Text

Forwards Response to Request for Addl Info Re Conversion to Improved Tech Specs (NURG-1433),per NRC
	ML20198Q592
Person / Time
Site:	Brunswick
Issue date:	11/06/1997
From:	Jury K; CAROLINA POWER & LIGHT CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	RTR-NUREG-1433 BSEP-97-0487, BSEP-97-487, NUDOCS 9711120268
	Download: ML20198Q592 (63)
	v • d • e

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_.,'.n 3 Caroana Power & Light Company; PO Box 10429 '

Southport, NC 28461 0429:

- NOV 061997 SERIAL: BSEP 97-0487

. U, S. Nuclear Regulatory Commission .

ATTN: Document Control Desk Washington, DC 20$551 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62

- RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS-Gentlemen:

On November 1,- 1996 (Serial: BSEP 96-0414), as supplemented on October 13,1997 (Serial:

BSEP 97-0443), Carolina Power & Light (CP&L) Company submitted a license rmendment request for the conversion of the Brunswick Steam Electric Plant (BSEP), Unit Nos, I and 2 Technical Specifications to the Improved Technical Specifications, as contained in' Revision 1 of NUREG 1433, " Standard Technical Specifications General Electric Plants, BWR/4." In a letter dated October 1,1997, the NRC requested additional information regarding this license amendment request; the requested information is enclosed. !

Please refer any cuestions regarding this submittal to Mr. Warren J. Dorman, Supervisor -

Licensing at (910) 457-2068.-

Sincerel ',

Keith R. Jury Manager - Regulatory Affairs Brunswick Steam Electric Plant MAT / mat g g c

Enclosure:

Response To Request For Additional Information 1GOM

gugggg y lElEl ele [E.EE.E -

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L Document Control Desk BSEP 97-0487 / Page 2 =

cc (with enclosure):

U. S. Nuclear Regulatory Commission, Region II -

1 ATTN:, Mr. Luis A. Reyes, Regional Administrator -

Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85:

Atlanta, GA 30303 U. S. Nuclear Regulatory Commission -

ATTN: Mr. Charles A. Patterson, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461--

= U. S. Nuclear Regulatory Commission ATTN: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738 The Honorable Jo A. Sanford Chairman - North Carolina Utilities Commission PO Box 29510 Raleigh, NC 27626-0510 Mr. Mel Fry Director - Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

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4 6-u ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR 62

. RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS 6

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BRUNSWICK W IT 1 & 2 CTS IWtKUP 3.8.1

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. ISSUE # . DOC # ' CTS /STS DESCRPTION OF ISSUE.' 'DATE DATE1 COMMENTS or ~ REF- OPENED CLOSED.

JF0 9 3.8.1-1 L2 LCO 3.0.5 The CTS is more restrictive than the proposed 4-28-97 DOC should be ;

Pg. 3/40-1 ITS, and the difference is not accurately identifed revised to address i or adequately justified. the staff concern. i BNP RESPONSE in Revision A to the improved Technical Specification (ITS) submittal, Discussion of Change (D')C) L2 for ITS 3.8.1 is revised to address the NRC concern.

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F BRUNSWICK (NIIT 1 & 2 CTS HARKUP -! ~

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g' ISSUE #

sDOC#3 CTS /ST8;) DESCRIPTION OF ISSUE <DATE :DATE: ." nn-WTS -

m y, or -

iREFA OPENED JCLOSED 0%~ 'w .

!' 3.8.1-2 L.3 - Action a.3 The DOC appears to indecote that the licensee 4-28 97- Revue the DOC l ;

Pg. 3/48-1 considers the NUREG 6 day limitanon to be such that the 6 day applicable to overtappens inoperabihties of offsste limitacon is only :

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! circuits or DGs, not offsite circuits AND DGs. applicable to f

, overtapping .

The second part of this DOC (which references inopereelRtses of :

Sect.1.3) appears to be incorrect. Extended offsste circuits g[d ;

completion times such as those proposed fo. DGs. - Also, revise :

3 Condition B&C are not covered by the provisions Conolpon B.

I of Section 1.3. ;

The second port of l the DOC should be {

deleted. .

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BNP RESPONSE in Revision A to the ITS sutmuttal, DOC L.3 for ITS 3.8.1 is revoed to address the NRC concem med with overtappeng i inoperabilities. However, revision of the second Co.C- ^' -. Time of ITS 3.8.1 Required Action B.3 ti.e., APC 10 days from J_ _ _21 of - ;

l failure to meet LCO 3.8.1.a or b) is not justified since the intent of the presentation of this second C, .W_ . Time le to preclude !

operation with contiguous failures of AC sources (e.g., a d;esel generator (DG), an offsete cwcult, and another DGl. Therefore, the '

4 restriction must be applied to failure to meet either ITS LCO 3.8.1.s (i.e., subloct unit offsite circuit OPERA 81UTY requirements) or ITS LCO 3.8.1.b (i.e., DG OPERABILITY requirements). '

Whde the maximum Completion Times provided in the ITS 3.8.1 ACTIONS are not addressed in the C,,.,, _ _--- , Twne extension prowesions

' of ITS Section 1.3, these provisions are applicable to ITS 3.8.1 Conditions involving offsite circuit inoperabienes or DG inoperabinnes. In '

! the event one offsite circuit is inoperable and a second offsite circuit subsequently becomes inoperatWe, the prowiesons of ITS Section 1.3 allow an extension of the asowable restoration time from the time of initial loss for the subsequent inoperablRty. This atowance, se described in ITS Section 1.3 and DOC L.3 for ITS 3.8.1, is only applicable for one use. In addinon, this extension con not be used to i

. exceed the me imum Completion Tames provided in the ITS 3.8.1 ACTIONS. Therefore, the hg in the second part of DOC L.3 for l ITS 3.8.1 is provided to acknow edges the allowance provided in ITS Section 1.3 and is moentained for cornpisteness.

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i BitultSWICK UNIT 1 & 2

. CTS HMKUP 3.8.1 1 l

ISSUEF' ; DOC #. ' CTS /STSI DESCRW' TION OF ISSUE UDATEt IDATE! enmanaamys'

Jor : 'REFJ W OPENED i Ct.OSED s

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,- u l 3.8.1-3 L4 Action b.2 The proposed change is acceptable. However, 4-28-97 Revise the DOC to '

Pg. 3/4 8-2 the DOC could be improved. For example, the aqHress the stoff's -

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, DOC appears to be written with only 2 DGs as conceme.

i opposed to the 4 DGs at Brunswick. A better case can be mode for not testeg the remaining .g DGs if the absence of a common mode failure can .

be established, and a better case can be made for j the proposed 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months w..fzW. time.

i BNP RESPONSE in Remsion A to the ITS submrttal, DOC L4 for ITS 3.8.1 is revised to address the NRC concem.

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! 3.8.1-4 L3 Action b.3 See discussion on DOC L3 in comment 3.8.1-2. 4-28-97 Revise the DOC Pg. 3/48-2 The NUREG hmrtation on overlopping similar to the DOC u inoperabilities applies to offsite circuits and DGS. rensen for comment 3.8.1-2. j BNP RESPONSE in Revision A to the ITS submittal, DOC L3 for ITS 3.8.1 is revised as discussed in the response to NRC issue 3.8.1-2.

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l b BIMI5 NICK UNIT.1 & 2 CTS NARKUP 3.8.1

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i l" : ISSUE #. + < . * . DOC #T .: CTS /STS . -

DESCRIPTION OF ISSUE + iDATE? ,_.DATE3 CONSEENTS

or -: REF- OPENED CLOSED

.; lFD # : m.

4 3.8.1-6 A.2 Acton d.1 Two or more offsite circuits inoperable is not an 4-28 Revise the DOC to

allowance in the CTS, and DOC A.2 does not enore adeguately :3 rneke an adequete case for including it in the ITS. address why . ;

allowing *two er.

more" offsite circuits to be inoperable et the some time.- (This l" l could mean as 4 circuits inoperable ,

for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .).

SNP RESPONSE in Revision A to the ITS submittal, new DOC L13 for ITS 3.8.1 is provided to address the condition of two *or more* offsite circuits l inoperable at the same time. ;

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3.8.1-7 L3 Acton d.3 See discussion on DOC L3 in comment 3.8.1-2.' 4-29-97 Revise DOC and the , i submittel for '

Condition 8.

BNP RESPONSE in Revision A to the ITS subtruttel, DOC L3 for ITS 3.8.1 is revised as discussed in the response to NRC issue 3.8.1-2.

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BRUNSWICK UNIT 1 & 2 CTS MARKUP 3.8.1 ISSUE 's DOC

CTS /STS DESCRIPTION OF ISSUE .DATE- :DATE COMMENTS :

or- REF- OPENED CLOSED 1

, JFD # -

3.8.1-8 L4 Action e.1 See discussion on DOC L4 in comment 3.8.1-3, 4-29-97 Revise DOC L4.

above.

BNP RESPONSE in Revision A to the ITS submittal, DOC L4 for ITS 3.8.1 is revised to address the NRC concern.

3.8.1-9 L3 Action e.3 See discussion on L3 in comment 3.8.1-2. Revise DOC and i submittel.

BNP RESPONSE in Revision A to the ITS submittal, DOC L3 for ITS 3.8.1 is revised as discussed in the response to NRC issue 3.8.1-2.

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BRistSWICK L9 TIT 1 & 2 CTS MARKUP

3.8.1 l

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. ISSUE # 1 JDOC#1 CTS /STS - DESCRIPTION OFISSUE iDATE- iDATE? CORSENTS S" L or i - REF -l ,

OPENED CLOSED ,

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? JFD # - '

3.8.1-10 A.7 SR 4.8.1.1.1 The proposed Note does not appear to be - 4-30-97' Revise the submittel acceptable. The Note states that the SR is only to ensure sE ;

applicable to Unit 1 offsite c8 cuits, but some - requwed offsite Actions require verifymg the OPERABILITY of cwcuits are treated

offsite circuits by performing the SR. In those the some.

cases, the Unit 2 offsite circuits are excluded even though the LCO requires them.

BNP RESPONSE in Revision A to the ITS submittal, the Note to the ITS 3.8.1 Survedience Requirements is deleted. As a result of this change, eE required

, offsite circuits are treated the same.

3.8.1-11 LO.1 SR 4.8.1.1.1.b The change 4 rom 18 rnonths to 24 months for the 4-30-97 SR frequency 6 beyond the scope of the ITS ,

conversion. !

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' BNP RESPONSE The change from 18 months to 24 months for the Survedience Frequency mey be beyond the scope of the NRC Technical # -

, Branch review, however, Surveillence Frequency extensions to 24 months have, in the post, been processed as port of ITS conversions. t

This change is currently being processed by the NRC Project Meneger for Brunswick Unit Nes.1 and 2 and should be included as port of '!

the ITS conversion. !

