BSEP 08-0069, Request for License Amendment - Technical Specification 3.6.1.6, Suppression Chamber-to-Drywell Vacuum Breakers.

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Request for License Amendment - Technical Specification 3.6.1.6, Suppression Chamber-to-Drywell Vacuum Breakers.
ML081980056
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/07/2008
From: Waldrep B
Progress Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 08-0069, TSC-2008-02
Download: ML081980056 (21)
v • d • e


Text

Progress Energy Benjamin C. Waldrep Vice President Brunswick Nuclear Plant Progress Energy Carolinas, lnc July 7,2008 SERIAL: BSEP 08-0069 10 CFR 50.90 TSC-2008-02 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-7 1 and DPR-62 Request for License Amendment - Technical Specification 3.6.1.6, "Suppression Chamber-to-Drywell Vacuum Breakers" Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,

is requesting a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendment revises Surveillance Requirements 3.6.1.6.1 and 3.6.1.6.2 regarding the testing of suppression chamber-to-drywell vacuum breakers. An evaluation of the proposed license amendment is provided in Enclosure 1.

CP&L has evaluated the proposed change in accordance with 10 CFR 50.9 1(a)( l), using the criteria in 10 CFR 50.92(c), and determined that this change involves no significant hazards considerations.

In accordance with 10 CFR 50.91(b), CP&L is providing, a copy of the proposed license amendment to the designated representative for the State of North Carolina.

CP&L requests approval of the proposed amendment by March 3 1,2009, and once approved, that the amendment be implemented within 90 days.

No regulatory commitments are contained in this submittal. Please refer any questions regarding this submittal to Mr. Randy C. Ivey, Manager - Support Services, at (910) 457-2447.

PO Box 10429 Southpart. NC 28461 T> 91 0 457 3698

Document Control Desk BSEP 08-0069 1 Page 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 7,2008.

Sincerely, Benjamin C. Waldrep WRMIwrm

Enclosures:

1. Evaluation of License Amendment Request
2. Marked-up Technical Specification Pages - Unit 1
3. Typed Technical Specification Pages - Unit 1
4. Typed Technical Specification Pages - Unit 2
5. Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

Document Control Desk BSEP 08-0069 / Page 3 cc (with enclosures):

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

ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly O. 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 08-0069 Enclosure 1 Page 1 of 9 Evaluation of Proposed License Amendment Request

Subject:

Technical Specification 3.6.1.6, "Suppression Chamber-to-Drywell Vacuum Breakers" 1.0 Description This letter is a request by Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., to amend the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendment revises Surveillance Requirements (SRs) 3.6.1.6.1 and 3.6.1.6.2 regarding the testing of suppression chamber-to-drywell vacuum breakers.

Currently, SR 3.6.1.6.1 requires that each suppression chamber-to-drywell vacuum breaker be verified closed: (1) every 14 days, and (2) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after any discharge of steam to the suppression chamber from any source. Currently, SR 3.6.1.6.2 requires functional testing of each required vacuum breaker: (1) every 92 days, (2) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber from the safety-relief valves (SRVs), and (3) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open.

2.0 Proposed Change The proposed change will remove the requirement to perform a functional test of each vacuum breaker within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open and instead establish a requirement to verify each vacuum breaker is closed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that causes any of the vacuum breakers to open. The specific wording of the proposed change follows. The addition to SR 3.6.1.6.1 is shown in bold and conditional Frequency being deleted in SR 3.6.1.6.2 is shown with strike-out font.

BSEP 08-0069 Enclosure 1 Page 2 of 9 Surveillance Frequency SR 3.6.1.6.1 ------------NOTE-------------

Not required to be met for vacuum breakers that are open during Surveillances.

Verify each vacuum breaker is 14 days closed.

AND Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after any discharge of steam to the suppression chamber from any source AND Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that cause any of the vacuum breakers to open SR 3.6.1.6.2 Perform a functional test of 92 days each required vacuum AND breaker.

Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber from the SRVs AND Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open.

For convenience, Enclosure 2 contains a marked-up version of the Unit 1 TSs showing the proposed changes. Since Surveillance Requirements 3.6.1.6.1 and 3.6.1.6.2 for Unit 1 and Unit 2 are identical, only the mark-up for Unit 1 is provided. Enclosures 3 and 4 provide typed versions of the Unit 1 and Unit 2 TSs, respectively. These typed TS pages are to be used for issuance of the proposed amendment.

