BSEP 08-0156, Request for License Amendment - Adoption of TSTF-478, Revision 2 - BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control
| ML083370316 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/24/2008 |
| From: | Waldrep B Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 08-0156, TSC-2007-06 | |
| Download: ML083370316 (44) | |
Text
Progress Energy Vice President Brunswick Nuclear Plant Progress Energy Carolinas, Inc.
November 24, 2008 SERIAL: BSEP 08-0156 10 CFR 50.90 TSC-2007-06 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 Request for License Amendment - Adoption of TSTF-478, Revision 2 -
BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control 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 (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.
The proposed amendment would delete TS 3.6.3.2, "Containment Atmosphere Dilution (CAD) System," and the associated Bases that will result in modifications to containment combustible gas control TS requirements as permitted by 10 CFR 50.44. This change is consistent with NRC approved Revision 2 to Technical Specification Task Force (TSTF)
Improved Standard Technical Specification Change Traveler, TSTF-478, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control."
CP&L is adopting the TSTF-478, Revision 2, CAD System TS changes without variation except that the BSEP TS for the CAD System is TS 3.6.3.2 rather than TS 3.6.3.3 as provided in the TSTF mark-ups. TSTF-478 Revision 2 also makes TS and associated Bases changes for the TS section on Drywell Cooling System Fans. Since BSEP TSs do not have this TS section, these changes are not needed. The availability of this TS improvement was announced in the Federal Register on November 21, 2007 (72 FR 65610), as part of the consolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. Enclosure 2 provides the existing Unit 1 TS pages marked-up to show the proposed change. The same TS changes are being requested for Unit 2. Enclosures 3 and 4 provide the proposed TS changes in final typed format for Units 1 and 2, respectively. Enclosure 5 provides the existing Unit I TS Bases pages marked-up to show the proposed changes. Identical changes will be made for the Unit 2 TS Bases. These Bases pages are being submitted for information only and do not require issuance by the NRC.
P.. Box 10429 Southport, NC 28461 T> 910.457.3698
Document Control Desk BSEP 08-0156 / Page 2 CP&L requests approval of the proposed amendments by May 29, 2009, and that once approved, the amendments shall be implemented within 60 days.
CP&L is providing, in accordance with 10 CFR 50.91, a copy of the proposed license amendment to the designated representative for the State of North Carolina.
No regulatory commitments are associated with this submittal. Please refer any questions regarding this submittal to Mr. Gene Atkinson, Supervisor - Licensing/Regulatory Programs, at (910) 457-2056.
I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 24, 2008.
Sincerely, Benjamin C. Waldrep MAT/mat
Enclosures:
- 1. Evaluation of Proposed License Amendment Requests
- 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 08-0156 / 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. Philip B. O'Bryan, 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 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 08-0156 Page 1 of 2 Evaluation of Proposed License Amendment Request
Subject:
Request for License Amendment - Adoption of TSTF-478, Revision 2 -
BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control 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) of Renewed Facility Operating Licenses DPR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.
The proposed amendment would delete TS 3.6.3.2, "Containment Atmosphere Dilution (CAD) System," and the associated Bases that will result in modifications to containment combustible gas control TS requirements as permitted by 10 CFR 50.44. This change is consistent with NRC approved Revision 2 to Technical Specification Task Force (TSTF)
Improved Standard Technical Specification Change Traveler, TSTF-478, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control." The availability of this TS improvement was announced in the Federal Register on November 21, 2007 (72 FR 65610) as part of the consolidated line item improvement process (CLIIP).
2.0 Proposed Changes Consistent with the NRC approved Revision 2 of TSTF-478, the proposed TS changes delete TS 3.6.3.2, "Containment Atmosphere Dilution (CAD) System." Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-478, Revision 2 is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.
This application is being made in accordance with the CLIIP. CP&L is proposing two minor variations from the TS changes described in TST4-478, Revision 2, and the NRC staff's model safety evaluation (SE) published on November 21, 2007 (72 FR 65610), as part of the CLIIP Notice of Availability. First, the BSEP TS for the CAD System is TS 3.6.3.2 rather than TS 3.6.3.3 as provided in the TSTF mark-ups. Second, TSTF-478 Revision 2 also makes TS and Bases changes for the TS section on Drywell Cooling System Fans. Since BSEP TSs do not have this TS section, these changes are not needed.