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BRUNSWICK WIT 1 & 2 CTS MARKUP 3.8.1

. lSSUE #l - DOC #' . ' CTS /STS ' DESCRIPTON OF ISSUE DATE. DATE- COMMENTS

or - REF. OPENED' . CLOSED JFD #

3.8.1-12 LS SR 4.8.1.1.2.a The DOC references

studies

that have been 4-30-97 Provide specific conducted regarding staggered testing. However, reference to the none of the studies is identified.

studies" and include them in a revised DOC.

BNP RESPONSE in Revision A to the ITS submittal, DOC L6 for ITS 3.8.1 is revised to provide specific reference to the studies that have been conducted regarding staggered testing.

3.8.1-13 A.8 SR The Note proposed to be added to these SRs in 4-30-97 4.8.1.1.2.a.4 the ITS could be more cieer.

SR 4.8.1.1.2.a.5 SR 4.8.1.1.2.d.2 Note

SR 4.8.1.1.d.3 SR 4.8.1.1.2.d.5 BNP RESPONSE The proposed Notes, which allow a single test at the specifisd Frequency to satisfy the Surveillence for both units, are consistent with thess provided for similar situations in the Peach Bottom ITS. These Notes are also consistent with current interpretation of the Current Technical Specification (CTS) and are considered to be understandable as written. Therefore, no further enhancement to these Notes is considered to be necessary.

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BRUNSWICK UNIT 1 & 2 CTS MARKUP 3.8.1 cISSUEF- i DOC * -' S CTS /STS DE$CRPTION OF ISSUE - DATE' DATE- COMMENTS'-

' or . REF OPENED CLOSED JFD t 3.8.1 14 7 SR The discussions assocated with changes to this 4-30-97 Provide a 4.8.1.1.2.a.4 SR do not address deleting the 10 second start justificat.on for requirement. deleting the 10 second start reouirement.

BNP RESPONSE in Revision A to the ITS submittal, new DOC L14 for ITS 3.8.1 is provided to justify deletion of the 10 second start requirement.

3.8.1-15 L11 SR The proposed frequency change does not appear 4-30-97 Revise the submittal 4.8.1.1.2.a.3 to be acceptable. Verifying that the fuel oil to require pump transfer pump operates automatically is testing every 31 I determined by how often the pump must operate days, or provide a to replace fuel oil used during DG testing (usually justification for why -

every 31 days). It is not a function of ASME this is not required Section X1 requirements. that does not reference ASME Section XI.

BNP RESPONSE in Revision A to the ITS submittal, the Frequency for verification of operation of the fuel oil transfer pumps (i.e., ITS SR 3.8.1.6) is revised to every 31 days.

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BRUNSWICK UNIT 1 & 2 CTS MARKUP l

3.8.1

-ISSUE #. DOC # CTS /STS' - DESCRIPTION OF ISSUE 1 - DATE' 6 ATE. COMMENTS or REF' OPENED CLOSED JFD #

3.8.1 16 LD.1 - SR 4.8.1.1.2.d The change in frequency from 18 rnonths to 24 5-1-97 rnonths is beyond the scope of ITS conversion.

BNP RESPONSE The change from 18 months to 24 months for the Surveillence Frequency may be beyond the scope of the NRC Techrucal Specification Branch review, however, Surveillance Frequency extensions to 24 rnonths have, in the past, been processed as ps t of ITS conversions.

This change is cu'rently being processed by the NRC Project Manager for Brunswick Unit Nos.1 and 2 and should be included as part of the ITS conversion.

3.8.1-17 LA.1 SR Relocating this SR is acceptable in concept, but 5-1-97 Provide a location 4.8.1.1.2.d.1 there should be some cor.trols associated with it. for this SR which Plant procedures do not provide adequate are adequate controls. controls.

BNP RESi ONSE in Revision A to the ITS submittal, the retocated requirement addressed in DOC LA.1 for ITS 3.8.1 is identified as being relocated to the Updated Final Safety Analysis Report (UFSAR).

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BRUNSWICK IMIT 112 CTS MARKUP 3.8.1 ISSUEF- DOC. F : : CTS /STS . DESCRIPTION OF ISSUE ..: DATE :DATE COMMENTS or REF' OPENED CLOSED JFD #

3.8.1-18 M.6 CTS Note

The DOC incorrectfy indicates that an engine 5-1 57 Correct the DOC.

prelube penod is mandatory. A preiube period is allowed, but not required.

BNP RESPONSE in Revision A to the ITS submittal, DOC M.6 for ITS 3.8.1 is deleted since a preiube pened is a# owed, but not required, in both CTS 4.8.1.1.2.a.4 Note

and ITS SR 3.8.1.2 Note 1.

3.8.1 19 LA.2 CTS Note

The DOC indicates that a part of this Note win be 5-1-97 ff the CTS relocated reiocated to procedures and controned under 10 meterial requires CFR 50.59. Procedures are not subject to control controls, relocate it under 10 CFR 50.59. to a different piece such as the Bases.

If controis are not required, revise the DOC to address why controls are not needed.

bhp RESPONSE in Revision A to the ITS submittal, DOC LA.2 for ITS 3.8.1 is revtsed. The sontrols associated with the relocated requirements of CTS 4.8.1.1.2.a.6, originally described in DOC LA.2 for ITS 3.8.1 as being relocated to procedures, are proposed to be eliminated.

Therefore, new DOC L12 for ITS 3.8.1 is provided in Revision A to the ITS subnuttal to justify this elimmatron.

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BRUNSWICK UNIT 1 & 2 CTS MARKUP 3.8.2 ISSUE # - DOC # .. !: CTS /STS DESCRPTION CM ISSUEi DATE- 'DATE- COMMENTS

or .. REF . OPENED . C;.OSED 7

-JFD #.

3.8.2-1 A.2 LCO 3.8.2.b The statf does not underr.tand why these two parts 5-12-97 Provide a discusson M.1 LCO 3.8.2.C of the same LCO have 3ifferent wading. Does the to respond to the proposed wording mean that LCO 3.8.8 does not staff questions.

address the ventAation requirements of Section 3.77 Revise the DOCS as Does this wording rneen that the SecSon 3.7 - necessary. The LCO .

ventilation systems do not require DG backup? should be cleer as to Also, the wording of LCO 3.8.2.b is confusing. Is whether or not the the requirement for 2 DGs, each capable of Unit 2 powering the same bus, or 2 DGs, each capable of systems / components powering a different bus? required by Unit 1 must have DG

- backup.

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BRUNSWICK IMIT 1 & 2 CTS MMIKUP 3.8.2 BNP RESPONSE The wording of ITS LCO 3.8.2.b and ITS LCO 3.8.2.c is different to reflect the Brunswick Unit Nos.1 and 2 design associated with 'f

, 3.8.2-1 providing AC power to the Control Room Emergency Ventilation (ChEV) System, Control Room Air Conditenmg System, and DC sources.

The DGs are capable of providing power to their assocated 4.16 kV emergency buses (E1, E2, E3, and E4). However, the Unit No.1 offsite circuits are only capable of providing power to 4.16 kV emergency buses El and E2 and the Unit No. 2 offsite crcuits are only capable of providing power to 4.16 kV emergency buses E3 and E4. Power is prended for the required CREV System components, Control Room Air Conditioning System components, and DC source components through 4.16 kV emergency buses assocated with both units. Therefore, ITS LCO 3.8.2.c is worded to reflect that the opposite unit offsite circuits must be OPERABLE to support those components needed by the shutdown unit that are powered from the emergency b Joes primarily assocated with the opposite unit.

The wording of ITS LCO 3.8.2.b reflects the fact that an onsite Class IE AC power distribution subsystem consists of two 4.16 kV emergency buses, as defined in ITS Bases Table B 3.8.7-1. Therefore, ITS LCO 5.8.2.b requires two DGs to be OPERABLE and esther -'

capable of each supplying one of the two 4.16 kV buses in one Class IE AC power distribution subsystem required by ITS LCO 3.8.8 or capable of each supplying one 4.16 kV emergency bus in one of the two Class IE AC power distribution subsystems required by ITS LCO 3.8.8. ITS LCO 3.8.2.b will be revised in Revision B to the iTS submittal to delete the reference to only "one" Class IE AC power distribution subsystem being required.

In addition, the intent of the presentation of ITS LCO 3.8.2.a, b and c is to ensure that all required components are other powe.A from an OPERABLE offsite AC power source or capable of being powered from en OPERABLE onsite AC power source.

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BRUNSWICK WIT 1 & 2 CTS NutKUP 3.8.2 ISSUE # ' DOC # - CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMEkTS _

or .REF OPENED -CLOSED:

.. JFD #

3.8.2-2 A.5 Action A The proposed Note is not necessary, and possibly 5-12-97 Delete the f%ta Re:

Note confusing, in Modes 1,2, or 3,if the AC or DC 3.0.3 appiceb2ty.

sources are inadequate to support fuel handling, the AC or DC sources operating LCOs will require a plant shutdown, and 3.0.3 is not a concem.

BNP RESPONSE The clarification provided by the proposed Note to the ITS 3.8.2 ACTIONS is necessary because defaulting to ITS LCO 3.0.3, during irradiated fuel assembly rnovement in MODE 1,2, or 3, would require the reactor to be shutdown but would not require immediate suspension of movement of irradiated fuel assemblies when required components are inoperable. ITS LCO 3.0.3 is only applicable in MODE 1, 2, or 3. Therefore, once the unit has been placed in MODE 4, in accordance with ITS LCO 3.0.3, ITS LCO 3.0.3 is no longer applicable. The actions of the " shutdown

Electrical Power System Technical Specifiestions (e.g.,ITS 3.8.2 ACTIONS), which require suspension of irradiated fuel movement, would then be applicable. However, the requirements of ITS LCO 3.0.3 would allow up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 4 and, as a result, up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months would be s8 towed to suspend irradiated fuel movement. Therefore, with the unit in this Condition, the Note, *LCO 3.0.3 is ret applicable,* ensures that the actions for requiring immediate suspension of movement of irradiated fuel assemblies are not postponed due to entry into ITS LCO 3.0.3 and that the unit is immediately placed in a condition of minimum risk, with respect to fuel handling activities during MODE 1,2, or 3. A revision to generic change Tochtwcal Specification Task Force ITSTF1-36 has been proposed to reflect this information.

