Isolated loop hot or cold leg isolation valve open with boron concentration requirement not met.

A.1 Close hot and cold leg isolation valves.

Immediately B.

Isolated loop cold leg isolation valve open with temperature requirement not met.

B.1 Close cold leg isolation valve.

Immediately boron concentration required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1;

RCS Loops-Isolated 3.4.18 BYRON UNITS 1 & 2 3.4.18 2 Amendment 106 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.18.1 Verify cold leg temperature of isolated loop is 20F below the highest cold leg temperature of the unisolated portion of the RCS.

Within 30 minutes prior to opening the cold leg isolation valve in the isolated loop SR 3.4.18.2 Verify boron concentration of isolated loop is greater than or equal to the required SDM boron concentration of the unisolated portion of the RCS.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to opening the hot or cold leg isolation valve in the isolated loop boron concentration required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1.

AC Sources-Shutdown 3.8.2 BYRON UNITS 1 & 2 3.8.2 2 Amendment 106 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to restore required qualified circuit to OPERABLE status.

AND A.2.5 Declare affected Low Temperature Overpressure Protection (LTOP) feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately (continued)

Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.1 A.2.2 A.2.3 A.2.4

AC Sources-Shutdown 3.8.2 BYRON UNITS 1 & 2 3.8.2 3 Amendment 106 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

Required DG inoperable.

B.1 Suspend CORE ALTERATIONS.

AND B.2 Suspend movement of irradiated fuel assemblies.

AND B.3 Initiate action to suspend operations involving positive reactivity additions.

AND B.4 Initiate action to restore required DG to OPERABLE status.

AND B.5 Declare affected LTOP feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

B.1 B.2 B.3 B.4

DC Sources-Shutdown 3.8.5 BYRON UNITS 1 & 2 3.8.5 2 Amendment 198 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to restore required DC electrical power subsystem to OPERABLE status.

AND A.2.5 Declare affected Low Temperature Overpressure Protection feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately (continued)

Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.1 A.2.2 A.2.3 A.2.4 delete

Inverters-Shutdown 3.8.8 BYRON UNITS 1 & 2 3.8.8 2 Amendment 171 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to restore required inverters to OPERABLE status.

AND A.2.5 Declare affected Low Temperature Overpressure Protection feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and breaker alignment to required AC instrument buses.

In accordance with the Surveillance Frequency Control Program Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.1 A.2.2 A.2.3 A.2.4 delete

Distribution Systems-Shutdown 3.8.10 BYRON UNITS 1 & 2 3.8.10 3 Amendment 106 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend operations involving positive reactivity additions.

AND A.2.4 Initiate actions to restore required AC, DC, and AC instrument bus electrical power distribution subsystem(s) to OPERABLE status.

AND A.2.5 Declare associated required residual heat removal train(s) inoperable and not in operation.

AND A.2.6 Declare affected Low Temperature Overpressure Protection feature(s) inoperable.

Immediately Immediately Immediately Immediately Immediately Immediately Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.1 A.2.2 A.2.3 A.2.4 A.2.5

Boron Concentration 3.9.1 BYRON UNITS 1 & 2 3.9.1 1 Amendment 171 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System, the refueling canal, and the refueling cavity shall be maintained within the limit specified in the COLR.

APPLICABILITY:

MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Boron concentration not within limit.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend positive reactivity additions.

AND A.3 Initiate action to restore boron concentration to within limit.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit specified in the COLR.

In accordance with the Surveillance Frequency Control Program A.1 A.2 delete

Unborated Water Source Isolation Valves 3.9.2 BYRON UNITS 1 & 2 3.9.2 1 Amendment 106 3.9 REFUELING OPERATIONS 3.9.2 Unborated Water Source Isolation Valves LCO 3.9.2 Each valve used to isolate unborated water sources shall be secured in the closed position.

APPLICABILITY:

MODE 6.

ACTIONS

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

Separate Condition entry is allowed for each unborated water source isolation valve.

CONDITION REQUIRED ACTION COMPLETION TIME A.

NOTE---------

Required Action A.3 must be completed whenever Condition A is entered.

One or more valves not secured in closed position.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Initiate actions to secure valve in closed position.

AND A.3 Perform SR 3.9.1.1.

Immediately Immediately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.1 A.2 A.2

Nuclear Instrumentation 3.9.3 BYRON UNITS 1 & 2 3.9.3 1 Amendment 109 3.9 REFUELING OPERATIONS 3.9.3 Nuclear Instrumentation LCO 3.9.3 Two source range neutron flux monitors shall be OPERABLE.

APPLICABILITY:

MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required source range neutron flux monitor inoperable.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend positive reactivity additions.

Immediately Immediately B.

Two required source range neutron flux monitors inoperable.

B.1 Initiate action to restore one source range neutron flux monitor to OPERABLE status.

AND B.2 Perform SR 3.9.1.1.

Immediately Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Suspend positive reactivity additions.

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

Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition.