BSEP 08-0156 Page 2 of 2 3.0
Background
The background for this application is adequately addressed by the NRC Notice of Availability published on November 21, 2007 (72 FR 65610).
4.0 Technical Analysis CP&L has reviewed the SE published on November 21, 2007 (72 FR 65610), as part of the CLIIP Notice of Availability. CP&L has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to BSEP Units 1 and 2 and, therefore, justify this amendment for the incorporation of the proposed changes to the BSEP TS.
5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Determination CP&L has reviewed the no significant hazards determination published on November 21, 2007 (72 FR 65610), as part of the CLIIP Notice of Availability. CP&L has concluded that the determination presented in the notice is applicable to BSEP Units 1 and 2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).
5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on November 21, 2007 (72 FR 65610).
6.0 Environmental Evaluation CP&L has reviewed the environmental evaluation included in the safety evaluation (SE) published on November 21, 2007 (72 FR 65610), as part of the CLIIP Notice of Availability.
CP&L has concluded that the staffs findings presented in that evaluation are applicable to BSEP Units I and 2 and the evaluation is hereby incorporated by reference for this application.
7.0 References
- 1. Federal Register Notice, Notice of Availability published on November 21, 2007 (72 FR 65610).
- 2. TSTF-478 Revision 2, "BWR Technical Specification Changes that Implement the Revised Rule for Combustible Gas Control."
BSEP 08-0156 Markup of Technical Specification Pages - Unit 1
CAD System 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System
',.J..7 p
.. Lal qrr
-Ln --
==.
APPLICABIL MODE I during the time period:
From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is> 150,TP following artup, to
- b.
24 hou rior to a scheduled reducti of THERMAL POWER to
< 15% R 4,CTIONS CONDITION REQUIR CTION COMPLETION TIME A.
CAD System inoperabl A.1 Restore CAD Syste to 31 days OPERABLE status.ý B. Required ction and C.1 Be in MODE 2.
8 ho asso ed Completion Time n, met.
I Brunswick Unit I 3.6-27 Amendment No.
I I
SURVEILL CE REQUIREMENTS CAD Syste 3..2 SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify Ž4 gal of liquid nitrogen are c ained in the 31 days CAD Syst~em.
SR 3.6.3.2.2 Verify each CAD subsys manual, power operated, 31 days and automatic valve e flo ath that is not locked, sealed, or othen' e secured in p ition is in the correct positi or can be aligned to correct position.
3.6.3.2.3 U
ycle each power operated, excluding automatic,*
24 months
........ k Unit 4
9.6328 Ali.....
,,,ft.
Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in MODE 1, 2, containment to OPERABLE or 3.
status.
B.
Required Action and B.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 of Condition A not met.
AND B.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 /> C.
Secondary containment C.1 inoperable during movement LCO 3.0.3 is not applicable.
of recently irradiated fuel assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs.
recently irradiated fuel assemblies in the secondary containment.
AND (continued)
II I
3.6t Brunswick Unit I Amendment No. *d I
Secondary Containment 3.6.4.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
(continued)
C.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment equipment hatches 24 months are closed and sealed.
SR 3.6.4.1.2 Verify one secondary containment access door is 24 months closed in each access opening.
SR 3.6.4.1.3 Verify each SGT subsystem can maintain >_ 0.25 inch 24 months on a of vacuum water gauge in the secondary containment STAGGERED for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate _ 3000 cfm.
TEST BASIS I
3.6-Amendment No. a Brunswick Unit 1
SCIDs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)
LCO 3.6.4.2 Each SCID shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS NOTES
- 1.
Penetration flow paths may be unisolated intermittently under administrative controls.
- 2.
Separate Condition entry is allowed for each penetration flow path.
- 3.
Enter applicable Conditions and Required Actions for systems made inoperable by SCIDs.
II CONDITION REQUIRED ACTION COMPLETION TIME A.
One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flow paths with one SCID penetration flow path by inoperable, use of at least one closed and de-activated automatic damper, closed manual damper, or blind flange.
AND (continued)
Brunswick Unit 1 Amendment No. 24el
SCIDs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2
.NOTE-Isolation devices in high radiation areas may be verified by use of administrative means.
Verify the affected Once per 92 days penetration flow path is isolated.
B.
NOTE-----
B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two isolation dampers.
and de-activated automatic damper, closed manual damper, or blind flange.
One or more penetration flow paths with two SCIDs inoperable.
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 of Condition A or B not met AND in MODE 1, 2, or 3.