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BRUNSWICK UNIT 1 8.2 CTS MARKUP 3.8.2 ISSUE 's DOC # ' ' CTS /STS ' DESCRIPTION OF ISSUE 'DATE DATE' COMMENTS or. REF OPENED CLOSED JFD # ~

3.8.2-3 L2 SR 3.8.2.1 if Unit 1 is in Mode 4 or 5, are other of tree Unit 2 5 '2-97 Provide a response A.6 Note DGs required to support Unit 17 ff not, why not? to the staff if either Unit 2 DG is required, the proposed Note questions and, as to this Unit 1 LCO would not require several SRs appbceble, how the to be perforrned on Unit 2 DGs. This violates the licensee proposed to Unit 2 OPERABILITY requirements of LCO 3.8.1. address the issue of Unit 2 OPERABILITY requirements.

(Reverse the

- question for thit 2 in Modes 4 or 5 and Unit 1 in Modes 1-3.)

BNP RESPONSE in Revision A to the ITS submittal, the Note to ITS SR 3.8.2.1 is revised to reflect that the allowance for certain Surveillence Requirements to not be performed is only applicable if the opposite unit's Technical Specifications do not require performance of these Surveillance Requirements.

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, Brut'9flCK UNITS 1 Ale 2 CTS muur l

3.8.4

! ISSUE A c,

i DOC #f

. Oora CTS /STSi iREFi i DESCRFTION OF ISSUE

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$ DATE3 ,

CLOSED

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1 N/A Sr 4.8.2.3.1.o Part is. of CTS SR 4.8.2.3.a includes a 8-12-97 The Econese should j requirement to verify the alignment of power provide a ,

justification for the . ,

conversion modules to the Division 11 bus b (Unit 1 and Unit 2). The CTS markup indicates this apperent deletion, . ,

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, requirement is moved to LCO 3.8.7. However, a or retain the CTS.

review of the proposed ITS did not show thir item i as part of LCO 3.8.7, the LCO Actions, or the -

LCO SRs. This apperent deletion of a CTS .!

requirement is not justified.

BNP RESPONSE in Revision A to the ITS submsttal, the requirement of CTS 4.8.2.3.1.b (i.e., verification of the esenment of power conversion modules to '

Division it bus b) is added as ITS SR 3.8.7.2.

2 N/A LCO The CTS merkup shows LCO 3.8.?.3.a.1 la 8-12-97 The licensee should i

3.8.2.3.2.b.2 250/125 voit bus) as being moved to ITS LCO , provide a ~ i 3.8.7. However, a review of the proposed ITS did jt,.; :::_ . for the

, not show this item as part of LCO 3.9.7, the LCO apparent deletion,

, Actions, or the SRs. This apparent deletion of a or retain the CTS.

i CTS requirement is not justified.

MNP RESPONSE The CTS merkup identifies that CTS LCO 3.8.2.3.a.1 requirements, assocated with the DC buses required to be' OPERA 8LE,'are .

addressed in ITS: 3.8.7. The CTS mwkup and DOCS for ITS 3.8.7 Identify that these requirements are relocated to the Beses of

[ 'ITS 3.8.7 per DOC LA.1 for ITS .3.8.7.

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BRUNSWICK UNITS 1 Alm 2 CTS MARKUP 3.8.4 ISSUE #: : UOC # - - CTS /STS DESCRFTION OF ISSUE DATE1 DATEL COMMENTS or ' REF OPENED CLOSED

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LJFD # -.

3 M.5 SR The CTS merkup and DOCS M.5 and LA.2 show 8-12-97 The licensee should LA.2 4.8.2.3.2.b.2 the value of connection resistance as moved to revise the submntal

' the Bases. This is Not Acceptable. These valves to retain resistance should be retained as part of the SR, consistent valves as part of the with CTS and NUREG-1433. SR.

BNP RESPONSE in Revision A to the ITS submittal, plant specific battery connection resistance values are provided in ITS SR 3.8.4.2.

4 LD.1 SR The proposed change in frequency for 8-12-97 This is a beyond 4.8.2.3.2.c.3 performance of SR 4.8.2.3.2.C.3 from every 18 scope isste.

SR months to every 24 months is beyond the scope 4.8.2.3.2.d of a conversion to the ITS. This is also true of the proposed change in frequency from 18 months to 24 months for SR 4.8.2.3.2.d.

8NP RESPONSE The change from 18 months to 24 months for these Surveillance Frequencies may be beyond the scope of the NRC Technical Specification Branch review, however, Surveillance Frequency extensions to 24 months have, in the past, been processed as part of ITS converskms. These changes are currently being processed by the NRC Project Manager for Brunswick Unit Nos.1 and 2 and should be included as part of the ITS conversion.

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BRUNSWICK bMITS 1 AfG 2 CTS fWUtKUP 3.8.4 ,

i

' ISSUE #'

' DOC #/ CTS /STS ' '

' DESCRFfl0N OF ISSUE DATE DATE COMMENTS

. ' or .REF OPENED CLOSED p' JFD # "

5 L2 SRs The Notes added to SR 4.8.2.3.2.d.1 and SR 8-12-97 The licensee should 4.8.2.3.2.d.1 4.8.2.3.2.e are not necessary. A generic change revise the sutwwwttal 4.8.2.3.2.e has been approved for SR 3.0.2 which covers to delete the unplanned events that satisfy the criterie of the proposed Notes, SR. The licensee should adopt the generic and adopt the resc'4 ion of this issue in lieu of adding notes to NUREG generic individual surveillances. change.

BNP RESPONSE Generic change TSTF-08 revises the Bases of ITS SR 3.0.1 to allow credit to be taken for unplanned events which satisfy a Surveillence.

TSTF-08 does not rnake a corresponding change to ITS SR 3.O.1. ITS SR 3.8.4.6 and SR 3.8.4.7 are modified by Notes that state:

"This Surveillance shall not be performed in MODE 1 or 2.* These Notes also state that credit is allowed to be taken for unplanned events that satisfy the Surveillance Requirements. Since the Bases can not be used to change Technical Specifications, the portion of the ITS SR 3.8.4.6 and SR 3.8.4.7 Notes, which allow credit to be taken for unplanned events in MODE 1 or 2, must be rneintmened in the Technical Specifications in order to provide the allowance intended by TSTF-08.

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BRUNSWICK UNITS 1 & 2 CTS MARKUP 3.8.6 !

ISSUE #;

D O C # L. ; CTS /STS . DESCRIPTION OF ISSUE IDATEI' .'DATEl CORN ENTS or; -. REF_ ' OPENED : CLOSED ^ '

' JFD # -

-1 L1 SR DOC L1 could be improved. ' The justif' c etion for 8-12-97 The license should 4.8.2.3.2.b.3 decreasing the number of cells that are checked revise DOC L1 to -

for temperature from all connected cells provide more (approximately 58-60 per 125 vdc bettery) to support for the rep <ewntative cells (10% of connected cells, or 6 change.

cells) should also address such things as *all cells are 'un the some location with a common ventilation system", and *other tests on all connected cells will call attention to cells that may ;

be heating up because of some problem." in its !

present form, DOC L1 does not make a strong ;

case for this less restrictive change.

BNP RESPONSE in Revision A to the ITS submittal, DOC L1 for ITS 3.8.6 is revised to provide additional support for the change.

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BRUNSWICK UNITS 1 & 2

CTS NARKUP 3.8.6 ISSUE F - DOC * -' . CTS /STS ' ' DESCRIPTION OF ISSUE ' DATE' iDATE . COMMENTS or - REF OPENED CLOSED - -

I JFD # ? 'O-2 M.1 Footnote Footnote C to CTS Table 4.8.2.3.2-1 requires that 8-12-97 The licensee should float voltage readings be corrected for electrolyte revise DOC M.1 to temperature. This CTS requirernent is not address staff included in the ITS. The rationele is J.5st the CTS concerns, or retain footnote is a permissive, not a requirement, and CTS.

that deleting the footnote is a more restrictive action. The staff does not agree with this position. It is the staff's view that the footnote constitutes a requirement and that deleting it is a less restrictive change that has not been justified.

BNP RESPONSE in Revision A to the ITS submittal, DOC M.1 for ITS 3.8.6 is deieted and the associated change (deletion of Footnote (c) to CTS Table 4.8.2.3.2-11 is addressed in new DOC L.6 for ITS 3.8.6.

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BRUNSWICK LNIITS 1 & 2 CTS MARKUP 3.8.7 ISSUE #1 DCC # CTS /STS ~ DESCRIPTION OF ISSUE DATE DATE COMMDITS

, ' or .; 'REFi OPENED CLOSED-

.JFD # '

1 LA.1 LCO LCO 3.8.2.1 (CTS) includes the requirement that 8-12-97 The licensee should 3.8.2.1 tie breakers between redundant busses must be revise the submittoi open in order to establish OPERABILITY. The to address staff recensee proposed to move this requirement to the concems.

Bases as discussed in DOC LA.1. In the staff's view, this DOC does not make a very strong argument in sur aort of this change. In Fght of this, the staff is of the opinion that the ' CTS requirement should be retained, possidr as part of proposed ITS SR 3.8.7.1. The licensee should revise the submittel, or provide a better justification for why the proposed change is acceptable.

BNP RESPONSE in Revision A to the ITS submittal, DOC LA.1 for ITS 3.8.7 is revised to provide additional justification for relocation of the associated information to the ITS Bases.

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4 BRUNSWICK UNITS 1 & 2 CTS MARKUP 3.8.7

~ ISSUE F ' DOC # i CTS /STS - ' DESCRIPTION OF ISSUE '- DATE ! DATE COMMENTS or REF OPENED CLOSED-JFD F 2 N/A LCO The CTS markup for LCO 3.8.2.3 does not appear 8-13 97 The licensee should 3.8.2.1 to be acceptable. Proposed ITS Action C is the revise the sutmttal prirnery concern. The CTS allow *one or more* to addrers staff batteries / chargers "in cne Division

to be concems.

inoperable for up to 7 days. This allowance, however, is only applicable if all redundant systems /cornponents are OPERABLE. Proposed Condition C would allow multiple *DC electrical power distribution subsystems" to be inoperable

, in either Division, subject only to the constraint of Condition E. This is a less restrictive change that has not been identified and has not been justified.

The submittal should be revised to address this ConCem.

BNP RESPONSE in Revision A to the ITS submittal, new DOC A.7 for ITS 3.8.7 is provided to address the NRC concern.

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BRUNSWICK UNITS 1 & 2 -

CTS MARKUP 3.8.7

-ISSUEF -DOC #- : CTS /STS - DESCRIPTION OF ISSUE '

'DATE .DATE ~

COMMENTS or - .REF l OPENED TCLOSED JFD 9 : ,

3 LA.1 SR The CTS SR 4.8.2.3.1 requirement to ersure the 8-13-97 The licensee should 4.8.2.3.1 tie breakers are open is moved to the Bases in the revise the submrttal ITS. The justification for this change is provided to address staff in DOC LA.I. At stated in issue No.1 above, the concerns.

staff does not feel that DOC LA.1 presents a strong argument in support of this proposed change, and that the requirement should be retained. The licensee should revise the submittal, or provide a better justifcation for why the proposed change is acceptable.

