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Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements
	ML17326B619
Person / Time
Site:	Brunswick
Issue date:	11/22/2017
From:	William Gideon; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 17-0108
	Download: ML17326B619 (58)
	v • d • e

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 November 22, 2017 Serial: BSEP 17-0108 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements Ladies and Gentlemen:

In accordance with 10 CFR 50.90 and 10 CFR 50.91(a)(5), Duke Energy Progress, LLC (Duke Energy), is requesting an emergency amendment associated with Technical Specification (TS) 3.8.1, AC Sources - Operating, for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

Emergency Diesel Generator 4 (EDG 4) was removed from service, in support of planned maintenance, on November 13, 2017, at 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months Eastern Standard Time (EST). Due to the shared electrical distribution system at Brunswick, both Unit 1 and Unit 2 entered TS 3.8.1, Condition D (i.e., one DG inoperable for reasons other than Condition B). If EDG 4 is not restored to operable status by 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months on November 27, 2017, Condition H will be entered and both units will be required to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (i.e., by 1945 hours0.0225 days 0.54 hours 0.00322 weeks 7.400725e-4 months on November 27, 2017).

A one-time, deterministic emergency license amendment is requested to extend the current Completion Time of TS 3.8.1, Required Action D.5, in order to avoid an unnecessary shutdown of both Unit 1 and Unit 2 without a commensurate benefit in nuclear safety. In addition, consistent with defense-in-depth philosophy, Duke Energy is requesting to suspend monthly testing of EDGs 1, 2, and 3 per Surveillance Requirement (SR) 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 during the proposed extended Completion Times, if applicable.

The original scope of work included investigation into the cause of an increasing trend of aluminum in the diesel lubricating oil. The investigation determined that two main bearings were damaged, and a total of five main bearings were replaced to correct the condition. On November 19, 2017, during post-maintenance testing activities, EDG 4 tripped on low lube oil pressure, accompanied by high pressure across the lube oil strainer. Inspections have determined that main bearing 7 was damaged and required replacement. In addition, the investigation identified unacceptable total indicated run-out of the EDG 4 crankshaft, and straightening of the crankshaft is necessary to fully restore the EDG to service. Straightening of the crankshaft will correct the condition leading to the main bearing degradation, and is in progress. The increase in the original work scope will extend the EDG 4 maintenance outage

U.S. Nuclear Regulatory Commission Page 2 of 3 beyond the current TS 3.8.1, Required Action D.5, Completion Time of 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months EST on November 27, 2017, at which time TS 3.8.1, Condition H would be entered requiring both Units to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . It is currently estimated that operability of EOG 4 will be restored by December 13, 2017. Duke Energy is requesting that, on a one-time basis, the Completion Time for TS 3.8.1, Required Action D.5, be extended from 14 days to 30 days. A commensurate change is also proposed to extend the maximum Completion Time of Required Action D.5 associated with discovery of failure to meet LCO 3.8.1.a orb (i.e., from 17 days to 33 days).

Duke Energy is requesting that the NRC review and approve this LAR on an emergency basis in accordance with 10 CFR 50.91 (a)(5). Approval of the proposed amendment is requested by November 26, 2017. This is a one-time, deterministic request that will remain in effect until December 13, 2017, at 0745 EST. If EOG 4 is not operable by this time, both Units 1 and 2 will enter TS 3.8.1, Condition H, and be in Mode 3 no later than December 13, 2017, at 1945 EST.

Surveillance testing of EDGs 1, 2, and 3, per SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6, will resume and be completed within seven days of restoration of EOG 4 operability or by December 20, 2017, whichever occurs first.

If additional emergent issues preclude completion of the ongoing EOG 4 maintenance outage within the proposed Completion Time, a second, risk informed emergency license amendment will be submitted in a timely manner.

In accordance with the Duke Energy Quality Assurance Program Description, the Plant Nuclear Safety Committee has reviewed and concurred with this proposed amendment.

In accordance with 10 CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

The enclosure provides a description and assessment of the proposed change, including a discussion as to the emergency nature of this submittal and why the emergency circumstances are necessitated. Attachments 1 and 2 to the enclosure provide the existing TS pages, for Units 1 and 2, marked to show the proposed change and revised (i.e., typed) TS pages. provides typed Operating License (OL) pages for Units 1 and 2. Attachment 4 provides an evaluation of risk insights related to the proposed amendment.