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 /> (continued) 3.6-.3ý Brunswick Unit 1 Amendment No. *Gia-ý
SCIDs 3.6.4.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and D.1 NOTE----
associated Completion Time LCO 3.0.3 is not applicable.
of Condition A or B not met during movement of recently irradiated fuel assemblies in Suspend movement of Immediately the secondary containment recently irradiated fuel or during OPDRVs.
assemblies in the secondary containment.
AND D.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each automatic SCID is 24 months within limits.
SR 3.6.4.2.2 Verify each automatic SCID actuates to the isolation 24 months position on an actual or simulated actuatidn signal.
3.6-,3te Amendment No.
Brunswick Unit 1
SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One SGT subsystem A.1 Restore SGT subsystem to 7 days inoperable in MODE 1, 2 or OPERABLE status.
3.
B.
Required Action and B.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 of Condition A not met.
AND OR B.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 /> Two SGT subsystems inoperable in MODE 1, 2, or3.
(continued)
II 3.6!
Brunswick Unit 1 Amendment No. -I41
SGT System 3.6.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.
One SGT subsystem C.1 Restore SGT subsystem to 31 days inoperable during movement OPERABLE status.
of recently irradiated fuel assemblies in the secondary containment or during OPDRVs.
D. Required Action and
NOTE------
associated Completion Time LCO 3.0.3 is not applicable.
of Condition C not met.
D.1 Place OPERABLE SGT Immediately subsystem in operation.
OR D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.
AND D.2.2 Initiate action to suspend Immediately OPDRVs.
(continued)
II 3.6ý Brunswick Unit 1 Amendment No.-.-Itri
SGT System 3.6.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E.
Two SGT subsystems E.1 NOTE inoperable during movement LCO 3.0.3 is not applicable.
of recently irradiated fuel assemblies in the secondary containment or during Suspend movement of Immediately OPDRVs.
recently irradiated fuel assemblies in secondary containment.
AND E.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for > 10 continuous 31 days hours with heaters operating.
SR 3.6.4.3.2 Perform required SGT filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP).
the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or 24 months simulated initiation signal.
I.
3.6tý Brunswick Unit 1 Amendment No. *+;,I
BSEP 08-0156 Typed Technical Specification Pages - Unit 1
CAD System 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System The requirement for the CAD System is deleted.
I Brunswick Unit I 3.6-27 Amendment No.
I
Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 APPLICABILITY:
The secondary containment shall be OPERABLE.
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in MODE 1, 2, containment to OPERABLE or 3.
status.
B.
Required Action and B.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 of Condition A not met.
AND B.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 /> C.
Secondary containment C.1 NOTE--
inoperable during movement LCO 3.0.3 is not applicable.
of recently irradiated fuel assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs.
recently irradiated fuel assemblies in the secondary containment.
AND (continued)
Brunswick Unit 1 3.6-28 Amendment No.
I
Secondary Containment 3.6.4.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
(continued)
C.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment equipment hatches 24 months are closed and sealed.
SR 3.6.4.1.2 Verify one secondary containment access door is 24 months closed in each access opening.
SR 3.6.4.1.3 Verify each SGT subsystem can maintain Ž 0.25 inch 24 months on a of vacuum water gauge in the secondary containment STAGGERED for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate < 3000 cfm.
TEST BASIS Brunswick Unit 1 3.6-29 Amendment No.
I
SCIDs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)
APPLICABILITY:
Each SCID shall be OPERABLE.
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS IIJ t j
' Z., ----
- 1.
Penetration flow paths may be unisolated intermittently under administrative controls.
- 2.
Separate Condition entry is allowed for each penetration flow path.
- 3.
Enter applicable Conditions and Required Actions for systems made inoperable by SCIDs.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flow paths with one SCID penetration flow path by inoperable, use of at least one closed and de-activated automatic damper, closed manual damper, or blind flange.
AND (continued)
Brunswick Unit 1 3.6-30 Amendment No.
I
SCIDs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2 Isolation devices in high radiation areas may be verified by use of administrative means.
Verify the affected Once per 92 days penetration flow path is isolated.
B.
NOTE --------
B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two isolation dampers.
and de-activated automatic damper, closed manual damper, or blind flange.
One or more penetration flow paths with two SCIDs inoperable.
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 of Condition A or B not rinet AND in MODE 1, 2, or 3.
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 /> (continued)
Brunswick Unit 1 3.6-31 Amendment No.