BNP RESPONSE in Revision A to the ITS submittal, DOC LA.1 for ITS 3.8.7 is revised to provide additional justifkation for relocation of the associated :

information to the ITS Bases.

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CTS MARKUP 3.8.7 i

. ESUEFL fDOCF CTS /STS - DESCRPTION OFISSUE DATE' :DATE COMMENTS or REF' OPENED CLOSED ;

-JFD #- .

4 LA.2 SR CTS SR 4.8.2.3.1.b, which regures verifyme that 8-13-97 The ~4ensee shount 4.8.2.3.1.b no more then 2 power corwersion modules are revise the submitte4 '

oligned to the Division 5 Bus B,is proposM to be to address staff rnoved to the Beses. The ju.i;LiW. for this concerns. '

change (DOC LA.2) does not provide a strong argument in support of this change. The staff is .

of the opwwon that this requirement should be retained in TS. The licensee M revise t5e '

subenttet to address staff concoms, or provide a I better justification for why the proposed change is i acceptable. , [

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, BNP RESPONSE in Revision A to the ITS sutmuttet, the requirement of CTS 4.8.2.3.1.h (Lo., verifiestion of the C . i of power conversion modules to l Division H bus b) is added es ITS SP 3.8.7.2. !

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BRURSWICK INIITS 1 & 2 CTS MAKUP 3.8.7

- ISSUE F ' DOC # CTS /STS DESCRemON OF ISSUE DATE 'OATE enmanasmTS m REF OPENED CLOSED

..JFD #

. 5 LA.1 LCO Proposed cfenges to Actens of CTS 3.8.2.4.1 as

, L1 3.8.2.4.1 justified by DOCS LA.1 and L1 are acceptetdo in 3 concept. However, the staff hos some concem regarding the use of the term *..., u"_4- instete acten to* as found in ITS Condmon 8. The staff -

understands why this i... :':.i was selected, i but is stir concemed ateut the lock of a definitive time constract where it is used. The , W Condition (B) could be interpreted as :;n d met for

an ineefinite pened of time promded some form of l ecten to transfer to the attemete power source was initiated immediatey. This, in tum, could leave affected safety emmpment inoperable for the some time period. The staff suggests that the Required Actens be revised as fotows: 8.1.1

, initiste action to transfer DC electncal power subsystem to its aRemote source AND 8.1.2 Declere required features supported by the snocerable DC electncal power distributert subsysteminoperable. The Complebon Time for B.1.1 would be immodately, and the Comple: ion Time for B.1.2 would be immodetely and continuing until the power transfer is complete.

Wrth this wording, the AOTs assocated with the inoperable equipment would drive the completen of the power transfer wh9e the wording of 8.1.1 would stiE preclude entenng a default statement.

The licensee should coreder the staff suggestion and re<ise the submrttal n consdered appropriate.

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BIMISWICK IMITS 1 & 2 ,

CTS MRKUP 3.8.7 1

BNP RESPONSE in "s.'s. A to the ITS sutmttal, the Actens of CTS 3.8.2.4.1, renected in ITS 3.8.7 ACTIONS 6.e., ITS 3.8.7 Required AcDons C.1, 3.8.7 5 C.2, C.3, and C.41, are rev: sed to address the NRC concem.

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, SNP IESPONSE in Renmon 8 to the ITS subnwttal, Justificaten for Doneten (JFDI 4 wm be remmed tc include the fosewes addeonel edernemen:

t 3.8.1-1

NUREG-1433 (ISTS) 3.8.1 Condeon D is rensed to renect the BGP Units 1 and 2 electncet demon and SPF ITS LCO 3.8.1, which toweres four offsite circuits to be OPERA 8LE. ISTS 3.8.1 Condmon D was wntten beood upon the soeungreen in Regulatory

Guale 1.931 that two offsite circuits are resured by the LCO and that less of these two offeste cwcusts results in a teesi less of i offsete power to the Class IE AC Bactncel Power Detribucon System. Reguistory Gude 1.93 and ISTS 3A.1 asow a Core j Trne of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for this condleon. With the SNP Units 1 and 2 demon, a less of the four effeite cwcues S.e., more then two eMolte

' circuits) results in this some condmon amoumed in Reguistory Guide 1.93 and ISTS 3A.1 Condmen D. Therefore, ISTS 3A.1 i j Conetton D is rensed (in SNP ITS 3.8.1 Condmon El to moeten conostency with the intent of ISTS 3 A.1 Condleon D and esnect j the SNP Units 1 and 2 offste circuit regurements G.e., two er more offste circuits may be inoperaisie for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). '

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ISTS 3.8.1 Condmon E is rensed to renect the SNP Units 1 and 2 electnesi demon and SNP ITS LCO 3 A.1, whsch requrw four diesel generators (DGsl to be OPERA 8LE. ISTS 3.8.1 Condeon E was wntten bened upon the soeumpton (in Regulatory Gude 1.931 that two DGs are required by the LCO end that loss of these two DGs results in a totsi less of onene power to the Ones IE AC Bectrical Power Distributen System. Regulatory Guide 1.93 and ISTS 3.8.1 anew a Correiecor Tene of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for this condson.

With the BNP Units 1 and 2 demon, a loss of the four DGs U.e., more then two DGol results in this some condeen assumed in Reguistory Guale 1.93 and ISTS 3.8.1 Condmon E. Therefore ISTS 32.1 Condeon E is rensed pn SNP ITS 32.1 Cenemen G1 to ,

moeten conostency with the intent of ISTS 3.8.1 Condeon E and renect the BNP Units 1 and 2 DG regurements U.e., two er more DGs may be k.:;_2*: for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ). '

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l-o BRUNSWICK NUREG MARKUP 3.8.1 ISSUE # . DOC # . CTS!STS DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPBED CLOSED pog 2 8 SR The proposed deletion of Note 1 in NUREG-1433 The 3.8.1.2 SR 3.8.1.2 is acceptable because this note is a licensee permissive, not a requirement. The Econsee is not should obligated in any way to include permissrves in the reconsider ITS. However, the staff does not agree with the deleting licensee's perception as discussed in MD #8. The NUREG staff is not aware cf anything in NUREG-1433 or Note 1.

any other document that specificaHy states,in a generic sense, that one SR may be substrtuted for another SR. Cornstant with this view, the OGs t sve considered it necessary to include a genene statement in Section 3.0 of the NUREGs which !

eBows unplanned events to satisfy the '

requirements of c SR. The staff recommends that the licensee reconsider this proposed deletion.

BNP RESPONSE While there is nothing written in NUREG-1433, or any other document, that specificany states, in a genene sense, that one Surveillence may be substituted for another Surverlience, it is a common industry practice to substitute a more restric*ive Surveillence for another Surveillance provided an acceptance criterie of the Sun Zse, for whsch substituten is proposed, are settsfied. The underlying reason for the Owner's Groups considering it necessary to include a genene statement, which allows unplanned evaits to satisfy requirements of i a Surveinence Requirement in the Bases of ISTS SR 3.0.1, was that only ISTS Secten 3.8 included Notes that stated: *;;c ca;;, credit l may be taken for unphnned events that satisfy this SR.* Therefore, to preclude confusion as to whether or not unplanned events moy be credited with satisfying Surveillance Requirements in all other places in the Techr> cal Speci*metens, the Bases of ISTS SR 3.0.1 was revised. The deletion of ISTS SR 3.8.1.2 Note 1 is being done to address the some concern. It is considered acceptable to substitute a more restrictive Surveinance Requirement for another Surveillance Requirement provided all acceptance criterie of the Surveillence, for which substitution is proposed, are satisfied. However, Note 1 to ISTS SR 3.8.1.2 is the ordy Note in the ISTS that explicitly states this fact. Therefore, to preclude confusion as to whether or not this practice may be allowed in all other Technical Specifications where this Note does not appeer, Note 1 to ISTS SR 3.8.1.2 is deleted.

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BRUNSWICK NUREG MARKUP l 3.8.1 i

ISSUEF DOC # CTS /STS' DESCRFTION OF ISSUE DATE DATE COuusagTS or' REF' OPENED CLOSED JFD #-

3 9 SR JFD 9 is acceptable. :?c..;.w, the sutmtta' The 3.8.1.2 and could be improved by adding a discussion of how Econsee 3.8.1.3 the issue of accelerated testing will be covered in should l NUREG Table the Brunswick wnplementation of the Meentenance revise the 3.8.1 1 Rule. sutmttal to address staff Concems.

BNP RESPONSE In Revision B to the ITS subtruttal, JFD 9 win be revised to include the fosowing additional information:

Consistent with the guedence in Generic Letter 9441, Caroline Power & Light (CP&L) Corr:peny hes ;.i6 .=iited a program to satisfy the requirements of 10 CFR 50.65,* Requirements for Monitoring the Effectnreness of Meentener ce at Nuclear Power Plants,*

at BNP Units 1 and 2. The DGs are included in this program. As part of this program DG performance win be monitored and if the I

required level of performence can not be assured, action wiR be taken to restore the required level of DG performence. These actions ,

will include accelerated testing of th6 DGs, as applicable. '

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BRUNSWICK MUREG MARKUP 3.8.1 ISSUEF- DOC # CTS /STS DESCRFTION OF ISSUE . DATE DATE COMMENTS or REF OPENED CLOSED i JFD #

l 4 12 SR Proposed SR 3.8.1.6 i somewhat confusing. The The 3.8.1.6 engine mounted ta.r* contaes only 150 gesons of licensee fuel. Most,if not aR of this fuel will be consumed should

, during a monthly surveWience, and makeup from provide a the day tank will be necessary. With this in mind, response why is the frequency for this SR established at 92 to the s'aff days? questen and/or revise the submrttet.

BNP RESPONSE in Revision A to the ITS submittal, the Frequency of ITS SR 3.8.1.6 is revised from 92 days to 31 days.

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, NUREG MAftKUP 3.8.1 ISSUE # DOC #- CTS /STS DESCRFTION OF ISSUE LATE- DATE COMMENTS or. REF- OPENED -CLOSED JFD #

5 2 SR Proposed Note 2 to ITS SR 3.8.1.8 is confuseg.

3.8.1.8 is this Note rooNy necessory? If so, con it Ipe Notes reworded to be more cleer? The plant deogn SR precludes an automatic transfer from the preferred 3.8.1.15 offsite source to the attemete for normeQ source, '

so why is a Note necessary? The Note could also be interpreted to meen this capoiHTrty never needs to be tested. To illustrate this, consider the fonowme. The pie.it is in Mode 3 through 5 and powered from its assooeted SAT - the Note says the automatic transfer SR is not required. Now, ;

the plant transitions to Mode 2. The Mode '

restnction of Note 1 now precludes performmg the test. When is the SR performed?