A.2 Suspend movement of fuel, sources, and reactivity control components within the reactor vessel.

delete delete

RHR and Coolant Circulation-High Water Level 3.9.5 BYRON UNITS 1 & 2 3.9.5 1 Amendment 106 3.9 REFUELING OPERATIONS 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation-High Water Level LCO 3.9.5 One RHR loop shall be OPERABLE and in operation.

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

The required RHR loop may be removed from operation for

! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause reduction of the Reactor Coolant System boron concentration.

APPLICABILITY:

MODE 6 with the water level 23 ft above the top of reactor vessel flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

RHR loop requirements not met.

A.1 Suspend operations involving a reduction in reactor coolant boron concentration.

AND A.2 Suspend loading irradiated fuel assemblies in the core.

AND A.3 Initiate action to satisfy RHR loop requirements.

AND Immediately Immediately Immediately (continued) introduction of coolant into the Reactor Coolant System with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

RHR and Coolant Circulation-Low Water Level 3.9.6 BYRON UNITS 1 & 2 3.9.6 2 Amendment 189 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

No RHR loop in operation.

B.1 Suspend operations involving a reduction in reactor coolant boron concentration.

AND B.2 Initiate action to restore one RHR loop to operation.

AND B.3 Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere.

Immediately Immediately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating reactor coolant at a flow rate of ! 1000 gpm.

In accordance with the Surveillance Frequency Control Program SR 3.9.6.2 Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation.

In accordance with the Surveillance Frequency Control Program (continued)

Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

delete

ATTACHMENT 4 Proposed Technical Specifications Bases Changes (Mark-up) - For Information Only Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 B 3.3.1-45 B 3.3.1-46 B 3.4.5-3 B 3.4.5-5 B 3.4.5-6 B 3.4.5-7 B 3.4.6-2 B 3.4.6-4 B 3.4.7-3 B 3.4.7-4 B 3.4.7-5 B 3.4.8-2 B 3.4.8-3 B 3.4.8-4 B 3.4.18-1 B 3.4.18-3 B 3.8.2-6 B 3.8.5-4 B 3.8.8-4 B 3.8.10-3 B 3.9.1-3 B 3.9.1-4 B 3.9.2-3 B 3.9.3-3 B 3.9.5-2 B 3.9.5-3 B 3.9.6-3

RTS Instrumentation B 3.3.1 BRAIDWOOD UNITS 1 & 2 B 3.3.1 45 Revision 145 BASES ACTIONS (continued)

Functions. If THERMAL POWER is greater than the P-6 setpoint but less than the P-10 setpoint, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to reduce THERMAL POWER below the P-6 setpoint or increase to THERMAL POWER above the P-10 setpoint. The provisions of LCO 3.0.4 allow entry into a MODE or other specified condition in the Applicability as directed by the Required Actions. Therefore, a MODE change is permitted with one channel inoperable whenever Required Action F.2 is used. The NIS Intermediate Range Neutron Flux channels must be OPERABLE when the power level is above the capability of the source range, P-6, and below the capability of the power range, P-10. If THERMAL POWER is greater than the P-10 setpoint, the NIS power range detectors perform the monitoring and protection functions and the intermediate range is not required. The Completion Times allow for a slow and controlled power adjustment above P-10 or below P-6 and take into account the redundant capability afforded by the redundant OPERABLE channel, and the low probability of its failure during this period. This action does not require the inoperable channel to be tripped because the Function uses one-out-of-two logic. Tripping one channel would trip the reactor. Thus, the Required Actions specified in this Condition are only applicable when channel failure does not result in reactor trip.

G.1 and G.2 Condition G applies to two inoperable Intermediate Range Neutron Flux trip channels in MODE 2 when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint.

Required Actions specified in this Condition are only applicable when channel failures do not result in reactor trip. Above the P-6 setpoint and below the P-10 setpoint, the NIS intermediate range detector performs the monitoring Functions. With no intermediate range channels OPERABLE, the Required Actions are to suspend operations involving positive reactivity additions immediately. This will preclude any power level increase since there are no OPERABLE Intermediate Range Neutron Flux channels. The operator must also reduce THERMAL POWER below the P-6 setpoint within two hours. Below P-6, the Source Range Neutron Flux channels will be able to monitor the core power level. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.

Required Action G.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this action, provided they are accounted for in the calculated SDM.

delete

RTS Instrumentation B 3.3.1 BRAIDWOOD UNITS 1 & 2 B 3.3.1 46 Revision 88 BASES ACTIONS (continued)

H.1 Condition H applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2, below the P-6 setpoint.

With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions.

With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

This will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

I.1 Condition I applies to two inoperable Source Range Neutron Flux trip channels when in MODE 2, below the P-6 setpoint, and in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted.

With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions.

With both source range channels inoperable, the RTBs must be opened immediately. With the RTBs open, the core is in a more stable condition.