This document contains no new regulatory commitments.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on skJo November 22, 2017.

William R. Gideon MAT/mat

U.S. Nuclear Regulatory Commission Page 3 of 3

Enclosure:

Description and Assessment of the Proposed Change Attachment 1: Proposed Technical Specification Changes (Mark-Up) - Units 1 and 2 Attachment 2: Revised (Typed) Technical Specification Pages - Units 1 and 2 Attachment 3: Revised (Typed) Operating License Pages - Units 1 and 2 Attachment 4: Risk Insights Related to One-Time Extended Completion Time cc:

U. S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Mark E. Franke, Acting Director Division of Reactor Projects 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Undine Shoop, Chief Plant Licensing Branch II-2 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

BSEP 17-0108 Enclosure Page 1 of 15 Description and Assessment of the Proposed Change

Subject:

Request for Emergency License Amendment Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change / Basis for Emergency Circumstances 2.4 Cause Determination 2.5 Description of Proposed Change

3. TECHNICAL EVALUATION 3.1 Deterministic Evaluation 3.2 Nuclear Risk Insights 3.3 Compensatory Actions

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Proposed Technical Specification Changes (Mark-Up) - Units 1 and 2

2. Revised (Typed) Technical Specification Pages - Units 1 and 2

3. Revised (Typed) Operating License Pages - Units 1 and 2

4. Risk Insights Related to One-Time Extended Completion Time

BSEP 17-0108 Enclosure Page 2 of 15

1.

SUMMARY

DESCRIPTION The proposed one-time deterministic emergency change revises Technical Specification (TS) 3.8.1, AC Sources - Operating, to provide an extension of the Completion Time for Required Action D.5 from 14 days to 30 days. A commensurate change is also proposed to extend the maximum Completion Time of Required Action D.5 associated with discovery of failure to meet LCO 3.8.1.a or b (i.e., from 17 days to 33 days). This provides sufficient time to complete repairs to Emergency Diesel Generator 4 (EDG 4) and avoid an unnecessary shutdown of both Brunswick Steam Electric Plant (BSEP), Units 1 and 2 without a commensurate benefit in nuclear safety.

The need for this emergency license amendment request was unavoidable. Based on information available prior to the ongoing EDG 4 maintenance outage, Duke Energy Progress, LLC (Duke Energy), took prudent action to address an identified elevated aluminum trend in the EDG 4 lubricating oil. The aluminum levels were well below action levels prior to the planned maintenance outage. Planning for the EDG 4 outage included the parts and resources necessary to accomplish the expected scope of work, including main bearing replacements, well within the current TS 3.8.1, Required Action D.5 Completion Times. Identification of a bowed EDG 4 crankshaft has resulted in additional work scope that cannot be completed within the current Completion Time. There was no available data which could have indicated that the EDG 4 crankshaft was bowed.

The extended Completion Times are necessary due to the complex and extensive nature of the work necessary to restore EDG 4 to operable status. This work includes additional bearing replacements as well as the crankshaft repair. Repair of the crankshaft is a first time maintenance activity for BSEP. A specialty vendor service has been contracted to correct the crankshaft bow. This has required additional disassembly within the crankcase to access and correct the condition and coordination of vendor resources and equipment necessary to perform the repairs.

In order to minimize risk, consistent with defense-in-depth philosophy, Duke Energy is also requesting to suspend monthly testing of EDGs 1, 2, and 3 per Surveillance Requirement (SR) 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 during the proposed extended Completion Times.

Performance of SR 3.8.1.2 and SR 3.8.1.3 require the affected EDG to be declared inoperable.

For EDGs 1 and 3, this is a short duration inoperability which occurs when the EDGs are being barred. The existing EDG 2 governor will not automatically return the EDG to ready-to-load operation when the EDG is in manual mode. During performance of SR 3.8.1.2 or SR 3.8.1.3, EDG 2 is in manual mode for approximately four hours. Duke Energy has completed EDG governor upgrades on EDGs 1, 2, and 4; however, the modification has not been completed on EDG 2. SR 3.8.1.6 verifies the fuel oil transfer system transfers fuel oil from the day fuel oil storage tank to the engine mounted tank. This SR is performed in conjunction with the EDG operation when fuel is consumed from the engine mounted tank.