I
SCIDs 3.6.4.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and D.1 NOTE-associated Completion Time LCO 3.0.3 is not applicable.
of Condition A or B not met during movement of recently irradiated fuel assemblies in Suspend movement of Immediately the secondary containment recently irradiated fuel or during OPDRVs.
assemblies in the secondary containment.
AND D.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each automatic SCID is 24 months within limits.
SR 3.6.4.2.2 Verify each automatic SCID actuates to the isolation 24 months position on an actual or simulated actuation signal.
Brunswick Unit 1 3.6-32 Amendment No.
I
SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 APPLICABILITY:
Two SGT subsystems shall be OPERABLE.
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One SGT subsystem A.1 Restore SGT subsystem to 7 days inoperable in MODE 1, 2 or OPERABLE status.
3.
B.
Required Action and B.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 of Condition A not met.
AND OR B.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 /> Two SGT subsystems inoperable in MODE 1, 2, or3.
(continued)
Brunswick Unit 1 3.6-33 Amendment No.
I
SGT System 3.6.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.
One SGT subsystem C.1 Restore SGT subsystem to 31 days inoperable during movement OPERABLE status.
of recently irradiated fuel assemblies in the secondary containment or during OPDRVs.
D.
Required Action and associated Completion Time LCO 3.0.3 is not applicable.
of Condition C not met.
D.1 Place OPERABLE SGT Immediately subsystem in operation.
OR D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.
AND D.2.2 Initiate action to suspend Immediately OPDRVs.
(continued)
Brunswick Unit 1 3.6-34 Amendment No.
I
SGT System 3.6.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E.
Two SGT subsystems E.1
-NOTE inoperable during movement LCO 3.0.3 is not applicable.
of recently irradiated fuel assemblies in the secondary containment or during Suspend movement of Immediately OPDRVs.
recently irradiated fuel assemblies in secondary containment.
AND E.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for > 10 continuous 31 days hours with heaters operating.
SR 3.6.4.3.2 Perform required SGT filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP).
the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or 24 months simulated initiation signal.
Brunswick Unit 1 3.6-35 Amendment No.
I
BSEP 08-0156 Typed Technical Specification Pages - Unit 2
CAD System 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System The requirement for the CAD System is deleted.
I Brunswick Unit 2 3.6-27 Amendment No.
I
Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 APPLICABILITY:
The secondary containment shall be OPERABLE.
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in MODE 1, 2, containment to OPERABLE or 3.
status.
B.
Required Action and B.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 of Condition A not met.
AND B.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 /> C.
Secondary containment C.1 NOTE--
inoperable during movement LCO 3.0.3 is not applicable.
of recently irradiated fuel assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs.
recently irradiated fuel assemblies in the secondary containment.
AND (continued)
Brunswick Unit 2 3.6-28 Amendment No.
I
Secondary Containment 3.6.4.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
(continued)
C.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment equipment hatches 24 months are closed and sealed.
SR 3.6.4.1.2 Verify one secondary containment access door is 24 months closed in each access opening.
SR 3.6.4.1.3 Verify each SGT subsystem can maintain > 0.25 inch 24 months on a of vacuum water gauge in the secondary containment STAGGERED for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate < 3000 cfm.
TEST BASIS Brunswick Unit 2 3.6-29 Amendment No.
I
SCIDs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)
LCO 3.6.4.2 Each SCID shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS
NOTES
- 1.
Penetration flow paths may be unisolated intermittently under administrative controls.
- 2.
Separate Condition entry is allowed for each penetration flow path.
- 3.
Enter applicable Conditions and Required Actions for systems made inoperable by SCIDs.
CONDITION REQUIRED ACTION COMPLETION TIME A.
One or more penetration A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flow paths with one SCID penetration flow path by inoperable, use of at least one closed and de-activated automatic damper, closed manual damper, or blind flange.
AND (continued)
Brunswick Unit 2 3.6-30 Amendment No.
I
SCIDs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2 NOTE-----
Isolation devices in high radiation areas may be verified by use of administrative means.
Verify the affected Once per 92 days penetration flow path is isolated.
B. ---------
NOTE------ B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two isolation dampers.
and de-activated automatic damper, closed manual damper, or blind flange.
One or more penetration flow paths with two SCIDs inoperable.
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 of Condition A or B not met AND in MODE 1, 2, or 3.