J.1 and J.2 Condition J applies to one inoperable source range channel in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the source range channels inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore it to an OPERABLE status. If the channel cannot be returned to an OPERABLE status, action must be initiated within the same 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to ensure that all rods are fully inserted, and the Rod Control System must be placed in a condition incapable of rod withdrawal within the next hour.

The allowance of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the channel to OPERABLE status, and the additional hour, are justified in Reference 7.

Required Action H.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this action, provided they are accounted for in the calculated SDM.

RCS Loops-MODE 3 B 3.4.5 BRAIDWOOD UNITS 1 & 2 B 3.4.5 3 Revision 0 BASES LCO (continued)

The Note permits all RCPs to be removed from operation (i.e., not in operation) for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

The purpose of the Note is to perform tests that are designed to validate various accident analyses values. One of these tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident. This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again. Another test performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow.

The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits the stopping of the pumps in order to perform this test and validate the assumed analysis values. As with the validation of the pump coastdown curve, this test should be performed only once unless the flow characteristics of the RCS are changed. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period specified is adequate to perform the desired tests, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of the Note is permitted provided the following conditions are met, along with any other conditions imposed by procedures:

a.

No operations are permitted that would dilute the RCS boron concentration, thereby maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and b.

Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1,

RCS Loops-MODE 3 B 3.4.5 BRAIDWOOD UNITS 1 & 2 B 3.4.5 5 Revision 0 BASES ACTIONS A.1 If the required RCS loop is not in operation, and the Rod Control System is capable of rod withdrawal, the Required Action is to place the Rod Control System in a condition incapable of rod withdrawal (e.g., disable all CRDMs by opening the RTBs or de-energizing the motor generator (MG) sets). When the Rod Control System is capable of rod withdrawal, it is postulated that a power excursion could occur in the event of an inadvertent control rod withdrawal.

This mandates having the heat transfer capacity of two RCS loops in operation. If only one loop is in operation, the Rod Control System must be rendered incapable of rod withdrawal. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to defeat the Rod Control System is adequate to perform these operations in an orderly manner without exposing the unit to risk for an undue time period.

B.1 and B.2 If no RCS loop is in operation with the Rod Control System not capable of rod withdrawal, except as permitted by the Note in the LCO section, all operations involving a reduction of RCS boron concentration must be suspended, and action to restore one RCS loop to operation must be immediately initiated. Boron dilution requires forced circulation for proper mixing.

The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to operation.

an introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1

RCS Loops-MODE 3 B 3.4.5 BRAIDWOOD UNITS 1 & 2 B 3.4.5 6 Revision 0 BASES ACTIONS (continued)

C.1, C.2, and C.3 If no RCS loop is in operation with the Rod Control System capable of rod withdrawal, except as permitted by the Note in the LCO section, or if the Required Action and associated Completion Time of Condition A are not met, action must be initiated to place the Rod Control System in a condition incapable of rod withdrawal (e.g., disable all CRDMs by opening the RTBs or de-energizing the MG sets).

Additionally, all operations involving a reduction of RCS boron concentration must be suspended, and action to restore one of the RCS loops to operation must be immediately initiated. Boron dilution requires forced circulation for proper mixing, and disabling the CRDMs removes the possibility of an inadvertent rod withdrawal.

The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to operation.

D.1 If one required RCS loop is inoperable, redundancy for heat removal is lost. The Required Action is restoration of the required RCS loop to OPERABLE status within the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This time allowance is a justified period to be without the redundant, nonoperating loop because a single loop in operation has a heat transfer capability greater than that needed to remove the decay heat produced in the reactor core and because of the low probability of a failure in the remaining loop occurring during this period.

E.1 If the Required Action and associated Completion Time of Condition D are not met, the unit must be brought to MODE 4.

In MODE 4, the unit may be placed on the Residual Heat Removal System. The additional Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is compatible with required operations to achieve cooldown and depressurization from the existing unit conditions in an orderly manner and without challenging plant systems.

Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

an introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1

RCS Loops-MODE 3 B 3.4.5 BRAIDWOOD UNITS 1 & 2 B 3.4.5 7 Revision 85 BASES ACTIONS (continued)

F.1, F.2, and F.3 If two required RCS loops are inoperable, action must be initiated to place the Rod Control System in a condition incapable of rod withdrawal (e.g., disable all CRDMs by opening the RTBs or de-energizing the MG sets). All operations involving a reduction of RCS boron concentration must be suspended, and action to restore one of the RCS loops to OPERABLE status must be initiated. Boron dilution requires forced circulation for proper mixing, and disabling the CRDMs removes the possibility of an inadvertent rod withdrawal. The immediate Completion Time reflects the importance of maintaining the capability for heat removal.

The action to restore must be continued until one loop is restored to OPERABLE status.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification that the required operating loops are in operation. Verification may include flow rate, temperature, and pump status monitoring, which helps ensure that forced flow is providing heat removal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.5.2 SR 3.4.5.2 requires verification of required SG OPERABILITY.

SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 18% for each required RCS loop. If the SG secondary side narrow range water level is

< 18%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink for removal of the decay heat. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1.

Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

delete

RCS Loops-MODE 4 B 3.4.6 BRAIDWOOD UNITS 1 & 2 B 3.4.6 2 Revision 0 BASES LCO The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal.

Note 1 permits all RCPs and RHR pumps to be removed from operation for ! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests that are designed to validate various accident analyses values. One of the tests performed during the startup testing program is the validation of rod drop times during cold conditions, both with and without flow. The no flow test may be performed in MODE 3, 4, or 5 and requires that the pumps be stopped for a short period of time. The Note permits the stopping of the pumps in order to perform this test and validate the assumed analysis values. If necessary, this test may also be conducted after the initial startup testing program. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met along with any other conditions imposed by procedures:

a.

No operations are permitted that would dilute the RCS boron concentration, therefore maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and b.

Core outlet temperature is maintained at least 10F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

with coolant with boron concentrations less than required to meet SDM of LCO 3.1.1,

RCS Loops-MODE 4 B 3.4.6 BRAIDWOOD UNITS 1 & 2 B 3.4.6 4 Revision 0 BASES ACTIONS A.1 and A.2 If no loop is in operation, except during conditions permitted by the Note in the LCO section, all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RCS or RHR loop to operation must be immediately initiated. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal.

B.1 and B.2 If one required RCS or RHR loop is inoperable and only one required loop remains OPERABLE, the intended redundancy for heat removal is lost. Action must be initiated to restore a second RCS or RHR loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

If the one required OPERABLE loop is an RHR loop and if the required loop is not restored to OPERABLE status, the unit must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the unit to MODE 5 is a conservative action with regard to decay heat removal. With only one RHR loop OPERABLE, the intended redundancy for decay heat removal is lost and, in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 (! 200F) rather than MODE 4 (200 to 350F). The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

C.1 and C.2 If no loop is OPERABLE, all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RCS or RHR loop to OPERABLE status must be initiated. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining the capability for decay heat removal.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 The required margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops-MODE 5, Loops Filled B 3.4.7 BRAIDWOOD UNITS 1 & 2 B 3.4.7 3 Revision 105 BASES LCO (continued)

Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by procedures:

a.

No operations are permitted that would dilute the RCS boron concentration, therefore maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and b.

Core outlet temperature is maintained at least 10#F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop when such testing is safe and possible.

Note 3 requires that the secondary side water temperature of each SG be < 50#F above each of the RCS cold leg temperatures before the start of a Reactor Coolant Pump (RCP) with an RCS cold leg temperature 350#F. This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG via natural circulation has greater than or equal to the minimum water level specified in SR 3.4.7.2 and is otherwise capable of providing the necessary heat sink via natural circulation. Management of gas voids is important to RHR System OPERABILITY.

with coolant with boron concentration less than required to meet SDM of LCO 3.1.1, delete

RCS Loops-MODE 5, Loops Filled B 3.4.7 BRAIDWOOD UNITS 1 & 2 B 3.4.7 4 Revision 0 BASES APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient circulation for these purposes.

However, one additional RHR loop is required to be OPERABLE or the secondary side water level of at least two SGs is required to be ! 18%.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

ACTIONS A.1 and A.2 If no required RHR loop is in operation, except during conditions permitted by Note 1, all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RHR loop to operation must be immediately initiated. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal.

B.1 and C.1 If the required RHR loop is inoperable or the required SG(s) have secondary side water levels 18%, redundancy for heat removal is lost. Action must be initiated immediately to restore either the required RHR loop to OPERABLE status or to restore the required SG secondary side water level(s).

The Required Actions will restore an available alternate heat removal path. The immediate Completion Times reflect the importance of maintaining the availability of two paths for heat removal.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops-MODE 5, Loops Filled B 3.4.7 BRAIDWOOD UNITS 1 & 2 B 3.4.7 5 Revision 85 BASES ACTIONS (continued)

D.1, D.2.1, and D.2.2 If two required RHR loops are inoperable or the required RHR loop and one or both SG secondary side water levels are not within limit(s), all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RHR loop to operation must be immediately initiated or initiate action to restore required SG secondary side water level to within limits. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification that the required operating RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.7.2 Verifying that at least two SGs are OPERABLE by ensuring their secondary side narrow range water levels are ! 18%

ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this surveillance is not needed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

delete Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

an introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1 introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 BRAIDWOOD UNITS 1 & 2 B 3.4.8 2 Revision 105 BASES LCO The purpose of this LCO is to require that at least two RHR loops be OPERABLE and one of these loops be in operation.

An OPERABLE loop is one that has the capability of transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the RHR System unless forced flow is used. A minimum of one running RHR pump meets the LCO requirement for one loop in operation. An additional RHR loop is required to be OPERABLE to meet single failure considerations.

Note 1 permits all RHR pumps to be removed from operation for ! 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by procedures:

a.