2. DETAILED DESCRIPTION 2.1 System Design and Operation The BSEP Class 1E Electrical Power Distribution System AC sources consist of the offsite power sources (i.e., preferred and alternate power sources), and the onsite standby power sources (i.e., EDGs 1, 2, 3, and 4). The design of the AC electrical power system provides

BSEP 17-0108 Enclosure Page 3 of 15 independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The Class 1E AC distribution system is divided into redundant load groups, so loss of any one group does not prevent the minimum safety functions from being performed. Each load group has access to two offsite power supplies (i.e., one preferred and one alternate) via a balance of plant (BOP) circuit path. This BOP circuit path consists of the BOP bus and the associated circuit path (i.e., master/slave breakers and interconnecting cables) to a 4160 V emergency bus.

Each load group can also be connected to a single EDG.

The onsite standby power source for 4160 V emergency busses E1, E2, E3, and E4 consists of four EDGs. Each EDG is dedicated to its associated emergency bus. An EDG starts automatically on a loss of coolant accident (LOCA) signal from either Unit 1 or Unit 2 or under emergency bus degraded voltage or undervoltage conditions. After the EDG has started, it automatically ties to its respective bus after offsite power is tripped as a consequence of emergency bus undervoltage or degraded voltage, independent of or coincident with a LOCA signal. The EDGs also start and operate in the standby mode without tying to the emergency bus on a LOCA signal alone. Following the trip of offsite power, all loads are stripped from the emergency bus except the 480 V emergency bus. When the EDG is tied to the emergency bus, select safety related loads are then sequentially connected to their respective emergency bus by individual timers associated with each auto-connected load following a permissive from a voltage relay monitoring each emergency bus.

The capability is provided to connect a supplemental diesel generator (SUPP-DG) to supply power to any of the four 4160 V emergency buses via a BOP circuit path. This BOP circuit path consists of the BOP bus and the associated circuit path (i.e., master/slave breakers and interconnecting cables) to a 4160 V emergency bus. The SUPP-DG is commercial-grade and not designed to meet Class 1E requirements. The SUPP-DG is made available to support extended Completion Times in the event of an inoperable EDG. The SUPP-DG is rated at 4000 kW, 4160 V, and can be connected to the 4160 V emergency busses (i.e., E1, E2, E3, or E4) in approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The SUPP-DG is made available as a defense-in-depth alternate source of AC power to one emergency bus to mitigate a station blackout event. The SUPP-DG would remain disconnected from the Class 1E distribution system except for testing or as required during a loss of power condition.

BSEP has also permanently installed two 500 kW FLEX diesel generators. Each is a fully contained system, capable of starting and operating with no reliance on other equipment or systems. Each has an integral 526 gallon sub-base fuel tank, a self-contained, closed loop cooling system, and an exhaust system. Each FLEX diesel generator is sized to supply the Unit 2 Division II and Unit 1 Division II identified critical loads simultaneously. The FLEX diesel generators feed emergency busses E6 and E8 via the new FLEX switchboards. Identified FLEX loads are then fed from E6, E8, and through bus ties, from E5, and E7 using the existing electrical system. The two FLEX switchboards can be cross connected to provide the capabilities of connecting each FLEX diesel generator to Unit 1 and Unit 2 Division II emergency busses E6 and E8. The FLEX critical loads are primarily battery chargers and uninterruptible power supplies (UPS), but other loads may be added as required.

For BSEP, a Station Blackout (SBO) is assumed to occur on only one unit. The non-blackout unit is capable of sharing a single EDG with the blackout unit, after assuming a single failure on the non-blackout unit (i.e., one of the two DGs on the non-blackout unit fails to start). With only

BSEP 17-0108 Enclosure Page 4 of 15 one DG available, it will be necessary to load strip and cross-tie the 4160 V and 480 V substations to provide power to both units. The SUPP-DG is a defense-in-depth measure for SBO. The SUPP-DG is not credited in the SBO analysis. The FLEX Diesel Generators provide the capability to power 480 V emergency busses E6 and E8 in the event of an extended loss of station AC power following a Beyond Design Basis External Event.