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 /> (continued)
Brunswick Unit 2 3.6o31 Amendment No.
I
SCIDs 3.6.4.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and D.1 associated Completion Time LCO 3.0.3 is not applicable.
of Condition A or B not met during movement of recently irradiated fuel assemblies in Suspend movement of Immediately the secondary containment recently irradiated fuel or during OPDRVs.
assemblies in the secondary containment.
AND D.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each automatic SCID is 24 months within limits.
SR 3.6.4.2.2 Verify each automatic SCID actuates to the isolation 24 months position on an actual or simulated actuation signal.
Brunswick Unit 2 3.6-32 Amendment No.
I
SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 APPLICABILITY:
Two SGT subsystems shall be OPERABLE.
MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One SGT subsystem A.1 Restore SGT subsystem to 7 days inoperable in MODE 1, 2 or OPERABLE status.
3.
B.
Required Action and B.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 of Condition A not met.
AND OR B.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 /> Two SGT subsystems inoperable in MODE 1, 2, or3.
(continued)
Brunswick Unit 2 3.6-33 Amendment No.
I
SGT System 3.6.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.
One SGT subsystem C.1 Restore SGT subsystem to 31 days inoperable during movement OPERABLE status.
of recently irradiated fuel assemblies in the secondary containment or during OPDRVs.
D.
Required Action and NOTE-associated Completion Time LCO 3.0.3 is not applicable.
of Condition C not met.
D.1 Place OPERABLE SGT Immediately subsystem in operation.
OR D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.
AND D.2.2 Initiate action to suspend Immediately OPDRVs.
(continued)
Brunswick Unit 2 3.6-34 Amendment No.
I
SGT System 3.6.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E.
Two SGT subsystems E.1 NOTE ---------
inoperable during movement LCO 3.0.3 is not applicable.
of recently irradiated fuel assemblies in the secondary containment or during Suspend movement of Immediately OPDRVs.
recently irradiated fuel assemblies in secondary containment.
AND E.2 Initiate action to suspend Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for > 10 continuous 31 days hours with heaters operating.
SR 3.6.4.3.2 Perform required SGT filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP).
the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or 24 months simulated initiation signal.
Brunswick Unit 2 3.6-35 Amendment No.
I
BSEP 08-0156 Marked-up Technical Specification Bases Pages - Unit I (For Information Only)
Primary Containment Oxygen Concentration B 3.6.3.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1 Primary Containment Oxygen Concentration BASES BACKGROUI4D The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration < 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentra'on.
The,-,.,.,-,apaI-,IIty.tq Ong, h
nrim~ant G-ont~na n*
t FI M~intnin -- 0 ý n
< 4A.0 Wze wer!(9 tegether with the Containmont Atmospor Diluti.on For example, an event that rapidlygenerae hydrogen from zirconium metal water reaction could result in excessive hydrogen in primary containment, but oxygen concentration will remain
<5.0 vlo and no combustion can occur.
eft e!
Ydrogoen onuo xygn*,rom r.dioti
.c.dcompo.ition.of.water ma.
oontuIally
- rhsult in a combuiiblo mixture in rrpmi
' contiinment if the I
`*;'-`S
-*;T`Z*`.-L**Z`ZL*Z AZl****
ir~i uiii.~UUIIIItJI
¶UI WI~iriWF AUUU
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~
AMPVR t-
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,JTwl'h LCO ensures that oxygen concentration does not exceed 4.0 vlo during operation in the applicable conditions.
APPLICABLE The Reference 1 calculations assume that the primary containment is SAFETY ANALYSES inerted when a Design Basis Accident (DBA) loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor c
.-W,/.o produce combustible gas mixtures in the primary continentJ Primary containment oxygen concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).
(continued)
Brunswick Unit 1 B 3.6.3.1-1 Revision No.
Primary Containment Oxygen Concentration B 3.6.3.1 BASES (continued)
LCO The primary containment oxygen concentration is maintained < 4.0 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.
APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODE 1, since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.
Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus.
Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible during a scheduled power reduction to < 15% RTP. As long as reactor power is < 15% RTP, the potential for an event that generates significant hydrogen and oxygen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a startup, or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a scheduled power reduction < 15% RTP, is low enough that these "windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.
ACTIONS A.1 If oxygen concentration is Ž: 4.0 v/o at any time while operating in MODE 1, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is allowed when oxygen concentration is >_ 4.0 vlo because of the availability of other hydro en
",,L..x aen mitigating system
.819 E a
T,,.,..*-*and the low probability and long duration of an event that wou generate significant amounts of hydrogen and oxygen occurring during this period.