No operations are permitted that would dilute the RCS boron concentration, therefore maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; b.

Core outlet temperature is maintained at least 10F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction; and c.

No draining operations are permitted that would further reduce the RCS water volume.

Note 2 allows one RHR loop to be inoperable for a period of

! 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop when these tests are safe and possible.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

Management of gas voids is important to RHR System OPERABILITY.

with coolant with boron concentration less than required to meet SDM of LCO 3.1.1, delete

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 BRAIDWOOD UNITS 1 & 2 B 3.4.8 3 Revision 0 BASES APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

ACTIONS A.1 and A.2 If no RHR loop is in operation, except during conditions permitted by Note 1, all operations involving a reduction of RCS boron concentration must be suspended and action to restore one RHR loop to operation must be immediately initiated. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal.

B.1 If only one RHR loop is OPERABLE, except during conditions permitted by Note 2, redundancy for decay heat removal is lost and action must be initiated immediately to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 The required margin to criticality must not be reduced in this type of operation.

Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 BRAIDWOOD UNITS 1 & 2 B 3.4.8 4 Revision 105 BASES ACTIONS (continued)

C.1 and C.2 If no required RHR loops are OPERABLE, all operations involving a reduction of RCS boron concentration must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining the capability for heat removal.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification that the required operating RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.

Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be delete an introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 The required margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1

RCS Loops-Isolated B 3.4.18 BRAIDWOOD UNITS 1 & 2 B 3.4.18 1 Revision 0 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.18 RCS Loops-Isolated BASES BACKGROUND The RCS may be operated with loops isolated in MODES 5 and 6 in order to perform maintenance. While operating with a loop isolated, there is potential for inadvertently opening the isolation valves in the isolated loop. In this event, the coolant in the isolated loop would suddenly begin to mix with the coolant in the unisolated portion of the RCS. This situation has the potential of causing a positive reactivity addition with a corresponding reduction of SDM if

a.

The temperature in the isolated loop is lower than the temperature in the unisolated portion of the RCS (cold water incident); or

b.

The boron concentration in the isolated loop is lower than the boron concentration required in the RCS to meet SDM (boron dilution incident).

As discussed in the UFSAR (Ref. 1), the startup of an isolated loop is done in a controlled manner that virtually eliminates any sudden positive reactivity addition from cold water or boron dilution because:

a.

This LCO and plant operating procedures require that the boron concentration in the isolated loop be maintained higher than the required SDM boron concentration of the unisolated portion of the RCS, thus eliminating the potential for introducing coolant from the isolated loop that could dilute the boron concentration in the unisolated portion of the RCS to less than the required SDM boron concentration;

b.

The cold leg loop isolation valve cannot be opened unless the temperatures of both the hot leg and cold leg of the isolated loop are within 20°F of the unisolated portion of the RCS. Compliance with the temperature requirement is ensured by operating procedures and automatic interlocks; and required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1

RCS Loops-Isolated B 3.4.18 BRAIDWOOD UNITS 1 & 2 B 3.4.18 3 Revision 0 BASES ACTIONS A.1 and B.1 Required Action A.1 and Required Action B.1 assume that the prerequisites of the LCO are not met and a loop isolation valve has been inadvertently opened. Therefore, the Actions require immediate closure of isolation valves to preclude a boron dilution event or a cold water event.

SURVEILLANCE SR 3.4.18.1 REQUIREMENTS This Surveillance is performed to ensure that the temperature differential between the isolated loop and the unisolated portion of the RCS is 20°F. Performing the Surveillance 30 minutes prior to opening the cold leg isolation valve in the isolated loop provides reasonable assurance, based on engineering judgment, that the temperature differential will stay within limits until the cold leg isolation valve is opened. This Frequency has been shown to be acceptable through operating experience.

SR 3.4.18.2 To ensure that the boron concentration of the isolated loop is greater than or equal to the boron concentration required in the RCS to meet SDM, a Surveillance is performed 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to opening either the hot or cold leg isolation valve.

Performing the Surveillance 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to opening either the hot or cold leg isolation valve provides reasonable assurance the resulting boron concentration difference will be within acceptable limits when the loop is unisolated.

This Frequency is acceptable due to the amount of time required to sample and confirm concentration results.

REFERENCES

1.

UFSAR, Section 15.4.4.

required to meet the SDM of LCO 3.1.1 or boron concentration of LCO 3.9.1,

AC Sources-Shutdown B 3.8.2 BRAIDWOOD UNITS 1 & 2 B 3.8.2 6 Revision 0 BASES ACTIONS (continued)

A.2.1, A.2.2, A.2.3, A.2.4, A.2.5, B.1, B.2, B.3, B.4, and B.5 With the offsite circuit not available to one or more required divisions, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, operations involving positive reactivity additions, and declare the affected Low Temperature Overpressure Protection (LTOP) features required by LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP)

System" inoperable. The Required Action to declare the affected LTOP features inoperable allows the operator to evaluate the current unit conditions and to determine which (if any) of the LTOP features have been affected by the loss of power. The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SDM is maintained. Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

that could result in loss of required SDM (Mode

5) or boron concentration (Mode 6)

B.4

DC Sources-Shutdown B 3.8.5 BRAIDWOOD UNITS 1 & 2 B 3.8.5 4 Revision 36 BASES ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown.

