BSEP 07-0048, Submittal of Technical Specification Bases Revisions

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Submittal of Technical Specification Bases Revisions
ML071570449
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 05/28/2007
From: Ivey R
Progress Energy Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 07-0048
Download: ML071570449 (51)
v • d • e


Text

Progress Energy

-MAY 2 8 2007 SERIAL: BSEP 07-0048 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Submittal of Technical Specification Bases Revisions Ladies and Gentlemen:

In accordance with Technical Specification (TS) 5.5.10 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., is submitting Revisions 48, 49, and 50 to the BSEP, Unit 1 TS Bases and Revisions 46, 47, and 48 to the BSEP, Unit 2 TS Bases.

No regulatory commitments are contained in this letter. Please refer any questions regarding this submittal to Ms. Annette H. Pope, Supervisor - Licensing/Regulatory Programs, at (910) 457-2184.

Sincerely, Randy C. Ivey Manager - Support Services Brunswick Steam Electric Plant WRM/wrm

Enclosures:

1. Summary of Revisions to Technical Specification Bases
2. Page Replacement Instructions
3. Unit 1 Technical Specification Bases Replacement Pages
4. Unit 2 Technical Specification Bases Replacement Pages Progress Energy Carolinas, Inc.

Brunswick Nuclear Plant PO Box 10429 Southport, NC 28461

Document Control Desk BSEP 07-0048 / Page 2 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mr. Stewart N. Bailey (Mail Stop OWFN 8B1) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 07-0048 Enclosure I Page 1 of 2 Summary of Revisions to Technical Specification (TS) Bases Affected RevisionI Unit Date Implemented Title/Description 48 1 March 12, 2007

Title:

Diesel Generator Load Test 46 2

Description:

Revision 48 for Unit 1 and 46 for Unit 2 incorporated changes to Section 318.1 of the TS Bases to clarify load testing requirements for the emergency diesel generators.

49 1 March 16, 2007

Title:

Turbine Bypass System Operability

Description:

Revision 49 for Unit 1 incorporated a change to Section 3.7.6 of the TS Bases regarding the number of main turbine bypass valves required for the main turbine bypass system to be OPERABLE. The change makes the requirements for main turbine bypass valves consistent with the minimum number of turbine bypass valves credited in the Core Operating Limits Report and Supplemental Reload Licensing Report.

47 2 April 2, 2007

Title:

Minimum Critical Power Ratio (MCPR)

Limits Used for Rod Block Monitor (RBM)

Operability

Description:

Revision 47 for Unit 2 deleted values for the cycle-specific RBM operability MCPR limits in Section 3.3.2.1 of the TS Bases and instead refers the reader to the values contained in the Core Operating Limits Report.

Revision 47 for Unit 2 incorporated change package TSB-2007-03.

Revision 48 for Unit 1 and Revision 46 for Unit 2 incorporated change package TSB-2006-06.

Revision 49 for Unit 1 incorporated change package TSB-2007-01.

Revision 50 for Unit 1 and Revision 48 for Unit 2 incorporated change package TSC-2006-01.

BSEP 07-0048 Enclosure I Page 2 of 2 Summary of Revisions to Technical Specification (TS) Bases Affected Revision1 Unit Date Implemented Title/Description 50 1 May 15, 2007

Title:

Addition of Limiting condition for 48 2 Operation 3.0.8 on Inoperable Snubbers

Description:

Revision 50 for Unit 1 and 48 for Unit 2 incorporated changes to Section 3.0, Limiting Condition for Operation (Applicability), of the TS Bases associated with Amendment 241 for Unit 1 and Amendment 269 for Unit 2, issued February 15, 2007. These amendments revised Technical Specification requirements for inoperable snubbers by adding a new Limiting Condition for Operation 3.0.8.

BSEP 07-0048 Enclosure 2 Page 1 of 2 Page Replacement Instructions - Unit I Remove Insert Unit I - Bases Book 1 Exterior Cover Page This cover page, which contains a photograph of the plant, is being eliminated.

Title Page, Revision 47 Title Page, Revision 50 LOEP-1, Revision 47 LOEP-1, Revision 50 Table of Contents, Page i, Revision 42 Table of Contents, Page i, Revision 50 B 3.0-1,Revision 31 B 3.0-1,Revision 50 B 3.0-10, Revision 41 B 3.0-10, Revision 50 B 3.0-11, Revision 41 B 3.0-11, Revision 50 B 3.0-12, Revision 41 B 3.0-12, Revision 50 B 3.0-13, Revision 41 B 3.0-13, Revision 50 B 3.0-14, Revision 41 B 3.0-14, Revision 50 B 3.0-15, Revision 41 B 3.0-15, Revision 50 B 3.0-16, Revision 41 B 3.0-16, Revision 50 B 3.0-17, Revision 41 B 3.0-17, Revision 50 B 3.0-18, Revision 50 Unit 1 - Bases Book 2 LOEP-1, Revision 47 LOEP-1, Revision 49 LOEP-3, Revision 45 LOEP-3, Revision 49 B 3.7.6-2, Revision 31 B 3.7.6-2, Revision 49 B 3.8.1-28, Revision 38 B 3.8.1-28, Revision 48 B 3.8.1-29, Revision 31 B 3.8.1-29, Revision 48

BSEP 07-0048 Enclosure 2 Page 2 of 2 Page Replacement Instructions - Unit 2 Remove Insert Unit 2 -Bases Book ..

Exterior Cover Page This cover page, which contains a photograph of the plant, is being eliminated.