BSEP 08-0069 Enclosure 1 Page 3 of 9 CP&L will make supporting changes to the TS Bases in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Enclosure 5 provides marked-up TS Bases pages for Unit 1. These pages are being submitted for information only and do not require issuance by the NRC.

3.0 Background On May 5, 2006 (i.e., ADAMS Accession Number ML060890283), in response to CP&L's application dated June 20, 2005 (i.e., ADAMS Accession Number ML051790195), the NRC issued License Amendments 240 and 268 for BSEP, Units 1 and 2, respectively, revising the frequency of suppression chamber-to-drywell vacuum breaker functional testing, as well as adding functional testing when certain conditions occur (i.e., steam discharge to the suppression chamber from the SRVs or vacuum breaker opening).

A failure of a vacuum breaker to re-close occurred at BSEP, Unit 2 in July 2004. This event was reported in Licensee Event Report 2-2004-002 (i.e., ADAMS Accession Number ML042790475). A faulty test actuator was determined to be a contributing cause for the failure of the vacuum breaker to close during surveillance testing. Because the actuating device used to test the vacuum breakers was susceptible to failure in a manner that could cause the vacuum breakers to fail open, which would render the suppression chamber inoperable due to the creation of a suppression chamber steam bypass pathway, CP&L proposed a change to revise the test frequency for these vacuum breakers during power operation from once every 31 days to once every 92 days.

In Amendments 240 and 268, SR 3.6.1.6.2 was revised to incorporate the most recent conditions pertaining to vacuum breaker functional testing as found in Revision 3 of NUREG-1433, Standard Technical Specifications, General Electric Plants, BWR/4.

SR 3.6.1.8.2 in NUREG-1433, corresponded to Brunswick SR 3.6.1.6.2. Rather than requiring vacuum breaker functional testing within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber, from any source, SR 3.6.1.6.2 was revised to incorporate the NUREG-1433 requirement for functional testing of the vacuum breakers within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any steam discharge to the suppression chamber from the SRVs. This change was intended to eliminate unnecessary vacuum breaker cycling after routine evolutions such as High Pressure Coolant Injection (HPCI) or Reactor Core Isolation Cooling (RCIC)

System testing, if no vacuum breakers were opened. In addition, a NUREG-1433 requirement for functional testing of each vacuum breaker within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open was also incorporated.

Since Amendments 240 and 268 were implemented, an unexpected and significant increase in the number of suppression chamber-to drywell vacuum breaker functional tests (i.e., approximately 30 performances for Unit 1 and approximately 48 performances for Unit 2) have been required due to the momentary vacuum breakers openings that were not associated with steam discharge to the suppression chamber. These vacuum breaker

BSEP 08-0069 Enclosure 1 Page 4 of 9 openings have been the result of momentary pressure differentials between the suppression chamber and drywell which normally occur during routine containment venting evolutions. At BSEP, venting of the primary containment is usually needed approximately every two to four days. As a result of these momentary vacuum breaker openings during containment venting evolutions, performance of vacuum breaker functional testing in accordance with SR 3.6.1.6.2 has been required far more frequently than was anticipated when the changes to SR 3.6.1.6.2 were proposed in 2005. In order to reduce excessive wear on the vacuum breaker test actuating mechanism, CP&L is proposing to remove the requirement to perform a functional test of each vacuum breaker within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open and instead establish a requirement under SR 3.6.1.6.1 to verify within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that causes any of the vacuum breakers to open that each vacuum breaker is closed.

A transient involving the discharge of steam from the SRVs to the suppression chamber may result in a suppression chamber environmental change sufficient to warrant demonstrating, via a functional test, the continued operability of a suppression chamber-to-drywell vacuum breaker. However, a momentary opening or loss of closed indication of a vacuum breaker during containment venting operations does not involve a significant transient or change in local environmental conditions that could challenge the operability of the vacuum breakers and, as such, a functional test is not needed. Instead, the ability of the vacuum breakers to support the containment suppression function by ensuring that a drywell steam bypass pathway to the suppression pool does not exist, can be adequately satisfied by verifying that each vacuum breaker is closed.