There is a possbility that NUREG-1433 Note 1 is also incorrect. Consider the plant is Mode 1 but reducing power in properation for a shutdown. At I some point Defore entering Mode 3 land possibly Mode 21, the power must be shifted from the UAT to the SAT. This can not be avoided, yet Note 1 would make this a TS violetxn. More thought needs to be given to both Notes 1 and 2.

The proposed frequency change for SR 3.8.1.8 from 18 rnonths to 24 months is beyond the scope of the ITS conversion.

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BIMtSWICK IUtEG MARKUP 3.8.1 BNP MESPONSE The plant design ordy includes the capetHTrty to automatice#y transfer the unit power supply from the norrnel crcurt to the preferred 3.8.1-5 offsite circuit. Once the power supply has been transferred to the preferred offste circuit, the funcnon of the automenc transfer has been satisfied and, as a result, the rsqueu;.ent to meet the Surveillence for venfying automebc transfer is no longer required. Note 2 is added to ITS SR 3.8.1.8 to p ovide this allowance. H the unit power supply is not from the preferred offsite circuit in MODE 1,2, or 3, then the requirements of ITS 3R 3.8.1.8.a are applicable and are required to be met. If they are not met, then the W offete circuit would be deciered inrporable. If the unit is in MODE 3,4, or 5 and the power supply is from the preferred offsite circuit tthrough the startup auxsiiery transfo mer), autometc transfer -::;:r^y is not required to be OPERABLE. However, in order to ensure thst the ,

i required offsite cicuits are OPERA 8t.E prior to entenne into MODE 1, 2, or 3 fin accordence with ITS LCO 3.0.4), senefactory performence of ITS SR 3.8.1.8.a within the required Frequency would be required to avoid decienne an offsite circuit ;. _i- _i'_ once the j unit power supply was transferred to the normal circuit.

1 in MODE 1 or 2, rnenuel transfer of the unit power supply, wtuch is genera #y initiated to prevent autometc transfer, may be necessary to preclude sectrical perturbations due to normel electrical power system operation. Note 1 to ITS SR 3.8.1.8, wtuch precludes performence of the Surveillance for the subrect unit offsite circuits when the subgect unit is in MODE 1 or 2, does not proctuoe the normel l operational activity of rnonue#y transferring the unit power supply from the normal circuit to the preferred circuit. Note 1 to ITS SR 3.8.1.8 only precludes crediting the transfer activity with satisfying the Surveillence Requtement, unless the tr:neder is the result of i en unplanned event.

The change from 18 months to 24 months for the Survollence Frequency may be beyond the scope of the NRC Techrwcei !;_mi. ,

Branch review, however, Survedience Frequency extensions to 24 months have, in the post, been processed as part of ITS conversions.

This change is cunentfy being processed by the NRC Project in;;r for Brunswick Unit Pos.1 and 2 and should be included as part of the ITS conversion.

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BRLNtSWICK IRIREE MARKUP 3.8.1 ISSUE # DOC's CTS /STS - DESCRIPTION OF ISSUE DATE .DATE COMMENTS or REF OPENED CLOSED JFD #

6 2 SR The proposed frequency change for SR 3.8.1.9 The 3.8.1.9 from 18 montt4 to 24 months is beyond the change

, scope of the iTS conversion. from 18 months to 24 months is beyond scope.

t BNP RESPONSE The change from 10 months to 24 months for the Surveillance Frequency may be beyond the scope of the NRC Techrecol Specificaten Branch revew, however, Survedlance Frequency extensions to 24 months heve, in the post, been processed as port of ITS conversions. ,

This change is currentty being processed by the NRC Project ?t.ar for Brunswek Unit Nos.1 and 2 and should be included as part of the ITS conversion.

7 15 NUREG JFD 15 contams statements with whch the staff The SR is not necessarily in agreement and w%ch may be licensee 3.8.1.10 difficult to substantiete. It is suggested this JFD should 3.8.1.15 be revised to simply state that the BNP current revise JFD licensing basis does not include this requirement 15.

i and the licansee does not wish to adopt it.

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BNPRrSPONSE In Revision B to the ITS submittal, JFD 15 will be revised to state: "The BNP current licensms basis does not inckA,e the requirements of ISTS SR 3.8.1.10 ar'd SR 3.8.1.15 and BNP will not be adopting these requirements in the BNP ITS.* l 8 !

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t EN N$ NICK MUREE MARKUP 3.8.1 ISSUEF; , DOC #! US/STS - DESCRFTION OF ISSUE DATE -DATE- CX30AENTS or - 'REF OPOED . CLOSED

- JFD # '

, 8. 17 NUREG The staff does not fury understond JFD 17. The The SR discussson appears to soy that aR of the Econsee 3.8.1.11 requirements of NUREG-1433 SRs 3.8.1.11 and should 3.8.1.12 3.1.12 are covered by ITS SR 3.8.L14. The staff revise the door not agree with this. NUREG Sit 3.8.1.11 sutmwttat demonstrates proper system operaten in the to address event of a LOOP, but without a LOCA, and st,ff wwolves ordy safe shutdown loeds. NUREG SR concerns. .

3.8.1.12 demonstrates, among other things, that !

permanently connected loods remem energered and emergency loods are seguenced on to the offsite power system. ITS SR 3.8.1.14 (NUREG .

SR 3.8.1.19) demonstrates soeuencmg of emergency loods on to the EDG. AR three SRs have ways in which they are different from each other and, for whch reason, they should be performed. The Econsee should reconsider the proposed deletion of NUREG SRs 3.8.1.11 and 3.8.1.12.

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BRLNtSWICK IENtEE MARKUP 3.8.1 DNPFESPONSE in Revision B to the ITS sutmttaf, JFD 17 wiB be revised to include the foEowing informetot 3.8.1-8 NUREG-1433 SRs 3.8.1.11 and 3.8.1.12 are not included in the BNP ITS. These tests seperately venfy 4.16 kV emergency bus sequential looding logic associated with an ECCS initiotion and with a loss of offsite power (LOOP). ir, order to support this ju.GT Gv6 the fonowing DG looding sequence is provided:

J Loss of Coolant Accident (LOCA) with LOOP LO AD fri kW) TME (from bus re eneraantion in anconda!

a 480 V MCCs 1200 O NSW pump 224 5 RHR pump 746 10 CS pump 933 15 LOCA without LOOP LOAD Cm kW) TBAE (from LOCA manal in secondal 480 V MCCs 1200 O NSW pump (if not running) 224 5 RHR pump (if not running) 746 10 CS pump (if not runneg) 933 15 LOOP onty (non LOCA1 LOAD rn kW1 TNE (from bus re-enernuation in secondal 480 V MCCs !200 O NSW pump 224 0 10

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B M GilCK IN EG M M UP 3.8.1 BNP RESPONSE NUREG-1433 SR 3.8.1.12 3.8.1-8 (continued) The LOCA concurrent with a LOOP sequence (identified abowel is currently tested per CTS 4.8.1.1.2.d.3 (ITS SR 3.8.1.14). This test requirement ensures proper stripping and sequenong of required loods. The lood sequence releys tested by this survedience test are the !

some reeys that would actuate during a LOCA without a LOOP sequence (identified abowel. Therefore, OPERASILITY of the startmg .

j secuence releyr is verified by one test, in addition, the DG startmg critorie is vonfied by ITS SR 3.8.1.7 (NUREG-1433 SR 3.7.1.7).

i One devotion from the loeding sequence of a LOCA with a LOOP and a LOCA without a LOOP is loods powered from the Emergency l Power Distribution System that are running prior to a LOCA w'thout a LOOP wiH not trip. The RHR pump and NSW pump runtwng prior to i the LOCA without a LOOP is considered the worst case. The BNP Voltage Study assumes the some lood soouence during a LOCA without a LOOP that is assumed during a LOCA with a LOOP (identified abowel. The study indecotes that the startup auxiliary transformers are rated to accept all LOCA loods. This electrical loeding sequence aW with the startup auxihery transformers bounds any electical lood transient that would occur with the RHR pump and NSW purg already running prior to instetson of the event.

If any loed does inadvertently trip, it wiE sequentially lood on the emergency bus at the some interval that it would lood during a LOCA

, with a LOOP since the lood sequencing releys are the same.

Smce the lood sequence releys tested by ITS SR 3.8.1.14 (NUREG-1433 SR 3.8.1.191 are the some releys that would actuote during a LOCA with or without a LOOP, the DG starting criterie is verified by ITS SR 3.8.1.7 (NUREG-1433 SR 3.7.1.7), and the SNP Voltage Study indicates that the BNP startup auxiliary transformers are rated to accept LOCA loeding with offsite power available under worst case conditions, NUREG-1433 SR 3.8.1.12 is not required.

M;8tEG-1433 SR 3.8.1.11 During a LOOP without a LOCA, the DG loeding sequence tidentif~ e d above) varies based on the assocated 4.16 kV emergency bus looding. The automatic loods (i.e.,480 V MCC loeds and the NSW pumps) will be re. energized immedistely upon re-energization of the !

4.16 kV emergency bus. This condition has previously been venfied to be acceptable during a specol test that was performed to verify !

i each DG could accept LOCA loeding from both units. Dunng this test an RHR pump and a CS pump were started simultaneously.

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BitDNSWICK NUREG MAlWQJP 3.8.1 BNP RESPONSE Starting an RHR pump and a C5 purty simultaneousty, which bounds the condition of a dusi unit LOCA, also bounds the concurrent 3.8.1-6 starting of the 480 V MCC loeds and an NSW pung (i.e 1689 kW versus 1424 kW). APhough the DGs are not routinely e_C _ _iW to (contsnued) this afightly harsher test whch simultaneously starts a NSW pump and 480 V MCC loeds, it is consdered reesonable that any DG '

degradation that wouRI prevent the DG from accepting tNs iced (1424 kW) will be deter.ted dunne the LOCA with LOOP test roeusrod by ITS SR 3.8.1.14 (NUREG-1433 SR 3.8.1.19) ad the lood biock sequence test required by ITS SR 3.8.1.13 (NUREG-1433 SR 3.8.1.18).

Since yty DG degradation that would prevent the DG from accepting the proper toed during a LOOP witdeut a LOCA ognet wis be detected during the LOCA with LOOP test recuired by ITS SR 3.8.1.14 (NUREG-1433 SR 3.8.1.19) and the lood block sequence test required by ITS SR 3.8.1.13 (NUREG-1433 SR 3.8.1.18), NUREG-1433 SR 3.8.1.11 is not required to ensure DG OPERABILITY.