Title Page, Revision 45 Title Page, Revision 48 LOEP-1, Revision 45 LOEP-1, Revision 48 LOEP-2, Revision 37 LOEP-2, Revision 47 Table of Contents, Page i, Revision 40 Table of Contents, Page i, Revision 48 B 3.0-1,Revision 30 B 3.0-1,Revision 48 B 3.0-10, Revision 39 B 3.0-10, Revision 48 B 3.0-11, Revision 39 B 3.0-11, Revision 48 B 3.0-12, Revision 39 B 3.0-12, Revision 48 B 3.0-13, Revision 39 B 3.0-13, Revision 48 B 3.0-14, Revision 39 B 3.0-14, Revision 48 B 3.0-15, Revision 39 B 3.0-15, Revision 48 B 3.0-16, Revision 39 B 3.0-16, Revision 48 B 3.0-17, Revision 39 B 3.0-17, Revision 48 B 3.0-18, Revision 48 B 3.3.2.1-4, Revision 32 B 3.3.2.1-4, Revision 47 B 3.3.2.1-5, Revision 30 B 3.3.2.1-5, Revision 47 Unit 2 - BasesRBook -2 LOEP-1, Revision 45 LOEP-1, Revision 46 LOEP-3, Revision 43 LOEP-3, Revision 46 B 3.8.1-28, Revision 35 B 3.8.1-28, Revision 46 B 3.8.1-29, Revision 30 B 3.8.1-29, Revision 46

BSEP 07-0048 Enclosure 3 Unit 1 Technical Specification Bases Replacement Pages

Unit 1 - Bases Book 1 Replacement Pages

Technical Specification Bases Brunswick Steam Electric Plant, Unit No. I Renewed Facility Operating License DPR-71 Revision 50

& Progress Energy

LIST OF EFFECTIVE PAGES - BASES Page No. Revision No. Page No. Revision No.

Title Page 50 B 3.1.1-5 31 I B 3.1.1-6 31 List of Effective Pages - Book 1 B 3.1.2-1 31 B 3.1.2-2 31 LOEP-1 50 B 3.1.2-3 31 LOEP-2 36 B 3.1.2-4 31 LOEP-3 44 B 3.1.2-5 31 LOEP-4 45 B 3.1.3-1 31 B 3.1.3-2 31 i 50 B 3.1.3-3 31 ii 31 B 3.1.3-4 31 B 3.1.3-5 31 B 2.1.1-1 31 B 3.1.3-6 31 B 2.1.1-2 31 B 3.1.3-7 31 B 2.1.1-3 31 B 3.1.3-8 31 B 2.1.1-4 31 B 3.1.3-9 31 B 2.1.1-5 31 B 3.1.4-1 31 B 2.1.2-1 31 B 3.1.4-2 31 B 2.1.2-2 31 B 3.1.4-3 31 B 2.1.2-3 31 B 3.1.4-4 31 B 3.1.4-5 42 B 3.0-1 50 B 3.1.4-6 31 B 3.0-2 31 B 3.1.4-7 31 B 3.0-3 31 B 3.1.5-1 31 B 3.0-4 31 B 3.1.5-2 31 B 3.0-5 41 B 3.1.5-3 31 B 3.0-6 41 B 3.1.5-4 31 B 3.0-7 41 B 3.1.5-5 31 B 3.0-8 41 B 3.1.6-1 31 B 3.0-9 41 B 3.1.6-2 31 B 3.0-10 50 B 3.1.6-3 31 B 3.0-11 50 B 3.1.6-4 31 B 3.0-12 50 B 3.1.6-5 31 B 3.0-13 50 B 3.1.7-1 34 B 3.0-14 50 B 3.1.7-2 31 B 3.0-15 50 B 3.1.7-3 31 B 3.0-16 50 B 3.1.7-4 31 B 3.0-17 50 B 3.1.7-5 31 B 3.0-18 50 B 3.1.7-6 34 B 3.1.8-1 31 B 3.1.1-1 31 B 3.1.8-2 37 B 3.1.1-2 31 B 3.1.8-3 37 B 3.1.1-3 31 B 3.1.8-4 31 B 3.1.1-4 31 B 3.1.8-5 31 (continued)

Brunswick Unit 1 LOEP-1 Revision 50 1

TABLE OF CONTENTS B 2.0 SA FETY LIM ITS (SLs) ............................................................................... B 2.1.1-1 B 2.1.1 R eactor C ore S Ls ................................................................................. B 2.1.1-1 B 2.1.2 Reactor Coolant System (RCS) Pressure SL ....................................... B 2.1.2-1 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ........... B 3.0-1 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .......................... B 3.0-12 B 3.1 REACTIVITY CONTROL SYSTEMS .......................................................... B 3.1.1-1 B 3.1.1 SHUTDOWN MARGIN (SDM) .............................................................. B 3.1.1-1 B 3.1.2 Reactivity A nom alies ............................................................................ B 3.1.2-1 B 3.1.3 Control Rod OPERABILITY .................................................................. B 3.1.3-1 B 3.1.4 Control Rod Scram Times ............................... B 3.1.4-1 B 3.1.5 Control Rod Scram Accumulators ........................................................ B 3.1.5-1 B 3.1.6 Rod Pattern Control ............................................................................. B 3.1.6-1 B 3.1.7 Standby Liquid Control (SLC) System .................................................. B 3.1.7-1 B 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves ...................... B 3.1.8-1 B 3.2 POWER DISTRIBUTION LIMITS ............................................................... B 3.2.1-1 B 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (A P LH G R ) ...................................................................................... B 3.2.1-1 B 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) .................................... B 3.2.2-1 B 3.3 INSTRUMENTATION ................................................................................ B 3.3.1.1-1 B 3.3.1.1 Reactor Protection System (RPS) Instrumentation ............................... B 3.3.1.1-1 B 3.3.1.2 Source Range Monitor (SRM) Instrumentation ..................................... B 3.3.1.2-1 B 3.3.2.1 Control Rod Block Instrumentation ....................................................... B 3.3.2.1-1 B 3.3.2.2 Feedwater and Main Turbine High Water Level Trip Instrum entation ............................................................................... B 3.3.2.2-1 B 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation ................................. B 3.3.3.1-1 B 3.3.3.2 Remote Shutdown Monitoring Instrumentation ..................................... B 3.3.3.2-1 B 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation ......................................................... B 3.3.4.1-1 B 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation .................. B 3.3.5.1-1 B 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation ........... B 3.3.5.2-1 B 3.3.6.1 Primary Containment Isolation Instrumentation .................................... B 3.3.6.1-1 B 3.3.6.2 Secondary Containment Isolation Instrumentation ............................... B 3.3.6.2-1 B 3.3.7.1 Control Room Emergency Ventilation (CREV) System Instrum entation ............................................................................... B 3.3.7.1-1 (continued)