4.0 Technical Analysis System Description/Applicable Safety Analysis The suppression chamber-to-drywell vacuum breakers function to relieve a negative pressure differential between the drywell and suppression chamber in the event of a loss-of-coolant accident (LOCA) in the drywell. Details of the primary containment functional design are discussed in Section 6.2.1 of the Updated Final Safety Analysis Report (UFSAR) for BSEP, Units 1 and 2. A description of the suppression chamber-to-drywell vacuum breakers is provided in Section 6.2.1.1.3.3.1 of the UFSAR.

If a LOCA were to occur, most of the non-condensible gases in the drywell would be blown into the suppression chamber as the drywell becomes pressurized with steam.

After the blow down, a vacuum would occur in the drywell as the steam condensed.

A negative pressure could also occur due to inadvertent drywell spray actuation during normal operation. If the drywell vacuum were not relieved, the drywell could buckle (i.e., implode). The design negative pressure for the containment is 2.0 psid. With 8 of the 10 suppression chamber-to-drywell vacuum breakers operable for the purpose of

BSEP 08-0069 Enclosure 1 Page 5 of 9 opening, the capability for non-condensible gases in the suppression chamber to pass back into the drywell is assured to restore pressure in the drywell. The degree of redundancy provided through the use of multiple vacuum breakers provides a high level of assurance that the drywell is protected from buckling.

In the event of a LOCA, the suppression chamber-to-drywell vacuum breakers must be closed for the suppression pool to provide its steam quenching function. If a suppression chamber-to-drywell vacuum breaker was not closed, a drywell bypass pathway to the suppression pool would exist, resulting in the potential for primary containment overpressurization due to the bypass leakage if a LOCA were to occur. The maximum allowable amount of bypass leakage area is equivalent to a 24-inch pipe for a large break LOCA, and equivalent to a 6-inch pipe for a small break LOCA. TS 3.6.1.6, ACTION B.1 requires that all open suppression chamber-to-drywell vacuum breakers be closed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or the plant to be in Mode 3 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Another function of the suppression chamber-to-drywell vacuum breakers is to minimize the elevation of the water column in the containment vent system during normal operation. If the drywell pressure is less than the suppression chamber pressure, there will be an increase in the height of the vent system downcomer water leg. The suppression chamber-to-drywell vacuum breakers limit the height of the water column in the vent system to ensure that vent clearing loads are not exceeded during a LOCA.

The suppression chamber-to-drywell vacuum breakers are located in the suppression chamber air space attached to the drywell vent system. The vacuum breakers are a swing-check device, with a 20-inch flapper or "pallet" which self-actuates to open under a differential pressure of 0.5 psi. Magnetic latches are provided to prevent chattering and vibration, with a differential pressure setting of approximately 0.1 to 0.15 psi. While venting the drywell, a pressure differential of 0.1 psi can be seen momentarily.

Each vacuum breaker is equipped with a pneumatically powered stroke test actuator which enables control room personnel to remotely stroke the vacuum breaker as a demonstration of operability. Redundant, proximity-type limit switches are provided to indicate when the pallet is in the fully closed position. Additionally, one primary and one spare mechanical limit switch are provided to indicate when the pallet is in the fully open position. The test actuators are not classified as safety-related devices and have not been tested under LOCA conditions.

Standing instructions to vent the suppression chamber for extended periods prior to venting the drywell have been used to limit the differential across the pallet with mixed results. Plant procedure 0PT-02.3.1, Suppression Chamber to Drywell Vacuum Breakers Operability Test, for testing the suppression chamber-to-drywell vacuum breakers uses an arm-actuated piston which forces an arm into the pallet face to force the vacuum breaker pallet open. Air is vented off the piston to shut the valve. The actuation of the valve is

BSEP 08-0069 Enclosure 1 Page 6 of 9 harsh and can wear both the actuator and the vacuum breaker components, hinge, bushings, magnet, etc. The normal function of the valve is to open with differential pressure alone. This forced actuation reduces to lifetime of valve components.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration The proposed change will remove from Surveillance Require (SR) 3.6.1.6.2 the requirement to perform a functional test of each vacuum breaker within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open and instead establish a requirement in SR 3.6.1.6.1 to verify each vacuum breaker is closed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that causes any of the vacuum breakers to open. CP&L has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed change does not involve physical changes to any plant structure, system, or component. The suppression chamber-to-drywell vacuum breakers only provide an accident mitigation function. As such, the probability of occurrence for a previously analyzed accident is not impacted by the change to the surveillance frequency for these components.