Not including NUREG.1433 SRs 3.8.1.11 and 3.8.1.12 in the BNP ITS is also cons stent with the BNP current Econsang basis. The subsequent Survediences remarnbered, where applicable, to reflect this deletiort 12

BRUNSWICK

, MUREG MARKUP 3.8.1 ISSUEF' DOC # CTS /STS DESCRPTION OF ISSUE . DATE DATE COhdasRWTS or REF OPENED CLOSED <

jpg a. i 9 2 SR The frequency change for ITS SR 3..S.1.10 and SR The ,

3.8.1.10 3.8.1.11 from 18 months to 24 months is beyond change 3.8.1.11 the scope of the iTS conversion. from 18 months to 24 months -

g is beyond I scope.

BNP RESPONSE The change from 18 months to 24 months for these Sur.. _r.ce Frequencies may be beyond the scope of the NRC Techrwcal Specification Branch review, however, Surveillance Frequency extensions to 24 months have, in the post. t,m processed as port of ITS .

conversions. These changes are currently being prccessed by the NRC Proioct Ef .--.-r for Brunswick Unit Nos.1 and 2 and should be !

included as part of the ITS conversion.

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4 BRMSUICK IWREG MARKUP 3.8.1 f- -

f

! i ISSUE #' l DOC #1 . CTS /STS DESCRFTION OF ISSUE DATE' 04TE N t

or: REF. OPENED CLOSED !

ED # - i l

'10 19 SR ED 19 appears to indicate a lock of The 3.8.1.11 understanding of NUREG-1433. It is not the liconose -

'etent of NUREG-1433 SR 3.8.1.14 to subpct a should EDG to overtoed conditions that could result in reconader !

l requiring an engine teerdown (e.g., by exceeding a delsong ;

} 2000 hr c uting). The intent of this SR is to the 24 '

, demonstrW the DEMA -x;:t *^p of the individusi hour run DGs by sub; wing them to a 10% overtoed for 2 from the hours. 'k. n-::, this is ordy a portion of the SR. ITS. !

The mein emphasis of the SR is to run the EDG ,

j for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at or near full (contmucus) IGad to demonstrate cepetM1ity for sustained operation.

4 This is not adequetely demonstrated by operates r

, at 3500-38'30kw for 80 trunutes once per i j refueling. The licensee should recortsider deletmg !

j this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run from the Brunsww:k ITS. j 4

- i BNP RESPONSE It is understood that it is not the intent of ISTS SR 3.8.1.14 to subject the DGs to overtoed conditions that could result in requiring an j

engire teerdown. ED 19 was provided to support mentaerung the current licenseg basis, reflected in CTS 4.8.1.1.2.d.5, in ITS i i SR 3.8.1.11. CTS 4.8.1.1.2.d.5 requires, cnce per 18 months, that each DG operate for grooter then or equel to 80 reunutes while i Iceded to greater then or equel to 3500 kW. The upper load limit (i.e.,3850 kW, added in ITS SR 3.8.1.11 is the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating for i the DGs. !

The addition of the ISTS SR 3.8.1.14 to the ITS has been re-examined.' CPR does not believe that addeg the requirement for a penodic [

j 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run of the DGs, during shutdown conditions, is nar====ry to ensure DG OPERABILITY and L itT^.p. Howower, CPR would like l r

to discuss this issue further with the NRC reviewer and requests a mesteg be scheduled.

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, 3.8.1 i .

s i.' ISSUE # J '

.' DOC # CIS/STS DESQWTION OF SSLE ;DATE ~ DATED ***8as'88tS l 2

i erd REFl OPBED Ct.OSED T

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11 20. NUREG The BNP CTS require a LOCAA.OOP SR to be The I SR performed once per refuegng. To restore the plant licensee !

3.8.1.16 to normel status wethout couung a less of power should !

cond.t.on - paragesne weih th. ,w .nd res. newer .

transferring power back to offsite. This is irnpiicst including !

in the recovery from the LOOPA.OCA that., in the ' NUREG- l 1 interest of cienty, is stated separately in the 1433 SR i

, NUREG. The Econoce should reconsider inclushne 3.8.1.16 'I

!- this SR in the BNP ITS. in the ofF l rTS. '

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4 BfrIESPONSE Restorstion of the plant to normal status wethout couems a loss of power condetson, by parassung the DG to the grid and transeemns the ]

4' . 4.16 kV emergency bus loeds back to the offsste circuit, is irnplicit in the recovery from a LOOP and a concunent LOCA. After the j performance of ITS SR 3.8.1.14, the amulated LOOPA.OCA test performed once per 24 months, transfer of the 4.16 kV emergency bus t loods from the associated DG to the W offete circurt is requwed to restore the plant to normal status. This transfer is !

I. =-:-:-- ., f.ei: by paralleling the DG to the grid and transfernne the 4.16 kV emergency bus loods back to the offsite cwcurt. As a result, j the requirements of NUREG-1433 SR 3.8.1.16 are implicetty requwed in the restoration of the plant from the resultant test conditions efter ;

l the successful w., r_; r. of ITS SR 3.8.1.14. Therefore, the explicst requirements of NUREG-1433 SR 3.8.1.16 are not regured to be l c

included in the ITS.

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4 MLESWICK nuars www 3.8.1 ;

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~ ISSUE FI 'DATE.

~ DOC f. . . CTS /STS

. DESCRE'TIDN OF ISSUE -DATE cnoanseasTS or REF -

oreseD ctossD <

.JFD f.

12 21 SR The licenses should provide an expended verson The i 3.8.1.12 of JFD 21 which enore cleerty describes how . licensee I proposed SR 3.8.1.12 is a

logic

test, only. The should i expanded JFD should also explom how a logic test revse the ;

satisfies the NUREG critorie of demonstroeng that suinettel !

the DG retums to running standby from test enode to address i in the presence of an ECCS actuation signet staff j

' concoms.

The .l change in ;

frequency

from is !

i raonths to

- 24 months is beyond !

the scope i of ITS.

I SNP RESPONSE in Revision B to the ITS subfruttal, JFD 21 wie be revised to include the fonounne ;..4..-h !

The current licensmo basis does not currently include the requirements of ISTS SR 3.8.1.17 (ITS SR 3.8.1.12). As port of the ITS conversion ITS SR 3.8.1.12 is added to the BNP ITS. However, CPR Cornpeny desires to mwumme the number of required DG !

starts and has modif%d ISTS SR 3.8.1.17 to not require additional DG starts in order to venfy the OPERAB!LITY of the test mode i overrite feature. As a result, a logic test of the test mode ovemde feature releys will be performed. A review of DG logic dreannes i and existeg DG surveillance precedures was performed and deternuned that there is sufficient overies between the esostme ;

surveillance procedures and the releys assooeted with the test mode ovemde feature such that a logic test of the releys could be .;

performed. This logic test of the releys, in combmetion with the esosting surveillerice procedures, wal demonstrate that an ECCS -

initiotion signal is capable of overridh c the test mode feature and retuming the DGs to ready-to-loed operation.

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BRUNSWICK NUREG MARKUP '

3.8.1 BNPIESPONSE in addition, Brunswick Unit Nos.1 and 2 will be transiterung from an 18 month operating cycle to a 24 rnonth operating cycie and 3.8.1-12 the Frequency of ISTS SR 3.8.1.17 is specified as being conostent with expected fusi cycle lengths. Therefore, the Frequency of the new requirements of ITS SR 3.8.1.12 is specified as 24 months, consistent with the expected fuel cycle lengths after ITS implementaten. ,

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BRUNSWICK NUREG NMIKUP 3.8.1 ISSUE F DCCF CTS /STS DESCRFTION OF ISSUE DATE DATE COMMENTS or -REF- OPENED CLOSED

'JFD F i 13 2 SR The proposed frequerry change from SR 3.8.1.13 The 3.8.1.13 and SR 3.8.1.14 from 18 months to 24 months is frogtency 3.8.1.14 outside the scope of an ITS conversion. change from 18 months to 24 months is outsede the scope of ITS.

BNP RESPONSE The change from 18 months to 24 months fr these Surveillanca Frequences may be beyoM the scope of the NRC Technica!

Specification Branch review, however, Surveillance Frequency extensions to 24 months hr h the past, been processed as part of ITS conversions. These changes are currently being processed by the NRC Project Maneow ~

wick Unit Nos.1 and 2 and should be included as part of the ITS conversion.

18

BRUNSWICK MUREG MMtKI,P

' %. A f IbSUE F ' DOC #. CTS /STS -DES tiPT10ft OF ISSUE : DATE DATE COMMENTS or REF OPENED CLOSED JFD F 1 4 LCO 3.8.2 The NUREG-1433 merkup adds a Note regarding The Action A LCO 3.0.3 not being appliceb;e. Tt s me.te licensee >

indicates this is in accordance with TSTF-38. should TSTF-38 deels with betteries. The staff believes revise the the correct reference is TSTF-36, wtwch has been subnwttel rejected. The submrttal should be changed to address accordingly. staff concems. '

Condition A of NUREG-1433 is enodified by adding >

the term *or rnore* aheed of

required offsite *. I This is acceptabte. However, JFD 4 does not make an adequete case in support of this change.

Specifically, the JFD does not address that this !s the only practul way to address (in the Actens) the fact that more tfun one offsite circuit is required at BNP, and that the only actions that can be taken in the event of offsite circuit enoperability are the same with one or both circuits inoperable. The JFD should be revised accordingly.

BNP RESPONSE in Revision B to the ITS submittal, the annotation of the NUREG-1433 merkup for the Note to ISTS 3.8.2 ACTIONS wiR be revised from '

TSTF-38 to TSTF-36.

The clarification provided by the proposed Note to the ITS 3.8.2 ACTIONS is necessary because defaulting to ITS LCO 3.0.3, during irradiated fuel assembly rnovement in MODE 1, 2, or 3, would require the reactor to be shutdown but would naveguire immodete ,

suspension of movement of irradisted fuel assemblies when required cv,w e ws are inoperable. ITS LCO 3.0.3 as only applicable in '

MODE 1, 2, or 3. Therefore, once the unit has been pieced in MODE 4, in accordance with ITS LCO 3.0.3, ITS LCO 3.0.3 is no longer applicable. The actions of the ' shutdown

Electrical Power System Tochtwcal Specif' e stens (e.g., ITS 3.8.2 ACTIONS), wtuch require i

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BRUNSWICK NUREG MARKUP 3.8.2 SNP RESPONSE suspension of irradiated fuel rnovement, would then be applicable. ;cu.r, the requirements of ITS LCO 3.0.3 would allow up to 3.8.2-1 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 4 and, as a result, up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months would be allowed to suspend wradetod fusi movement. Therefore.