Brunswick Unit 1 i Revision No. 50 I

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements I applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the (continued)

Brunswick Unit 1 B 3.0-1 Revision No. 50 I

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.

Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.

LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.

(continued)

Brunswick Unit 1 B 3.0-10 Revision No. 50 I

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.8 If the allowed time expires and the snubber(s) are unable to perform their (continued) associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system.

LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

Brunswick Unit 1 B 3.0-11 Revision No. 50 I

SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs; or
b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a Special Operations LCO are only applicable when the Special Operations LCO is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given MODE or other specified condition.

(continued)

Brunswick Unit 1 B 3.0-12 Revision No. 50 I

SR Applicability B 3.0 BASES SR 3.0.1 Surveillances, including Surveillances invoked by Required Actions, (continued) do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > 800 psi. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 800 psi to perform other necessary testing.
b. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.

(continued)

Brunswick Unit 1 B 3.0-13 Revision No. 50 I

SR Applicability B 3.0 BASES SR 3.0.2 SR 3.0.2 permits a 25% extension of the interval specified in the (continued) Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of "in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." The requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

(continued)

Brunswick Unit 1 B 3.0-14 Revision No. 50 I

SR Applicability B 3.0 BASES (continued)

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered not to have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 also provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the (continued)

Brunswick Unit 1 B 3.0-15 Revision No. 50 I

SR Applicability B 3.0 BASES SR 3.0.3 limit of the specified Frequency is provided to perform the missed (continued) Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

This Regulatory Guide addresses consideration of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

(continued)

Brunswick Unit 1 B 3.0-16 Revision No. 50 I

SR Applicability B 3.0 BASES (continued)

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to a Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change.

When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

(continued)

Brunswick Unit 1 B 3.0-17 Revision No. 50 I

SR Applicability B 3.0 BASES SR 3.0.4 The precise requirements for performance of SRs are specified such that (continued) exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met.

Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

Brunswick Unit 1 B 3.0-18 Revision No. 50 I

Unit 1 - Bases Book 2 Replacement Pages

LIST OF EFFECTIVE PAGES - BASES Pacie No. Revision No. Page No. Revision No.

List of Effective Pages - Book 2 B 3.4.7-5 41 B 3.4.8-1 31 LOEP-1 49 B 3.4.8-2 31 I LOEP-2 47 B 3.4.8-3 31 LOEP-3 49 B 3.4.8-4 31 LOEP-4 31 B 3.4.8-5 31 LOEP-5 31 B 3.4.9-1 31 B 3.4.9-2 38 ii 31 B 3.4.9-3 38 31 B 3.4.9-4 31 B 3.4.9-5 38 B 3.4.1-1 31 B 3.4.9-6 38 B 3.4.1-2 31 B 3.4.9-7 31 B 3.4.1-3 31 B 3.4.9-8 31 B 3.4.1-4 31 B 3.4.9-9 38 B 3.4.1-5 31 B 3.4.10-1 31 B 3.4.1-6 31 B 3.4.10-2 31 B 3.4.2-1 31 B 3.4.2-2 31 B 3.5.1-1 31 B 3.4.2-3 31 B 3.5.1-2 31 B 3.4.2-4 31 B 3.5.1-3 31 B 3.4.3-1 31 B 3.5.1-4 36 B 3.4.3-2 31 B 3.5.1-5 36 B 3.4.3-3 31 B 3.5.1-6 41 B 3.4.3-4 31 B 3.5.1-7 31 B 3.4.4-1 31 B 3.5.1-8 31 B 3.4.4-2 31 B 3.5.1-9 31 B 3.4.4-3 31 B 3.5.1-10 31 B 3.4.4-4 31 B 3.5.1-11 31 B 3.4.4-5 31 B 3.5.1-12 31 B 3.4.5-1 31 B 3.5.1-13 31 B 3.4.5-2 31 B 3.5.1-14 44 B 3.4.5-3 43 B 3.5.1-15 44 B 3.4.5-4 41 B 3.5.1-16 31 B 3.4.6-1 41 B 3.5.1-17 31 B 3.4.6-2 41 B 3.5.2-1 31 B 3.4.6-3 41 B 3.5.2-2 31 B 3.4.7-1 31 B 3.5.2-3 31 B 3.4.7-2 31 B 3.5.2-4 31 B 3.4.7-3 41 B 3.5.2-5 31 B 3.4.7-4 41 B 3.5.2-6 31 B 3.5.3-1 31 B 3.5.3-2 41 (continued)

Brunswick Unit 1 LOEP-1 Revision 49 1

LIST OF EFFECTIVE PAGES - BASES (continued)

Page No. Revision No. Paqe No. Revision No.