(continued)
Brunswick Unit I B 3.6.3.1-2 Revision No. 20-1
CAD System B 3.6.3.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.2 Containment Atmosphere Dilution (CAD) System 3ACK 3OUND The CAD System functions to maintain combustible gas concentr,o'ns
~within the primary containment at or below the flammability limit ollowing
~~a postulated loss of coolant accident (LOCA) by diluting hydrrren and
~oxygen with nitrogen. To ensure that a combustible gas m* jure does not occur, oxygen concentration is kept < 5.0 volume perce (v/o).
e CAD System is manually initiated and consists two 100% capacity su stems. Each subsystem consists of a com n liquid nitrogen supp tank, an electric vaporizer, and connect* piping to supply the Sdrywell
- d suppression chamber volumes. Te liquid nitrogen supply tank and ed tric vaporizers are common amponents which are shared between the riluD subsystems of the units. Piping from the liquid
~nitrogen supply tk downstream of Jhe vaporizers is split and routed to each unit. Each pip to a particul unit is drnded to provide the
- ~~~aaiity to supply ni tgen tth the dr--------well and the suppression concentra Ts below combustible levels.
nindoad uate thepotntialoorChydrgentam oxyga cu l
ise CAlculated (as es f
nc.unction oftm olwingtheeinitiat y ofpteraccidnt)
Thoedasumpios sthate in Reeec rsed to mad izear cname thpessr fedamont ofeapoaht aiti hydrogen and oxygen gnrtd h aclt ofrsta whenthemiitiin systelwcmbstiare acuaedv nacodaclitserec APPLIABLE operatingtproceduresatheopeakdoxgen cndonentr umuation inprm SAFETY ANALY containmeontaismn folwn
- 5. v/oA (Ref.ge 2).ge eerto containment~onti ds<50v Rf )
Brunswick Unit 1 B 3.6.3.2-1 Revision No.4/1
CAD System B 3.6.3.2 BA\\SES APPLICABLE Hydrogen and oxygen may accumulate within primary coo inment SAFETY ANALY S following a LOCA as a result of:
(continued)
- a.
A metal water reaction between the zirconi fuel rod cladding and the reactor coolant; or
- b.
Radiolytic decomposition of water in th Reactor Coolant System.
The D System satisfies Criterion 3 of 10 FR/50.36(c)(2)(ii)(Ref. 3).
LCO The CAD S tem (two CAD subsyste s) must be OPERABLE with an OPERABLE w path capable of suvplying nitrogen to the drywell. This ensures operat n of at least one /AD subsystem in the event of a worst case single activ failure. Oper on of at least one CAD subsystem is designed to maint n primary c ntainment post-LOCA oxygen concentration < 5.0 o for 30 ays.
APPLICAB ILITY In MODE I when prim containment oxygen concentration is required to be < 4.0 v/o (i.e., p ma containment inerted) in accordance with LCO 3.6.3.1, "Prim Cont inment Oxygen Concentration," the CAD System is require to maintai the oxygen concentration within primary containment be w the flamma ility limit of 5.0 v/o following a LOCA.
This ensures at the relative le tightness of primary containment is adequate a prevents damage t safety related equipment and instrument located within primary ontainment.
In MOD 1, when primary containme t oxygen concentration is not requir to be < 4.0 v/o in accordance ith LCO 3.6.3.1, "Primary Con inment Oxygen Concentration," a d in MODE 2, the potential for an ev t that generates significant hydroge and oxygen is low, the primary c tainment need not be inert, and the C System is not required to be PERABLE. Furthermore, the probability an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a startup, or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a scheduled power reduction 15% RTP (i.e., when primary containment oxygen concentration is n t required to be < 4.0 v/o in accordance with LCO 3.6.3.1), is low enough hat these "windows,"
when the primary containment is not inerted and he CAD System is not required to be OPERABLE, are also justified.
Brnwc Uni;t 1 B 3.6.3.2 2 Revision No
CAD System BASESB 3.6.3.2 APPLICABILITY In" ODE 3, both the hydrogen and oxy ~en production rates and (continued) the tal amounts produced after a LO A would be less than those calcul ed for the Design Basis Accid nt LOCA. Thus, if the analysis were to performed starting with a OCA in MODE 3, the time to reach a flamma concentration would b extended beyond the time conservativ calculated for MOD
- 1. The extended time would allow hydrogen rem val from the prima containment atmosphere by other means and also 11ow repair of a inoperable CAD subsystem, if CAD were not availabl Therefore, t e CAD System is not required to be OPERABLE in MO E 3.