(continued) with the unit in this Condition, the Note, *LCO 3.0.3 is not applicable," ansures that the actens for requiring immedete suspenmon of rnovement of irradisted fuel assemblies are not postponed due to entry into ITS LCO 3.0.3 and that the omit is immedetely pieced in a condition of rrunimum risk, with respect to fuel handling activites during MODE 1,2, or 3. A revsson to generic change TSTF-36 has been proposed to reflect this information.

t in Revision B to the ITS submittal, JFD 4 will be re.ised to include the following information:

NUREG-1433 (ISTS) 3.8.2 Condition A is revised to reflect the BNP Units 1 and 2 electncel design and BNP ITS LCO 3.8.2, wtuch requires more then one (i.e.,two) offsite circuits to be OPERABLE for the shutdown unit. As a result of the requirement for two offsite circuits to be OPERABLE while a unit is shutdown ITS 3.8.2 Condition A is wntten to address the condition of one *or more*

enoperable required offsite circuits. The appropriate actions to take are the same in the event of the inoperability of other one or two required offsite circuits. Therefore, the associated Regoired Actens of ISTS 3.8.2 Condsten A are meintamed for the assocated Required Actions of :TS 3.8.2 Condition A.

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{ BEESWICK .;

MREE IMMF l 3.8.2 i

i 4

ISSUEF DOC # >

? CTS /STS DESCRrTIOSI OF ISSUE 'DATE' : DATE : N

ori .

^

' REF. . OPSIED CLOSED

JFD # , -

2 23 LCO 'JFD 23 addresses the BNP reyuwement for two The

j 3.8.2.b DGs to be OPERA 8LE during shutdown and is Econese

acceptside. However, LCO 3.8.2.h appears to should hows a wording protdent The LCO is werded revise the such that it could be interpreted as meerung two sutwnittel DG capable of supplywig the amme Class IE to address electrical power distribution -t ,_ _ . The sesff j licenses should conenter changing LCO 3.8.2.h to concerns.

read something like "two DGs, each cepende of i - - ,-: ..iii t assocated Class IE AC etc

l BNP RESPONSE The wording of ITS LCO 3.8.2.b reflects the fact that an enste Class IE AC power distribution s itpeystem consists of two 4.16 kV emergency buses, as defined in ITS Bases Table 8 3.8.7-1. Therefore, ITS LCO 3.8.2.b requires two DGs to be OPERABLE and either capable of each supplying one of the two 4.16 kV buses in one Class IE AC power distribution C,.6.. reeuwed by ITS LCO 3.8.8 or cepetde of each supplying one 4.16 kV emergency bus in one of the two Class IE AC power distnbution sul> systems requwed by ITS .1

LCO 3.8.8. ITS LCO 3.8.2.b wM be rewmed in Revision 5 to the ITS sutwtwttei to delete the reference to ordy *one* Ones IE AC power

! distribution subsystem being required.

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SMMSNICK MREE OUMMP 3.8.2 ,

~

DESCRFTION OF ISSUE LDATE _ -DATE~ cnnanssasTS ISSUE # ! DOC # ' CTS /STS

. . er , , REF OPENED CLOSED a y; -

4 SR The staff does ret futy agree with the wording of The 3 licensee 3.8.2.1 proposed SR 3.8.2.1, as fonows. SR 3.8.1.13 is, in the staff's view, Not Applicable h-it should irwolves testing of intervals between tens releys rense the that are only needed to respond to a ECCS sulmuttal irwtaten. An ECCs instetton is not postulated in - to address Modes 8 and 5, so the releys are not regured to staff be OPERA 8LE and the SR is not requwed.. SR concoms.

3.8.1.15, however, is applicable since it addresses oppoeste unit SRs wtuch must be performed in order to monteen system / component OPERABlWTY for the offste unit.

The staff suggests expending SR 3.8.2.1 to include 3 categones of SRs from LCO 3.8.1, and cleerfy :f _.a;M., wtuch SRs fell into each of the categories. The suggested categories include 1-ApplicatWe and must be performed,2-Applicable but not required to be performed, and 3- Not 4-7-liti.

SNP RESPONSE ITS SR 3.8.1.13 involves testing of intervels ostween timing releys that are needed to respond to an ECCS insteten. In MODES 4 and 5, automatic irwtetion of low pressure ECCS is reeuwed by ITE 3.3.5.1,

Emergency Core Cooling (ECCS) Instrumentsten," (i.e., ITS Table 3.3.5.1-1, Functens 1.a,1.c,1.d, 2.a, 2.c, and 2.f) and ITS 3.5.2, *ECCS-Shutdown." Therefore, ITS SR 3.8.1.13 is conodored to be applicable as described in tt.e Note to ITS SR 3.8.2.1. In Revison A to the ITS sulmuttel, ITS SR 3.8.1.15 was deleted from ITS 3.8.1 and ITS SR 3.8.2.1.

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BRUNSWICK NUREG MARKUP 3.8.2 BNP RESPONSE The suggested change to SR 3.8.2.1 is not cormdered to be necessary since the 3 categories dascribed in the issue are already 3.8.2-3 addressed. The category of Survenience Requirements (SRs) which are applicab4e and not required to be performed are addressed in %

(continued) Note to ITS SR 3.8.2.1. The category of SRs whch are applicable are addressed in ITS SR 3.8.2.1. The category of SRs wheh are not applicable are addressed as exceptions to ITS SR 3.8.2.1.

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BRUNSWICK NUREG MAAKUP 3.8.2 ISSUEa DOC # : CTS /STS ' DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENED CLOSED JFD s 4 10 SR The staff does not agree with proposed SR The 3.8.2.2 3.8.2.2. Tnis SR is not necessary and is licensee potentiety confusing. The SR only deels with SR should 3.8.1.1 of the opposete unit. This could be revise the rnisinterpreted as rneeneng that only SR 3.8.1.1 sutwrwttat frorn the opposite unit is required. By rnoldng SR to address 3.8.1.15 applicable, proposed SR 3.8.2.2 and any staff potentW confusion assocated with it will be concerns.

, efirranatec.

l' SNP RESPONSE in Revision A, the ITS subrnittal was revtsed to address the NRC concern.

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88tLNtSWICK EREG MAftKUP 3.8.3 ISSUE # DOC # CTS /STS DESCRFTION OF ISSUE DATE -DATE COtWENTS or - REF Ore:2D CLOSED JFD #

1 25 LCO in JFD 25, the licensee states that the DG starang The j 3.8.3 air systsm also provules ew control air. Is this licensee control air required at at tirnos for the DG to should functW e.g., required to both start the DG and provide a to operate the DG for en extended period of time? response If control air is lost, will the DG fail? Ihe licensee ? tne staff should provide sooroonste details. ouestens.

BNP RESPONSE Control air for the DGs is required at at times for the DGs to functvart in other words, the DGs require control air to both start the DGs sad to operate the DGs for an extended penod of time. tr controt air is lost, the assooeted DG would fail.

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_a BRUNSWICK NUREG MAPUP 3.8.4

" DESCRIPTION OF ISME DATE DATE: : COMMENTS ISSUE *- DOC # . CTS /STS -

or' REF OPENED. ' CLOSED w- ~<

..JFD #

1 32 SR The rnerkup of SR 3.8.4.2 shows the resistance The license 3.8.4.2 valves being rnoved tr the Bases. This is not should '

acceptable. These valves should be retained as revise the act.vtance criteria in the SR. sutmttal to address staff concems.

BNP RESrONSE in Revision A to the ITS submittal, plant specific battery connection resistaw values are provided in ITS SR 3.8.4.2.

2 2 SRs The completion times for SRs 3.8.4.3 and 3.8.4.4 ! The 3.8.4.3 are changed from 12 Ms (NUREG) to 18 licensee 3.8.4.4 rnonths (ITS). Similarly, the completion time in should 3.8.4.5 SRs 3.8.4.5 and 3.8.4.6 are changed from 18 provide a 3.8.4.6 months to 24 months. BNP does not now have a j response 24 month refueling cycle, and the change from , S to staff !

to 24 months is outside the scope of the ITS questions conversion. Is the change from 12 months to 18 and revise months a Tafiection of BNP CLB, or is this another the change that is outside the scope of the ITS sutmttal, conversion. JFD 2 does not address the out of as scope issue. speropriate BNP RESPONSE The Frequency of ITS SRs 3.8.4.3 and 3.8.4.4 are changed from 12 months to 18 rmnths to reflect the current licensing Lasis in CTS 4.8.22 2.c.1 and CTS 4.8.2.3.2.c.2.

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BRUNSWICK NUREG MARKUP 3.8.4 l

I BNP RESPONSE The Frequency of ITS SR 3.8.4.5 and ITS SR 3.8.4.6 are extended from 18 rnonths to 24 months since Brtetswick Unit Nos.1 and 2 will 3.8.4-2 - be transitioning from an 18 month operating cycle to a 24 rnonth operating cycle. The change frorn 18 months to 24 months for these (continued) Surveillance Frequencies may be beyond the scope of the NRC Techrwal Specification Branch review, however, Survedience Frequency extensions to 24 rnonths have, in the past, been processed as part of ITS conversions. These changes are currerby being processed by the NRC Project Manager for Brut.awick Unit Nos.1 and 2 r,N should be included as part of the ITS conversion.

2

BRUNSWICK NUREG MARKUP 3.8,4

' ISSUE #' DOC's CTS /STS' DESCRIPTIG' M ISSUE EDATE- DATE- COMMENTS or. REF -

OPENED 'CtOSED JFD # '

3 32 NUREG NUREG-1433 SR 3.8.4.5 is deleted from the ITS. The SR JFD 32 states that the opton exists to verify licensee 3.8.4.5 battery connection resistance is acceptable, out should there is no requirement to meesure resistance revise the periodically Consequently,in the ITS,if visible subnuttal corrosion is removed, there would never be a to address requirement to verify that connection resistance is staff acceptable. It is the staff's view that CTS SR concerns.

4.8.2.3.2.C.2 is a requirement to check connection resistance, albeit in a de facto sense.

The SR requires verification that bettery connectors are " free

of " corrosion *. There is no mention o? visible corrosion, which means the absence of invisible corrosion must also be verified. This can be done by physically disassembling the connections, or by taking i resistance readings. This CTS requirement is not reflected in the ITS, and an adequete justification has not been provided for the absence. The licensee should provide the appropriate justification or add the requirement to the ITS.

BNP RESPONSE in Revision B to the ITS submittal, JFD 32 will be revised to include the following inforrnetion:

The requirement in CTS 4.8.2.3.2.c.2, to verify that the battery connections are

free of corrosion," is not interpreted as requiring the verification of the absence of "in Asible" corrosion. CTS 4.8.2.3.2.c.2 is currently satisfied by performing an inspection of battery connections for visible corrosion. This inspection is not performed by disassembling the connections. In addition, the performance of connection resistance verifications would not, in all cases, ensure the absence of all corrosion (visible or irwisble) on the battery connections.