B 3.6.4.3-4 31 B 3.7.7-1 31 B 3.6.4.3-5 31 B 3.7.7-2 31 B 3.6.4.3-6 31 B 3.7.7-3 31 B 3.7.1-1 31 B 3.8.1-1 31 B 3.7.1-2 31 B 3.8.1-2 31 B 3.7.1-3 41 B 3.8.1-3 36 B 3.7.1-4 41 B 3.8.1-4 41 B 3.7.1-5 41 B 3.8.1-5 41 B 3.7.2-1 31 B 3.8.1-6 31 B 3.7.2-2 31 B 3.8.1-7 31 B 3.7.2-3 31 B 3.8.1-8 31 B 3.7.2-4 31 B 3.8.1-9 31 B 3.7.2-5 31 B 3.8.1-10 31 B 3.7.2-6 31 B 3.8.1-11 31 B 3.7.2-7 31 B 3.8.1-12 31 B 3.7.2-8 31 B 3.8.1-13 31 B 3.7.2-9 31 B 3.8.1-14 31 B 3.7.2-10 31 B 3.8.1-15 31 B 3.7.2-11 31 B 3.8.1-16 31 B 3.7.2-12 31 B 3.8.1-17 31 B 3.7.2-13 31 B 3.8.1-18 31 B 3.7.2-14 31 B 3.8.1-19 31 B 3.7.3-1 31 B 3.8.1-20 31 B 3.7.3-2 45 B 3.8.1-21 31 B 3.7.3-3 31 B 3.8.1-22 31 B 3.7.3-4 31 B 3.8.1-23 31 B 3.7.3-5 31 B 3.8.1-24 31 B 3.7.3-6 31 B 3.8.1-25 31 B 3.7.3-7 36 B 3.8.1-26 31 B 3.7.4-1 31 B 3.8.1-27 31 B 3.7.4-2 31 B 3.8.1-28 48 B 3.7.4-3 31 B 3.8.1-29 48 B 3.7.4-4 31 B 3.8.1-30 31 B 3.7.4-5 31 B 3.8.1-31 31 B 3.7.5-1 31 B 3.8.1-32 31 B 3.7.5-2 31 B 3.8.1-33 36 B 3.7.5-3 31 B 3.8.1-34 31 B 3.7.6-1 31 B 3.8.2-1 31 B 3.7.6-2 49 B 3.8.2-2 31 B 3.7.6-3 31 B 3.8.2-3 31 B 3.7.6-4 31 B 3.8.2-4 31 (contnued B 3.8.2-5 31 (continued)

Brunswick Unit 1 LOEP-3 Revision 49 1

Main Turbine Bypass System B 3.7.6 BASES (continued)

LCO The Main Turbine Bypass System is required to be OPERABLE to limit peak pressure in the main steam lines and maintain reactor pressure within acceptable limits during events that cause rapid pressurization, so that the Safety Limit MCPR is not exceeded. With the Main Turbine Bypass System inoperable, modifications to the APLHGR limits (LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)") and the MCPR limits (LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)") may be applied to allow this LCO to be met.

The APLHGR and MCPR limits for the inoperable Main Turbine Bypass System are specified in the COLR. An OPERABLE Main Turbine Bypass System requires the minimum number of bypass valves, specified in the COLR, to open in response to increasing main steam line pressure. This response is within the assumptions of the applicable analysis (Refs. 2, 3, and 4).

APPLICABILITY The Main Turbine Bypass System is required to be OPERABLE at

> 23% RTP to ensure that the fuel cladding integrity Safety Limit and the cladding 1% plastic strain limit are not violated during the turbine generator load rejection transient. As discussed in the Bases for LCO 3.2.1 and LCO 3.2.2, sufficient margin to these limits exists at

< 23% RTP. Therefore, these requirements are only necessary when operating at or above this power level.

ACTIONS A.1 If the Main Turbine Bypass System is inoperable (two or more bypass valves as specified in the COLR inoperable), and the APLHGR and MCPR limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are not applied, the assumptions of the design basis transient analysis may not be met. Under such circumstances, prompt action should be taken to restore the Main Turbine Bypass System to OPERABLE status or adjust the APLHGR and MCPR limits accordingly.

The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is reasonable, based on the time to complete the Required Action and the low probability of an event occurring during this period requiring the Main Turbine Bypass System.

(continued)

Brunswick Unit 1 B 3.7.6-2 Revision No. 49 1

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g.,

high jacket water temperature) are bypassed on an ECCS initiation test signal and critical protective functions (engine overspeed, generator differential overcurrent, low lubricating oil pressure, reverse power, loss of field, and phase overcurrent-voltage restrained) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.11 Brunswick Nuclear Plant performs a 60 minute run greater than or equal to the continuous rating (3500 kW) and less than or equal to the 2000-hour rating (3850 kW) to demonstrate diesel generator operation and to detect potential degradations and incipient failures. Post-accident DG loading is allowed up to the 2000-hour rating; however, it is impractical to require testing at this load but not to exceed it. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in the Bases for SR 3.8.1.2, and for gradual loading, discussed in the Bases for SR 3.8.1.3, are applicable to this SR.

(continued)

Brunswick Unit 1 B 3.8.1-28 Revision No. 48 I

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor < 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience.