The consequences of a previously analyzed accident are dependent on the initial conditions assumed for the analysis, the behavior of the fuel during the analyzed accident, the availability and successful functioning of the equipment assumed to operate in response to the analyzed event, and the setpoints at which these actions are initiated. No physical change to suppression chamber-to-drywell vacuum breakers is being made as a result of the proposed change, nor does the change alter the manner in which the vacuum breakers operate during an accident. As a result, no new failure modes of the suppression chamber-to-drywell vacuum breakers are being introduced. The surveillance requirements for the suppression chamber-to-drywell vacuum breakers will continue to ensure testing of the suppression chamber-to-drywell vacuum breakers following plant transients involving the discharge of steam to the suppression chamber from the SRVs, and such testing will continue to provide assurance that the vacuum breakers are able to perform their design function. Based on this evaluation, there is no significant increase in the consequences of a previously analyzed event.

BSEP 08-0069 Enclosure 1 Page 7 of 9

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

Response: No The proposed change to the surveillance requirements for the suppression chamber-to-drywell vacuum breakers does not involve any physical alteration of plant systems, structures, or components. No new or different equipment is being installed. No installed equipment is being operated in a different manner. There is no alteration to the parameters within which the plant is normally operated or in the setpoints that initiate protective or mitigative actions. As a result no new failure modes are being introduced. Therefore, the proposed change to the surveillance requirements for the suppression chamber-to-drywell vacuum breakers does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No The proposed change revises Surveillance Requirement 3.6.1.6.1 to add a new requirement to verify each vacuum breaker is closed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that causes any of the vacuum breakers to open and revises Surveillance Requirement 3.6.1.6.2 by removing the requirement to perform functional testing of each vacuum breaker within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breakers to open. The operability and functional characteristics of the suppression chamber-to-drywell vacuum breakers remains unchanged. The margin of safety is established through the design of the plant structures, systems, and components, through the parameters within which the plant is operated, through the establishment of the setpoints for the actuation of equipment relied upon to respond to an event, and through margins contained within the safety analyses. The proposed change to the surveillance requirements for the suppression chamber-to-drywell vacuum breakers does not impact the condition or performance of structures, systems, setpoints, and components relied upon for accident mitigation.

The proposed change to Surveillance Requirements 3.6.1.6.1 and 3.6.1.6.2 will avoid unnecessary cycling and wear of the vacuum breaker test actuation mechanisms, will improve the reliability of the vacuum breakers, and will minimize the potential for a plant shut down due to a problem with a vacuum breaker test actuating mechanism from excessive wear. The proposed change does not impact any safety analysis assumptions or results. Therefore, the proposed change does not result in a significant reduction in the margin of safety.

BSEP 08-0069 Enclosure 1 Page 8 of 9 Based on the above, CP&L concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 36(d)(3) requires that a surveillance requirements must be established that include testing, calibrating, or inspecting to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the Limiting Condition for Operation (LCO) will be met. While the proposed changes eliminate some functional testing of the vacuum breakers, the scope of the testing being eliminated only applies to operating conditions that do not result in significant stresses to the vacuum breakers and thus are not likely to impact he operability of the components. The existing TS LCO will continue to require that the suppression chamber-to-drywell vacuum breakers be operable during the specified operating conditions. No other requirements of existing LCOs or Surveillance Requirements are being added, deleted, or altered as a result of the proposed changes.

6.0 Environmental Considerations A review has determined that the proposed amendment is administrative in nature and does not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and does not change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 References Letter from Cornelius J. Gannon (CP&L) to NRC Document Control Desk, "Request for License Amendments Regarding Suppression Chamber-to-Drywell Vacuum Breaker Surveillance Testing," June 20, 2005, ADAMS Accession Number ML051790195.