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l BRtNISWICK i HUREG MMtKUP 3.8.t i

BNP MESPONSE Once per refueling outage, plant procedures do require the performance of battery connection resistance verifications.'

3.8.4-3 However, these verifications are perforrned as a good rnmentenance practice and not to satisfy a Technscal Specificaten requirement.

(continued) In addition, individual battery connection resistance values do not ewcessarily reiste to battery OPERABILITY. For example, resistance values may be highu for some battery connections and lower for other battery connections and the bettery stir te capable of performing its function. Therefore, the key issue for battery OPERABluTY is overall bettery resistance. Overas bettery resistance l is adequately determined to be acceptable through the successful completion of the bettery sennce or discherge tests required by ITS SR 3.8.4.6 and SR 3.8.4.7. Not including the requirement of ISTS SR 3.8.4.5. which requires w;ht; 6 that bettery connecten

resistances are within limits, in the BNP ITS is also consistent with TSTF-199.

4

BRUNSWICK NUREG MARKUP 3.8.5

-ISSUEF- : DOC * ; CTS /STS .? . DESCRIPTION OF ISSUE DATE- DATE . COMMENTS of REF: OPENED. CLOSED .

JFD # -

1 N/A LCO 3.8.5 The proposed generic change to adde Note The Actions regarding 3.0.3 applicability has been rejected by licensee the staff. should delete the proposed Note. ,

L BNP RESPONSE The clarification provided by the proposed Note to the ITS 3.8.5 ACTIONS is necassary because defaulting to ITS LCO 3.03, during irradiated fuel assembly movement in MODE 1, 2, or 3, would require the reactor to be shutdown but would not require immediate suspension of movement of irradiated fuel assemblies when required components are inoperable. ITS LCO 3.0.3 is only applicable in MODE 1, 2, or 3. Therefore . once the unit has been pieced in MODE 4, in accordance with ITS LCO 3.0.3, ITS LCO 3.0.3 is no longer applicable. The actions of the " shutdown" Electrical Power System Techrucal Specifications (e.g., ITS 3.8.5 ACTIONS), which require '

suspension of irradiated fuel movement, would then be applicable. However, the requirements of ITS LCO 3.0.3 would allow up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 4 and, as a result, up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months would be allowed to suspend irradisted fuel movement. Therefore, with the unit in this Condition, the Note, *LCO 3.0.3 is not applicable," ensures that the actions for requiring immediate suspension of movement of irradiated fuel assemblies are not pos+poned due to entry into ITS LCO 3.0.3 and that the unit is immediately placed in a condition of minimum risk, with respect to fuel handling activities during MODE 1,2, or 3. A revision to generic change TSTF-36 has been proposed to reflect this information.

l

BRINGilCK NUREG MARKUP 3.8.5 ISSUE # DOC #: CTS /STS DESCRFTION OF ISSUE . DATE DATE- COMMENTS or ' REF OPENED CLOSED-

'JFD #

2 10 SR The staff has some concerns regarding the Note in The 3.8.5.2 proposed SR 3.8.5.2. First, the Note could be licensee confusing because it references SR 3.8.5.1, but should the SR proper references SRs in LCO 3.8.4. provide a Second, why would the requirement to perform response SRs be set aside just because irradiated fuel is to the staff being moved? The licensee should consider cuerns revising the submittal to address these concerns. and The staff suggests the licensee consider deleting suggestion the Note in favor of including all the information in .

the SR; e.g., "For required Unit (1)(2) DC electrical power distribution subsystems the SRs of LCO 3.8.4 or LCO 3.8.5 are applicable."

BNP RESPONSE in Revision A, the ITS submittal was revised to address the NRC concern.

2

l 1

l -

BRUNSWICK MUREG MARKUP 3.8.8 ISSUE # - ' DOC #

CTS /STS - DESCRIPTION OF ISSUE DATE- P\TE- COMMENTS '

or . REF ' OPENED CLuSED *

.JFD # " s-1 N/A LCO The ITS LCO does not address the requirement for The 3.8.8 opposite unit power sources. (See Comamnt No. licensee 1 for LCO 3.8.7 in comments on NUREG merkup.) should address the staff concerns ,

by revising the submrttal or providing as l discussion for why a change is not necessary.

BNP RESPONSE ITS LCO 3.8.8 does not explic!tly address requirements for opposite unit power distribution subsystems since the requirements con viity based on the specific components that are being credited with satisfying the requirements for other " shutdown

Technical Specifica':ms ,

(i.e., equipment required to be OPERABLE). As a result, ITS LCO 3.8.8 wording is specified as "The necessary portions of ifw AC and DC electrical power distribution sut, systems shall be OPERABLE to support equipment required to be OPERABLE / This presentation requires portions of the subject unit and opposite unit power distribution subsystem to be OPERABLE as required to support the OPERABILITY of equipment required to be OPERABLE by other " shutdown

Technical Specifications. Therefore, no change is considered to be necessary.

a 4

1

. . .4 BRINtSWICK IRNtEG MARKUP 3.8.7

~

n. .. .

1 DATEE COtedENTS

-DATEi

-ISSUE #.1 - D O C #l--

CTS /STS i . L DESCRFTION OF ISSUE -

' .~" OPENED -l CLOSED or LREFc r pg ,

N/A LCO 8NP ITS LCOs 3.8.1-3.8.6 include requirements The licensee 1

3.8.7 for opposite unit AC and DC electrical power should subsystems. This LCO, however, does not reflect address any of those other LCO requirements. Onk the stoff Division I and Division 18 AC and DC electrical concerns by power distribution subsystems are required. revisme :he Absent any indications to the contrary, one would subettel or have to assume the LCO requirements apply only prowulene to the assocated unit. This conflicts with the justificaten remainder of the ITS. forr.ot changing A smier comment appleos to the Corwhtions and the Required Actens. There is nothing to indicate submrttal.

opposite unit power sources are required or how they should be treeted.

BNP RESPONSE The Electrical Power Distribution System addressed in ITS 3.8.7 is defined in ITS Bases Table B 3.8.7-1. This Table is based on the requirements of CTS 3.8.2.1 and CTS 3.8.2.4.1 and does include buses assocated with the opposite unit. ITS 8 eses Table 8 3.8.7-1.'

includes buses that are considereo to be common to both units (i.e., not specifically identified with a particular unit) and buses thet have specific unit designators. Therefore, to avoid confusion associated with bus nomencloture, ITS LCO 3.8.7 does not refer to unit specific electrical power distribution subsystems. Instood, ITS Bases Table 3 3.8.7-1 is used to defene which common buses and which unit '

specific buses constitute the Electrical Power Distribution System addressed by ITS 3.8.7.

1

T BRUNSWICK NUREG MARKUP 3.8.6 8

-ISSUEF DOC # . ! - CTS /STS . DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENU) CLOSED

~JFD # -

1 28 LCO 3.8.6 The LCO requires batteries in both units to be The 42 within lirnits. However, the LCO is not specif'c as licensee to which lirnits apply. Consequently, it could be should interpreted that Unit 2 batteries must rneet the consider limits of Unit 1 Table 3.8.6-1. In the practical revising sense this is not a problem since Table 3.8.6-1 the LCO.

will be the same for both units. However, to avoid any potential confusion, the LCO should be revisad to indicate that the opposite unit's batteries must be within the limits established for that unit.

BNP RESPONSE ITS LCO 3.8.6 states

Battery cell parameters for the Unit 1 Division I and 11 batteries and the Unit 2 Division I and 11 tatteries shall be within the Limits of Table 3.8.6-1. The intent of the requirement is that both units' batteries be within the limits of the subject unit's Technical Specification Table 3.8.6-1 (e.g., the Unit 2 batteries must meet the limits of Unit 1 Technical Specification Tabte 3.8.6-11. As peinted out in the NRC Description of issue, the limits and requirements of ITS Table 3.8.6-1 are the same for both units. Therefore, it is not expected that potential confusion, regarding the applicability of Tsbie 3.8.6-1 limits or requirements for the Unit 1 and Unit I batteries, will be caused by the presentation of ITS LCO 3.8.6.

2 N/A SR SR 3.8.6.3 may require changes to reflect -

0.8.6.3 responses to staff concerns regarding temperature of connected versus representativa cells identified in comments on the CTS markup.

BNP RESPONSE in Revision A to the ITS subrrittal, DOC L1 for ITS ').8.6 is revised to provide additional justification to support the change to CTS 4.8.2.3.2.b.3 reflected in ITS SR 3.8.6.3.

I

~

. t 1

BRtMSWICK NUREG MARKUP 3.8.8 ISSUE # '. DOC # ; CTS /STS : - DESCRIPTION OF ISSUE ' ;DATE . DATE: COMMENTS

. or . REF -

OPENED CLOSED

-JFD# .

2 N/A LCO The generic change to add a Note to the Actions 3.8.8 regarding 3.0.3 has not been accepted by the staff.

BNP RESPONSE The clarification provided by the proposed Nete to tt e ITS 3.8.8 ACTIONS is necessary because defaulting to ITS LCO 3.0.3, during irradiated fuel assembly rnovement in MODE 1,2, or 3, would require the reactor to be shutdown but would not require imrnediate suspension of movernent of irradiated fuel assemblies when required components are inoperable. ITS LCO 3.0.3 is only applicable in MODE 1, 2, or 3. Therefore, once the unit has been placed in MODE 4, in accordance with ITS LCO 3.0.3, I1S LCO 3.0.3 is no longer applicable. The actions of the " shutdown

Electrical Power System Techrucal Specifications (e.g., ITS 3.8.8 ACTIONS), which require suspension of irradiated fuel movement, would then be applicable. However, the require.nonts of ITS LCO 3.0.3 would allow up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to place the unit in MODE 4 and, as a result, up to 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months would be allowed to suspend irradiated fuel movement. Therefore, with the unit in this Condition, the Note, "LCO 3.0.3 is not applicable," ensures that the actions for requiring immediate suspension of movement of irradiated fuel assemblies are not postponed due to entry into ITS LCO 3.0.3 and that the unit is immediately pieced in a condition of minimum risk, with respect to fuel handling activities during MODE 1,2, or 3. A revisoon to generic change TSTF-36 has been proposed to reflect this information.

2

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BSEP-97-0487, Forwards Response to Request for Addl Info Re Conversion to Improved Tech Specs (NURG-1433),per NRC

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BSEP-97-0487, Forwards Response to Request for Addl Info Re Conversion to Improved Tech Specs (NURG-1433),per NRC

Text

Enclosure:

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