The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This Surveillance has been modified by two Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. To minimize testing of the DGs, Note 2 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.13, demonstration of the test mode override feature ensures that the DG availability under accident conditions is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation (continued)

Brunswick Unit 1 B 3.8.1-29 Revision No. 48 I

BSEP 07-0048 Enclosure 4 Unit 2 Technical Specification Bases Replacement Pages

Unit 2 - Bases Book 1 Replacement Pages

Technical Specification Bases Brunswick Steam Electric Plant, Unit No. 2 Renewed Facility Operating License DPR-62 Revision 48 SProgress Energy

LIST OF EFFECTIVE PAGES - BASES Page No. Revision No. Page No. Revision No.

Title Page 48 B 3.1.1-5 30 B 3.1.1-6 30 List of Effective Pages - Book 1 B 3.1.2-1 30 B 3.1.2-2 30 LOEP-1 48 B 3.1.2-3 30 LOEP-2 47 B 3.1.2-4 30 LOEP-3 42 B 3.1.2-5 30 LOEP-4 43 B 3.1.3-1 30 B 3.1.3-2 30 i 48 B 3.1.3-3 30 ii 30 B 3.1.3-4 30 B 3.1.3-5 30 B 2.1.1-1 30 B 3.1.3-6 30 B 2.1.1-2 30 B 3.1.3-7 30 B 2.1.1-3 30 B 3.1.3-8 30 B 2.1.1-4 30 B 3.1.3-9 30 B 2.1.1-5 30 B 3.1.4-1 30 B 2.1.2-1 30 B 3.1.4-2 30 B 2.1.2-2 30 B 3.1.4-3 30 B 2.1.2-3 30 B 3.1.4-4 30 B 3.1.4-5 40 B 3.0-1 48 B 3.1.4-6 30 B 3.0-2 30 B 3.1.4-7 30.

B 3.0-3 30 B 3.1.5-1 30 B 3.0-4 30 B 3.1.5-2 30 B 3.0-5 39 B 3.1.5-3 30 B 3.0-6 39 B 3.1.5-4 30 B 3.0-7 39 B 3.1.5-5 30 B 3.0-8 39 B 3.1.6-1 30 B 3.0-9 39 B 3.1.6-2 30 B 3.0-10 48 B 3.1.6-3 30 B 3.0-11 48 B 3.1.6-4 30 B 3.0-12 48 B 3.1.6-5 30 B 3.0-13 48 B 3.1.7-1 30 B 3.0-14 48 B 3.1.7-2 30 B 3.0-15 48 B 3.1.7-3 30 B 3.0-16 48 B 3.1.7-4 30 B 3.0-17 48 B 3.1.7-5 30 B 3.0-18 48 B 3.1.7-6 30 B 3.1.8-1 30 B 3.1.1-1 30 B 3.1.8-2 34 B 3.1.1-2 30 B 3.1.8-3 34 B 3.1.1-3 30 B 3.1.8-4 30 B 3.1.1-4 30 B 3.1.8-5 30 (continued)

Brunswick Unit 2 LOEP-1 Revision 48 1

LIST OF EFFECTIVE PAGES - BASES (continued)

Page No. Revision No. Page No. Revision No.

B 3.2.1-1 30 B 3.3.1.1-34 30 B 3.2.1-2 30 B 3.3.1.1-35 30 B 3.2.1-3 30 B 3.3.1.1-36 30 B 3.2.1-4 30 B 3.3.1.1-37 30 B 3.2.1-5 30 B 3.3.1.1-38 30 B 3.2.2-1 37 B 3.3.1.1-39 30 B 3.2.2-2 37 B 3.3.1.1-40 30 B 3.2.2-3 30 B 3.3.1.1-41 33 B 3.2.2-4 37 B 3.3.1.1-42 33 B 3.2.2-5 37 B 3.3.1.1-43 30 B 3.3.1.2-1 30 B 3.3.1.1-1 30 B 3.3.1.2-2 30 B 3.3.1.1-2 30 B 3.3.1.2-3 30 B 3.3.1.1-3 30 B 3.3.1.2-4 30 B 3.3.1.1-4 30 B 3.3.1.2-5 30 B 3.3.1.1-5 30 B 3.3.1.2-6 30 B 3.3.1.1-6 30 B 3.3.1.2-7 30 B 3.3.1.1-7 30 B 3.3.1.2-8 30 B 3.3.1.1-8 30 B 3.3.1.2-9 30 B 3.3.1.1-9 30 B 3.3.2.1-1 30 B 3.3.1.1-10 30 B 3.3.2.1-2 30 B 3.3.1.1-11 30 B 3.3.2.1-3 30 B

B B

3.3.1.1-12 3.3.1.1-13 3.3.1.1-14 30 30 30 B 3.3.2.1-4 B 3.3.2.1-5 B 3.3.2.1-6 47 47 30 I

B 3.3.1.1-15 30 B 3.3.2.1-7 30 B 3.3.1.1-16 30 B 3.3.2.1-8 30 B 3.3.1.1-17 30 B 3.3.2.1-9 30 B 3.3.1.1-18 30 B 3.3.2.1-10 30 B 3.3.1.1-19 30 B 3.3.2.1-11 30 B 3.3.1.1-20 30 B 3.3.2.1-12 30 B 3.3.1.1-21 30 B 3.3.2.1-13 30 B 3.3.1.1-22 30 B 3.3.2.1-14 30 B 3.3.1.1-23 30 B 3.3.2.1-15 30 B 3.3.1.1-24 30 B 3.3.2.2-1 30 B 3.3.1.1-25 30 B 3.3.2.2-2 30 B 3.3.1.1-26 30 B 3.3.2.2-3 30 B 3.3.1.1-27 30 B 3.3.2.2-4 30 B 3.3.1.1-28 37 B 3.3.2.2-5 30 B 3.3.1.1-29 37 B 3.3.2.2-6 30 B 3.3.1.1-30 30 B 3.3.2.2-7 30 B 3.3.1.1-31 30 B 3.3.3.1-1 30 B 3.3.1.1-32 30 B 3.3.3.1-2 30 B 3.3.1.1-33 30 B 3.3.3.1-3 30 (continued)