A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features' LCO ACTIONS.

In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, operations involving positive reactivity additions, and declare the affected Low Temperature Overpressure Protection (LTOP) features, required by LCO 3.4.12, inoperable). The Required Action to declare the associated LTOP features inoperable allows the operator to evaluate the current unit conditions and to determine which (if any) of the LTOP features have been affected by the loss of power. The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystem and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystem should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

delete that could result in loss of required SDM (Mode

5) or boron concentration (Mode 6).

A.2.4

Inverters-Shutdown B 3.8.8 BRAIDWOOD UNITS 1 & 2 B 3.8.8 4 Revision 36 BASES ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown.

A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions.

In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, operations involving positive reactivity additions, and declare the associated Low Temperature Overpressure Protection (LTOP) features inoperable). The Required Action to declare the associated LTOP features inoperable allows the operator to evaluate the current unit conditions and to determine which (if any) of the LTOP features have been affected by the loss of power. If the LTOP features have not been affected, then unnecessarily restrictive actions may be averted. The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained. Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

delete that could result in loss of required SDM (Mode

5) or boron concentration (Mode 6).

A.2.4

Distribution Systems-Shutdown B 3.8.10 BRAIDWOOD UNITS 1 & 2 B 3.8.10 3 Revision 0 BASES ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown.

A.1, A.2.1, A.2.2, A.2.3, A.2.4, A.2.5, and A.2.6 Although redundant required features may require redundant divisions of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem division may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement.

By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable (Required Action A.1), appropriate restrictions are implemented in accordance with the affected required feature LCO's Required Actions. In many instances, however, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions of Required Actions A.2.1 through A.2.4 is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions). Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6)

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

A.2.5

Boron Concentration B 3.9.1 BRAIDWOOD UNITS 1 & 2 B 3.9.1 3 Revision 0 BASES LCO The LCO requires that a minimum boron concentration be maintained in all filled portions of the RCS, the refueling canal, and the refueling cavity, that are hydraulically coupled to the reactor core, while in MODE 6. The boron concentration limit specified in the COLR ensures that a core keff of d 0.95 is maintained during fuel handling operations. Violation of the LCO could lead to an inadvertent criticality during MODE 6.

APPLICABILITY This LCO is applicable in MODE 6 to ensure that the fuel in the reactor vessel will remain subcritical. The required boron concentration ensures a keff d 0.95. In MODES 1 and 2 with keff t 1.0, LCO 3.1.4, "Rod Group Alignment Limits,"

LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits," ensure an adequate amount of negative reactivity is available to shutdown the reactor.

In MODE 2 with keff < 1.0 and MODES 3, 4, and 5, LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," ensures that an adequate amount of negative reactivity is available to shut down the reactor and maintain it subcritical.

ACTIONS A.1, A.2, and A.3 Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO.

A.2

Boron Concentration B 3.9.1 BRAIDWOOD UNITS 1 & 2 B 3.9.1 4 Revision 0 BASES ACTIONS (continued)

If the boron concentration of any coolant volume in the filled portions of the RCS, the refueling canal, or the refueling cavity is less than its limit, an inadvertent criticality may occur due to an incorrect fuel loading. To minimize the potential of an inadvertent criticality resulting from a fuel loading error, all operations involving CORE ALTERATIONS and positive reactivity additions must be suspended immediately.

Suspension of CORE ALTERATIONS and positive reactivity additions shall not preclude moving a component to a safe position, or heating or cooling the coolant volume for the purpose of system temperature control within established procedures.

In addition to immediately suspending CORE ALTERATIONS and positive reactivity additions, action to restore the boron concentration must be initiated immediately.

There are no safety analysis assumptions of boration flow rate and concentration that must be satisfied. The only requirement is to restore the boron concentration to its required value as soon as possible. In order to raise the boron concentration as soon as possible, the operator should begin boration with the best source available for unit conditions.

Once actions have been initiated, they must be continued until the boron concentration is restored. The restoration time depends on the amount of boron that must be injected to reach the required concentration.

Operations that individually add limited positive reactivity (e.g.

temperature fluctuations from inventory addition or temperature control fluctuations),

but when combined with all other operations affecting core reactivity (e.g.,

intentional boration) result in overall net negative reactivity addition, are not precluded by this action.

Unborated Water Source Isolation Valves B 3.9.2 BRAIDWOOD UNITS 1 & 2 B 3.9.2 3 Revision 11 BASES ACTIONS The ACTIONS table has been modified by a Note that allows separate Condition entry for each unborated water source isolation valve.