1. Letter from Brenda L. Mozafari (USNRC) to James Scarola (CP&L), "Issuance of Amendment on Suppression Chamber-to-Vacuum Breaker Stroke Testing (TAC

BSEP 08-0069 Enclosure 1 Page 9 of 9 Nos. MC7352 and MC7353)," May 5, 2006, ADAMS Accession Number ML060890283.

BSEP 08-0069 Enclosure 2 Marked-up Technical Specification Pages - Unit 1

Suppression Chamber-to-DrywellVaccum Breakers 3.6.1.6 3.6 CONTAINMENT SYSTEMS LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening.

AND Ten suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY: MODES 1,2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required suppression A. 1 Restore one vacuum 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> chamber-to-drywell vacuum breaker to OPERABLE breaker inoperable for status.

opening.

B. One suppression chamber-to-d rywelI vacuum breaker B. 1 Close the open vacuum breaker.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> I not closed.

C. Required Action and c.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND c.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Brunswick Unit 1 3.6-1 8 Amendment No. 223 I

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SU RVElLLANCE REQUl REMENTS S URVEILLANCE FREQUENCY Verify each vacuum breaker is closed. 14 days Nithin 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after any discharge of steam to the suppression chamber from any gurce 3.6.1.6.2 Perform a functional test of each required vacuum 92 days I breaker.

Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber from the S RVs i?

~

SR 3.6.1.6.3 Verify the full open setpoint of each required vacuum 24 months breaker is 5 0.5 psid.

Brunswick Unit 1 3.6-19 Amendment No. 240 I

BSEP 08-0069 Enclosure 3 Typed Technical Specification Pages - Unit 1

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 --------------------------------NOTE-------------------------------

Not required to be met for vacuum breakers that are open during Surveillances.

Verify each vacuum breaker is closed. 14 days AND Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after any discharge of steam to the suppression chamber from any source AND Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that causes any of the vacuum breakers to open 3.6.1.6.2 Perform a functional test of each required vacuum 92 days breaker.

AND Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber from the SRVs SR 3.6.1.6.3 Verify the full open setpoint of each required vacuum 24 months breaker is 0.5 psid.

Brunswick Unit 1 3.6-19 Amendment No. XXX

BSEP 08-0069 Enclosure 4 Typed Technical Specification Page - Unit 2

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 ------------------------------NOTE--------------------------------

Not required to be met for vacuum breakers that are open during Surveillances.

Verify each vacuum breaker is closed. 14 days AND Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after any discharge of steam to the suppression chamber from any source AND Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following an operation that causes any of the vacuum breakers to open SR 3.6.1.6.2 Perform a functional test of each required vacuum 92 days breaker.

AND Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber from the SRVs SR 3.6.1.6.3 Verify the full open setpoint of each required vacuum 24 months breaker is 0.5 psid.

Brunswick Unit 2 3.6-19 Amendment No. xxx

BSEP 08-0069 Enclosure 5 Marked-up Technical Specification Bases Page - Unit 1 (For Information Only)

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BASES S U RVEl LLANC E SR 3.6.1.6.1 (continued)

REQUIREMENTS and drywell is maintained > 0.5 times the initial differential pressure for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> without nitrogen makeup. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel and procedural controls to ensure the drywell is normally maintained at a higher pressure than the suppression chamber, and has been shown to be acceptable through operating experience. This verification is also required within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after any discharge of steam to the suppression ich allows suppression chamber-to-drywell vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers.

SR 3.6.1.6.2 Each required vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position. This is accomplished by verifying each required vacuum breaker operates through at least one complete cycle of full travel. This SR ensures that the safety analysis assumptions are valid. The 92 day Frequency of this SR was developed, based on lnservice Testing 1

Program requirements to perform valve testing at least once every 92 daw. In addition, this functional test is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after a SR 3.6.1.6.3 Verification of the vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 24 month Frequency has been demonstrated to be acceptable, based on operating experience, and is further justified because of other surveillances performed more frequently that convey the proper functioning status of each vacuum breaker.

REFERENCES 1. UFSAR, Section 6.2.

2. 10 CFR 50,36(c)(2)(ii).

Brunswick Unit 1 B 3.6.1.6-5 Revision No.@ I

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