Brunswick Unit 2 LOEP-2 Revision 47 1

TABLE OF CONTENTS B 2.0 SA FETY LIM ITS (S Ls) .................................................................................. B 2.1.1-1 B 2.1.1 R eactor C ore S Ls .................................................................................... B 2.1.1-1 B 2.1.2 Reactor Coolant System (RCS) Pressure SL .......................................... B 2.1.2-1 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ............ B 3.0-1 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............................ B 3.0-12 B 3.1 REACTIVITY CONTROL SYSTEMS .............................................. B 3.1.1-1 B 3.1.1 SHUTDOWN MARGIN (SDM) ............................ B 3.1.1-1 B 3.1.2 Reactivity A nom alies ................................................................................ B 3.1.2-1 B 3.1.3 Control Rod OPERABILITY ..................................................................... B 3.1.3-1 B 3.1.4 Control Rod Scram Times ............................... B 3.1.4-1 B 3.1.5 Control Rod Scram Accumulators ........................................................... B 3.1.5-1 B 3.1.6 Rod Pattern Control ................................................................................. B 3.1.6-1 B 3.1.7 Standby Liquid Control (SLC) System ..................................................... B 3.1.7-1 B 3.1.8 Scram Discharge Volume (SDV) Vent and Drain Valves ........................ B 3.1.8-1 B 3.2 POWER DISTRIBUTION LIMITS ............................. B 3.2.1-1 B 3.2.1 AVERAGEPLANAR LINEAR HEAT GENERATION RAT E (A PLH G R )............................................................................. B 3.2.1-1 B 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) ...................................... B 3.2.2-1 B 3.2.3 Fraction of Core Boiling Boundary (FCBB) .............................................. B 3.2.3-1 B 3.3 INSTR UMENTATIO N .................................................................................... B 3.3.1.1-1 B 3.3.1.1 Reactor Protection System (RPS) Instrumentation ................................. B 3.3.1.1-1 B 3.3.1.2 Source Range Monitor (SRM) Instrumentation ....................................... B 3.3.1.2-1 B 3.3.1.3 Period Based Detection System (PBDS) ................................................. B 3.3.1.3-1 B 3.3.2.1 Control Rod Block Instrumentation .......................................................... B 3.3.2.1-1 B 3.3.2.2 Feedwater and Main Turbine High Water Level Trip Instrum entation .................................................................................. B 3.3 .2.2-1 B 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation .................................... B 3.3.3.1-1 B 3.3.3.2 Remote Shutdown Monitoring Instrumentation ....................................... B 3.3.3.2-1 B 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation ............................................................ B 3.3.4.1-1 B 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation .................... B 3.3.5.1-1 B 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation ............ B 3.3.5.2-1 B 3.3.6.1 Primary Containment Isolation Instrumentation ....................................... B 3.3.6.1-1 B 3.3.6.2 Secondary Containment Isolation Instrumentation .................................. B 3.3.6.2-1 B 3.3.7.1 Control Room Emergency Ventilation (CREV) System Instrum entation .................................................................................. B 3.3.7 .1-1 (continued)

Brunswick Unit 2 Revision No. 48 I

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements I applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the (continued)

Brunswick Unit 2 B 3.0-1 Revision No. 48 1

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, or to perform special evolutions.

Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.

LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.

(continued)

Brunswick Unit 2 B 3.0-10 Revision No. 48 I

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.8 If the allowed time expires and the snubber(s) are unable to perform their (continued) associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system.

LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

Brunswick Unit 2 B 3.0-11 Revision No. 48 1

SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs; or
b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a Special Operations LCO are only applicable when the Special Operations LCO is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given MODE or other specified condition.

(continued)

Brunswick Unit 2 B 3.0-12 Revision No. 48 I

SR Applicability B 3.0 BASES SR 3.0.1 Surveillances, including Surveillances invoked by Required Actions, (continued) do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > 800 psi. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 800 psi to perform other necessary testing.
b. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.

(continued)

Brunswick Unit 2 B 3.0-13 Revision No. 48 I

SR Applicability B 3.0 BASES SR 3.0.2 SR 3.0.2 permits a 25% extension of the interval specified in the (continued) Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of "in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." The requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

(continued)

Brunswick Unit 2 B 3.0-14 Revision No. 48 I

SR Applicability B 3.0 BASES (continued)

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered not to have been performed when specified, SR 3.0.3 allows the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 also provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend (continued)

Brunswick Unit 2 SB 3.0-15 Revision No. 48 I

, , v.

SR Applicability B 3.0 BASES SR 3.0.3 Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified (continued) Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time require to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65 (a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillance will be placed in the Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the (specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

(continued)

Brunswick Unit 2 B 3.0-16 Revision No. 48 I

SR Applicability B 3.0 BASES (continued)

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change.

When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed per SR 3.0.1, which states that Surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

(continued)

Brunswick Unit 2 B 3.0-17 Revision No. 48 I

SR Applicability B 3.0 BASES SR 3.0.4 The precise requirements for performance of SRs are specified such that (contined) exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability would have its Frequency specified such that it is not "due" until the specific conditions needed are met.

Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

Brunswick Unit 2 B 3.0-18 Revision No. 48 I

Control Rod Block Instrumentation B 3.3.2.1 BASES APPLICABLE 1. Rod Block Monitor (continued)

SAFETY ANALYSES, LCO, and uncertainties, process effects, calibration tolerances, instrument drift, and APPLICABILITY environment errors are accounted for and appropriately applied for the instrumentation.

The RBM is assumed to mitigate the consequences of an RWE event when operating __29% RTP. Analyses demonstrate that below this power level, the consequences of an RWE event will not exceed the MCPR SL and, therefore, the RBM is not required to be OPERABLE. Cycle specific analyses with Reference 2 methods are performed to establish an initial MCPR value above which the occurrence of an RWE event will not result in exceeding the MCPR SL while operating < 90% RTP. Cycle specific analyses are also performed to demonstrate that with MCPR greater than or equal to a specified value, no RWE event will result in exceeding the MCPR SL when operating at >_90% RTP. The MCPR values for both

< 90% RTP and _ 90% RTP are provided in the COLR. Under the conditions of THERMAL POWER and MCPR specified in the COLR, the RBM is not required to be OPERABLE.

The RBM selects one of three different RBM flux trip setpoints to be applied based on the current value of THERMAL POWER. THERMAL POWER is indicated to each RBM channel by a simulated thermal power (STP) reference signal input from an associated reference APRM channel. The OPERABLE range is divided into three "power ranges," a "low power range," an "intermediate power range," and a "high power range." The RBM flux trip setpoint applied within each of these three power ranges is, respectively, the "low trip setpoint," the "intermediate trip setpoint," and the "high trip setpoint" (Allowable Values for which are defined in the COLR). To determine the current power range, each RBM channel compares its current STP input value to three power setpoints, the "low power setpoint" (29%), the "intermediate power setpoint" (current value defined in the COLR), and the "high power setpoint" (current value defined in the COLR), which define, respectively, the lower limit of the low power range, the lower limit of the intermediate power range, and the lower limit of the high power range. The trip setpoint applicable for each power range is more restrictive than the corresponding setpoint for the lower power range(s). When STP is below the low power setpoint, the RBM flux trip outputs are automatically bypassed but the low trip setpoint continues to be applied to indicate the RBM flux setpoint on the NUMAC RBM displays.

(continued)

Brunswick Unit 2 B 3.3.2.1-4 Revision No. 47

Control Rod Block Instrumentation B 3.3.2.1 BASES APPLICABLE 1. Rod Block Monitor (continued)

SAFETY ANALYSES, LCO, and The calculated (required) setpoints and applicable power ranges are APPLICABILITY bounding values. In the equipment implementation, it is necessary to apply a "deadband" to each setpoint. The deadband is applied to the RBM trip setpoint selection logic and the RBM trip automatic bypass logic such that the setpoint being applied is always equal to or more conservative than the required setpoint. Since the RBM flux trip setpoint applicable to the higher power ranges are more conservative than the corresponding trip setpoints for lower power ranges, the trip setpoint applicable to the higher power range (high power range or intermediate power range) continues to be applied when STP decreases below the lower limit of that range until STP is below the power range setpoint by a value exceeding the deadband. Similarly, when STP decreases below the low power setpoint, the automatic bypass of RBM flux trip outputs will not be applied until STP decreases below the trip setpoint by a value exceeding the deadband.

The RBM channel uses THERMAL POWER, as represented by the STP input value from its reference APRM channel, to automatically enable RBM flux trip outputs (remove the automatic bypass) and to select the RBM flux trip setpoint to be applied. However, the RBM Upscale function is only required to be OPERABLE when the MCPR values are less than the limit specified in the COLR, depending on the THERMAL POWER level. Therefore, even though the RBM Upscale Function is implemented I

in each RBM channel as a single trip function with a selected trip setpoint, it is characterized in Table 3.3.2.1-1 as three Functions, the Low Power Range-Upscale Function, the Intermediate Power Range-Upscale Function, and the High Power Range-Upscale Function, to facilitate correct definition of the OPERABILITY requirements for the functions.

Each Function corresponds to one of the RBM power ranges. Due to the deadband effects on the determination of the current power range, the transition between these three Functions will occur at slightly different THERMAL POWER levels for increasing power versus decreasing power.

Since the RBM flux trip setpoints applied for the higher power ranges are more conservative, the OPERABILITY requirement for the Low Power Range-Upscale Function is satisfied if the Intermediate Power Range-Upscale Function or the High Power Range-Upscale Function is (continued)

Brunswick Unit 2 B 3.3.2.1-5 Revision No. 47

Unit 2 - Bases Book 2 Replacement Pages

Unit 2 - Bases Book 2 Replacement Pages

I, LIST OF EFFECTIVE PAGES - BASES Page No. Revision No. Page No. Revision No.