In MODES 4 and 5, t prob ility and consequences of a LOCA are reduced due to the pre sure nd temperature limitations of these MODES. Therefore, the System is not required to be OPERABLE in MODES 4 and 5.
ACTIONS A.1 If the CAD System (o e or both bsystems) is inoperable, it must be restored to OPERA E status wit in 31 days. In this Condition, the oxygen control fun ion of the CAD ystem is lost. However, alternate oxygen controlca bilities maybe p vided by the Containment Inerting System. The 31 ay Completion Time is based on the low probability of the occurrence a LOCA that would g erate hydrogen and oxygen in amounts capa e of exceeding the flamm bility limit, the amount of time available afte he event for operator actiro to prevent exceeding this limit, and the avail bility of other hydrogen mitiga *ng systems.
B.1 If Requj ed Action A.1 cannot be met within the sociated Completion
- Time, e plant must be brought to a MODE in whi h the LCO does not appl To achieve this status, the plant must be br ught to at least MO E 2 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The allowed Completion Ti e of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is re onable, based on operating experience, to reach ODE 2 from full p
er conditions in an orderly manner and without ch lenging plant
\\
(continued)
I Qmnwn'ink I mit I R -62:22 Qirion f'n 41 1
CAD System B 3.6.3.2 RQIEE Verifying that there is >_ 4350 gal of liq nitrogen supply in the CAD System will ensure at least 29 days o post-LOCA CAD operation. This inimum volume of liquid nitrogen ows sufficient time after an accident toeplenish the nitrogen supply for ong term inerting. This is verified eve 31 days to ensure that the ystem is capable of performing its intenc d function when require. The 31 day Frequency is based on operati experience, which s shown 31 days to be an acceptable period to rify the liquid nitr gen supply and on the availability of other hydrogen tigating systers.
Verifying the cor ct a' nment for manual, power operated, and automatic valves in each oft AD subsystem flow paths provides assurance that the proper flow pat exist for system operation. This SR does not apply to valves that are c
d, sealed, or otherwise secured in position, since these valves we veri i d to be in the correct position prior to locking, sealing, or se cring.
A valve is al allowed to b in the nonaccident position provided it can be aligned to t e accident positi within the time assumed in the accident analysis.
his is acceptable be ause the CAD System is manually
- itiated, his SR does not apply o valves that cannot be inadvertently misaig dsuch as check valves.
his SR does not require any testing rval manipulation; rather, it invol s verification that those valves capa e of being mispositioned are in e correct position.
Th 31 day Frequency is appropriate be use the valves are operated er procedural control, improper valve p sition would only affect a ingle subsystem, the probability of an even requiring initiation of the system i t
stem 1a manually i0 2ated system.
(continued)
.............. Uni q B 3.6.3.2-4 Rovisiu i No. 4 1
CAD System B 3.6.3.2 BASES SURVEILLANCE REQUIREMENTS (continued)
'ýR 3.6.3.2.3 Cycli each power operated valve, exc ding automatic valves, in the t6 e
s ha ve le te i\\
t s I r CAD stem flow path through one co plete cycle of full travel re en n1c inal Dc v
a' ir rt demons tes; that the valves are me anically OPERABLE and will t
0 tj ons e r 0p gh function w en required. While this urveillance may be performed with the reactor power, the 24 month requency of the Surveillance is rv 11 c w p rl d /e n
I w
intended to) b consistent with ex cted fuel cycle lengths. Operating I
I e
experience has emonstrated t t these components will pass this Surveillance whe performed the 24 month Frequency. Therefore, the tmc t w0 I
- Ian e he e
h 24 m lu, 3
acc pt Frequency was co luded to e acceptable from a reliability standpoint.
REFERENCES
- 1.
Safety Guide 7, ch 1971.
- 2.
UFSAR, Section
..5.3.2.1, Amendment No. 9.
- 3.
10 CFR 50.36 )(2)(ii
- 4.
UFSARTab 6-11.
-r2: k16 DrnwikUnit 4 B 3.6.3.2-5 Rtzviuici i 'Ju. 41
- 1
!F