A.1, A.2, and A.3 Continuation of CORE ALTERATIONS is contingent upon maintaining the unit in compliance with this LCO. With any valve used to isolate unborated water sources not secured in the closed position, all operations involving CORE ALTERATIONS must be suspended immediately. The Completion Time of "immediately" for performance of Required Action A.1 shall not preclude completion of movement of a component to a safe position.

Preventing inadvertent dilution of the reactor coolant boron concentration is dependent on maintaining the unborated water isolation valves secured closed. Securing the valves in the closed position ensures that the valves cannot be inadvertently opened. The Completion Time of "immediately" requires an operator to initiate actions to close an open valve and secure the isolation valve in the closed position without delay. Once actions are initiated, they must be continued until the valves are secured in the closed position.

Due to the potential of having diluted the boron concentration of the reactor coolant, SR 3.9.1.1 (verification of boron concentration) must be performed whenever Condition A is entered to demonstrate that the required boron concentration exists. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is sufficient to obtain and analyze a reactor coolant sample for boron concentration.

Condition A has been modified by a Note to require that Required Action A.3 be completed whenever Condition A is entered.

A.2 A.2

Nuclear Instrumentation B 3.9.3 BRAIDWOOD UNITS 1 & 2 B 3.9.3 3 Revision 4 BASES ACTIONS A.1 and A.2 With only one required source range neutron flux monitor OPERABLE, redundancy has been lost. Since these instruments are the only direct means of monitoring core reactivity conditions, CORE ALTERATIONS and positive reactivity additions must be suspended immediately. Performance of Required Action A.1 or A.2 shall not preclude completion of movement of a component to a safe position or normal heatup/cooldown of the coolant volume for the purpose of system temperature control.

B.1 and B.2 With no required source range neutron flux monitor OPERABLE, there are no direct means of detecting changes in core reactivity. Therefore, action to restore a monitor to OPERABLE status shall be initiated immediately and continued until a source range neutron flux monitor is restored to OPERABLE status.

Since CORE ALTERATIONS and positive reactivity additions are not to be made, the core reactivity condition is stabilized until the source range neutron flux monitors are OPERABLE.

This stabilized condition is determined by performing SR 3.9.1.1 to ensure that the required boron concentration exists.

The Completion Time of once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient to obtain and analyze a reactor coolant sample for boron concentration and ensures that unplanned changes in boron concentration would be identified. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable, considering the low probability of a change in core reactivity during this time period.

Performance of Required Action A.1 shall not preclude completion of movement of a component to a safe position. Suspending the movement of fuel, sources, and reactivity control components ensures that positive reactivity is not inadvertently added to the reactor core while the source range neutron flux monitor is inoperable. Required Action A.2 is modified by a Note that states that fuel assemblies, sources, and reactivity control components may be moved if necessary to facilitate repair or replacement of the inoperable source range neutron flux monitor. It may be necessary to move these items away from the locations in the core close to the source range neutron flux monitor to minimize personnel radiation dose during troubleshooting or repair. The Note also permits completion of movement of a component to a safe position, should the source range neutron flux monitor be discovered inoperable during component movement.

and movement of fuel, sources, and reactivity control components within the reactor vessel delete

RHR and Coolant Circulation-High Water Level B 3.9.5 BRAIDWOOD UNITS 1 & 2 B 3.9.5 2 Revision 105 BASES LCO Only one RHR loop is required for decay heat removal in MODE 6, with the water level 23 ft above the top of the reactor vessel flange because the volume of water above the reactor vessel flange provides backup decay heat removal capability. One RHR loop is required to be in operation and OPERABLE to provide:

a.

Removal of decay heat; b.

Mixing of borated coolant to minimize the possibility of criticality; and c.

Indication of reactor coolant temperature.

An OPERABLE RHR loop includes an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs. Management of gas voids is important to RHR System OPERABILITY.

The LCO is modified by a Note that allows the required operating RHR loop to be removed from service for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause a reduction of the RCS boron concentration. Boron concentration reduction is prohibited because uniform concentration distribution cannot be ensured without forced circulation. This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, decay heat is removed by natural convection to the large mass of water in the refueling cavity.

introduction of coolant into the RCS with boron concentration less than required to meet the minimum boron concentration of LCO 3.9.1 delete

RHR and Coolant Circulation-High Water Level B 3.9.5 BRAIDWOOD UNITS 1 & 2 B 3.9.5 3 Revision 0 BASES APPLICABILITY One RHR loop must be OPERABLE and in operation in MODE 6, with the water level 23 ft above the top of the reactor vessel flange, to provide decay heat removal and mixing of the borated coolant. The 23 ft water level was selected because it corresponds to the 23 ft requirement established for fuel movement in LCO 3.9.7, "Refueling Cavity Water Level." Requirements for the RHR System in MODES 1, 2, 3, 4, and 5 are covered by LCO 3.4.6, "RCS Loops-MODE 4,"

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled," LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled," LCO 3.5.2, "ECCS-Operating," and LCO 3.5.3, "ECCS-Shutdown." RHR loop requirements in MODE 6 with the water level < 23 ft are located in LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

ACTIONS A.1, A.2, A.3, and A.4 If RHR loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations. Reduced boron concentrations can occur by the addition of water with a lower boron concentration than that contained in the RCS. Therefore, actions that could result in a reduction in the coolant boron concentration must be suspended immediately.