Title Page N/A B 3.4.7-4 39 B 3.4.7-5 39 List of Effective Pages - Book 2 B 3.4.8-1 30 B 3.4.8-2 30 LOEP-1 46 B 3.4.8-3 30 LOEP-2 45 B 3.4.8-4 30 LOEP-3 46 B 3.4.8-5 30 LOEP-4 30 B 3.4.9-1 30 LOEP-5 30 B 3.4.9-2 35 B 3.4.9-3 35 ii 30 B 3.4.9-4 30 30 B 3.4.9-5 35 B 3.4.9-6 35 B 3.4.1-1 30 B 3.4.9-7 30 B 3.4.1-2 30 B 3.4.9-8 30 B 3.4.1-3 30 B 3.4.9-9 35 B 3.4.1-4 30 B 3.4.10-1 30 B 3.4.1-5 30 B 3.4.10-2 30 B 3.4.1-6 30 B 3.4.2-1 30 B 3.5.1-1 30 B 3.4.2-2 30 B 3.5.1-2 30 B 3.4.2-3 30 B 3.5.1-3 30 B 3.4.2-4 30 B 3.5.1-4 33 B 3.4.3-1 30 B 3.5.1-5 33 B 3.4.3-2 30 B 3.5.1-6 39 B 3.4.3-3 30 B 3.5.1-7 30 B 3.4.3-4 30 B 3.5.1-8 30 B 3.4.4-1 30 B 3.5.1-9 30 B 3.4.4-2 30 B 3.5.1-10 30 B 3.4.4-3 30 B 3.5.1-11 30 B 3.4.4-4 30 B 3.5.1-12 30 B 3.4.4-5 30 B 3.5.1-13 30 B 3.4.5-1 30 B 3.5.1-14 42 B 3.4.5-2 30 B 3.5.1-15 42 B 3.4.5-3 41 B 3.5.1-16 30 B 3.4.5-4 39 B 3.5.1-17 30 B 3.4.6-1 39 B 3.5.2-1 30 B 3.4.6-2 39 B 3.5.2-2 30 B 3.4.6-3 39 B 3.5.2-3 30 B 3.4.7-1 30 B 3.5.2-4 30 B 3.4.7-2 30 B 3.5.2-5 30 B 3.4.7-3 39 B 3.5.2-6 30 B 3.5.3-1 30 B 3.5.3-2 39 (continued)

Brunswick Unit 2 LOEP-1 Revision 46 1

LIST OF EFFECTIVE PAGES - BASES (continued)

Page No. Revision No. Page No. Revision No.

B 3.6.4.3-4 30 B 3.7.7-1 30 B 3.6.4.3-5 30 B 3.7.7-2 30 B 3.6.4.3-6 30 B 3.7.7-3 30 B 3.7.1-1 30 B 3.8.1-1 30 B 3.7.1-2 30 B 3.8.1-2 30 B 3.7.1-3 39 B 3.8.1-3 33 B 3.7.1-4 39 B 3.8.1-4 39 B 3.7.1-5 39 B 3.8.1-5 39 B 3.7.2-1 30 B 3.8.1-6 30 B 3.7.2-2 30 B 3.8.1-7 30 B 3.7.2-3 30 B 3.8.1-8 30 B 3.7.2-4 30 B 3.8.1-9 30 B 3.7.2-5 30 B 3.8.1-10 30 B 3.7.2-6 30 B 3.8.1-11 30 B 3.7.2-7 30 B 3.8.1-12 30 B 3.7.2-8 30 B 3.8.1-13 30 B 3.7.2-9 30 B 3.8.1-14 30 B 3.7.2-10 30 B 3.8.1-15 30 B 3.7.2-11 30 B 3.8.1-16 30 B 3.7.2-12 30 B 3.8.1-17 30 B 3.7.2-13 30 B 3.8.1-18 30 B 3.7.2-14 30 B 3.8.1-19 30 B 3.7.3-1 30 B 3.8.1-20 30 B 3.7.3-2 43 B 3.8.1-21 30 B 3.7.3-3 30 B 3.8.1-22 30 B 3.7.3-4 30 B 3.8.1-23 30 B 3.7.3-5 30 B 3.8.1-24 30 B 3.7.3-6 30 B 3.8.1-25 30 B 3.7.3-7 33 B 3.8.1-26 30 B 3.7.4-1 30 B 3.8.1-27 30 B 3.7.4-2 30 B 3.8.1-28 46 B 3.7.4-3 30 B 3.8.1-29 46 B 3.7.4-4 30 B 3.8.1-30 30 B 3.7.4-5 30 B 3.8.1-31 30 B 3.7.5-1 30 B 3.8.1-32 30 B 3.7.5-2 30 B 3.8.1-33 33 B 3.7.5-3 30 B 3.8.1-34 30 B 3.7.6-1 30 B 3.8.2-1 30 B 3.7.6-2 30 B 3.8.2-2 30 B 3.7.6-3 30 B 3.8.2-3 30 B 3.7.6-4 30 B 3.8.2-4 30 B 3.8.2-5 30 (continued)

Brunswick Unit 2 LOEP-3 Revision 46 1

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g.,

high jacket water temperature) are bypassed on an ECCS initiation test signal and critical protective functions (engine overspeed, generator differential overcurrent, low lubricating oil pressure, reverse power, loss of field, and phase overcurrent-voltage restrained) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.11 Brunswick Nuclear Plant performs a 60 minute run greater than or equal to the continuous rating (3500 kW) and less than or equal to the 2000-hour rating (3850 kW) to demonstrate diesel generator operation and to detect potential degradations and incipient failures. Post-accident DG loading is allowed up to the 2000-hour rating; however, it is impractical to require testing at this load but not to exceed it. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in the Bases for SR 3.8.1.2, and for gradual loading, discussed in the Bases for SR 3.8.1.3, are applicable to this SR.

(continued)

Brunswick Unit 2 B 3.8.1-28 Revision No. 46 1

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor < 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience.

The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This Surveillance has been modified by two Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. To minimize testing of the DGs, Note 2 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.13, demonstration of the test mode override feature ensures that the DG availability under accident conditions is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation (continued)

Brunswick Unit 2 B 3.8.1-29 Revision No. 46 I

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