With no forced circulation cooling, decay heat removal from the core occurs by natural convection to the heat sink provided by the water above the core. A minimum refueling water level of 23 ft above the reactor vessel flange provides an adequate available heat sink. Suspending any operation that would increase decay heat load, such as loading a fuel assembly, is a prudent action under this condition. Therefore, actions shall be taken immediately to suspend loading of irradiated fuel assemblies in the core.

Suspension of these activities shall not preclude completion of movement of a component to a safe condition.

With the unit in MODE 6 and the refueling water level 23 ft above the top of the reactor vessel flange, removal of decay heat is by ambient losses only. Therefore, corrective actions shall be initiated immediately and shall continue until the RHR loop requirements are met.

Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

RHR and Coolant Circulation-Low Water Level B 3.9.6 BRAIDWOOD UNITS 1 & 2 B 3.9.6 3 Revision 0 BASES ACTIONS A.1 and A.2 With one or more RHR loops inoperable, the RHR System may not be capable of removing decay heat and mixing the borated coolant. Therefore, action shall be immediately initiated and continued until the required number of RHR loops are restored to OPERABLE status or until 23 ft of water level is established above the reactor vessel flange. When the water level is 23 ft above the reactor vessel flange, the Applicability changes to that of LCO 3.9.5, and only one RHR loop is required to be OPERABLE and in operation. An immediate Completion Time is necessary for an operator to initiate corrective actions.

B.1, B.2, and B.3 If no RHR loop is in operation, there will be no forced circulation to provide mixing to establish uniform boron concentrations. Reduced boron concentrations can occur by the addition of water with a lower boron concentration than that contained in the RCS. Therefore, actions that would result in a reduction in the coolant boron concentration must be suspended immediately.

In addition, with no forced circulation, any decay heat removal occurs by ambient losses only. Therefore, action shall be initiated immediately to restore one RHR loop to operation. Once initiated, actions shall continue until one RHR loop has been restored to operation.

Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

ATTACHMENT 5 Proposed Technical Specifications Bases Changes (Mark-up) - For Information Only Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 B 3.3.1-43 B 3.3.1-44 B 3.4.5-3 B 3.4.5-5 B 3.4.5-6 B 3.4.5-7 B 3.4.6-2 B 3.4.6-4 B 3.4.7-3 B 3.4.7-4 B 3.4.7-5 B 3.4.8-2 B 3.4.8-3 B 3.4.8-4 B 3.4.18-1 B 3.4.18-3 B 3.8.2-6 B 3.8.5-4 B 3.8.8-4 B 3.8.10-3 B 3.9.1-3 B 3.9.1-4 B 3.9.2-3 B 3.9.3-3 B 3.9.5-2 B 3.9.5-3 B 3.9.6-3

RTS Instrumentation B 3.3.1 BYRON UNIT 1 & 2 B 3.3.1 43 Revision 78 BASES ACTIONS (continued)

OPERABLE when the power level is above the capability of the source range, P-6, and below the capability of the power range, P-10. If THERMAL POWER is greater than the P-10 setpoint, the NIS power range detectors perform the monitoring and protection functions and the intermediate range is not required. The Completion Times allow for a slow and controlled power adjustment above P-10 or below P-6 and take into account the redundant capability afforded by the redundant OPERABLE channel, and the low probability of its failure during this period. This action does not require the inoperable channel to be tripped because the Function uses one-out-of-two logic. Tripping one channel would trip the reactor. Thus, the Required Actions specified in this Condition are only applicable when channel failure does not result in reactor trip.

G.1 and G.2 Condition G applies to two inoperable Intermediate Range Neutron Flux trip channels in MODE 2 when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint.

Required Actions specified in this Condition are only applicable when channel failures do not result in reactor trip. Above the P-6 setpoint and below the P-10 setpoint, the NIS intermediate range detector performs the monitoring Functions. With no intermediate range channels OPERABLE, the Required Actions are to suspend operations involving positive reactivity additions immediately. This will preclude any power level increase since there are no OPERABLE Intermediate Range Neutron Flux channels. The operator must also reduce THERMAL POWER below the P-6 setpoint within two hours. Below P-6, the Source Range Neutron Flux channels will be able to monitor the core power level. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.

H.1 Condition H applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2, below the P-6 setpoint.

With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions.

With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

Required Action G.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided they are accounted for in the calculated SDM.

RTS Instrumentation B 3.3.1 BYRON UNIT 1 & 2 B 3.3.1 44 Revision 78 BASES ACTIONS (continued)