2.2 Current Technical Specification Requirements EDG 4 was removed from service, in support of planned maintenance, on November 13, 2017, at 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months Eastern Standard Time (EST). Due to the shared electrical distribution system at Brunswick, both Unit 1 and Unit 2 entered TS 3.8.1, Condition D (i.e., one DG inoperable for reasons other than Condition B). With the SUPP-DG available, EDG 4 must be restored to operable status by 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months EST on November 27, 2017, or Condition H will be entered and both units will be required to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (i.e., by 1945 hours0.0225 days 0.54 hours 0.00322 weeks 7.400725e-4 months on November 27, 2017).

SR 3.8.1.2 verifies that each EDG starts from standby conditions and achieves steady state voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz. The Frequency of SR 3.8.1.2 is "In accordance with the Surveillance Frequency Control Program." The current Frequency for SR 3.8.1.2, in the BSEP Surveillance Frequency Control Program, is 31 days.

SR 3.8.1.3 verifies that each EDG is synchronized and loaded and operates for 60 minutes at a load 2800 kW and 3500 kW. The Frequency of SR 3.8.1.3 is "In accordance with the Surveillance Frequency Control Program." The current Frequency for SR 3.8.1.3, in the BSEP Surveillance Frequency Control Program, is 31 days.

SR 3.8.1.6 verifies that the fuel oil transfer system operates to transfer fuel oil from the day fuel oil storage tank to the engine mounted tank. The Frequency of SR 3.8.1.6 is "In accordance with the Surveillance Frequency Control Program." The current Frequency for SR 3.8.1.6, in the BSEP Surveillance Frequency Control Program, is 31 days.

2.3 Reason for the Proposed Change / Basis for Emergency Circumstances EDG 4 was removed from service, in support of planned maintenance, on November 13, 2017, at 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months EST. The original scope of work included investigation into the cause of an increasing trend of aluminum in the diesel lubricating oil. The elevated trend in aluminum has been at very low levels, well below action level, dating back to 2013. During the planned maintenance window, main bearings 7 and 8 were found degraded. A total of five main bearings were replaced to correct the condition of the bearings. The investigation also identified that the EDG 4 crankshaft has a bow, as indicated by a total runout of 0.010 inches on main bearing 7. This crankshaft bow is believed to have occurred over several years of normal EDG operation, with low levels of bearing heating causing the bowed condition. The wear on bearings 7 and 8 had accommodated this increased crankshaft runout. Replacement of the main bearings, which tightened clearances, during the planned maintenance window revealed the need to also correct the crankshaft bow.

The EDG 4 crankshaft has been evaluated, and the shaft is acceptable for continued operation, pending correction of the excessive runout. The shaft hardness is within specifications, and there are no indications of cracking or excessive shaft heating. A specialty vendor service has been contracted to correct the crankshaft bow in-situ (i.e., inside the crankcase). This has required additional disassembly within the crankcase to access and correct the condition.

BSEP 17-0108 Enclosure Page 5 of 15 Straightening of the crankshaft will correct the condition leading to the main bearing degradation, and is in progress. The increase in the original work scope will extend the EDG 4 maintenance outage beyond the current TS 3.8.1, Condition D, Completion Time of 0745 hours0.00862 days 0.207 hours 0.00123 weeks 2.834725e-4 months EST on November 27, 2017, at which time TS 3.8.1, Condition H would be entered requiring both Units to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

While the sequence to repair the crankshaft and restore the EDG to an operable status is understood, this is a first time performance of this maintenance activity at BSEP. Duke Energy is requesting that, on a one-time basis, the Completion Time for TS 3.8.1, Required Action D.5, be extended from 14 days to 30 days. A commensurate change is also proposed to extend the maximum Completion Time of Required Action D.5 associated with discovery of failure to meet LCO 3.8.1.a or b (i.e., from 17 days to 33 days). The requested Completion Time extensions provide time for the potential for additional discovery issues.

Based on information available prior to the ongoing EDG 4 maintenance outage, Duke Energy took prudent action to address the elevated aluminum trend in the EDG 4 lubricating oil. The aluminum levels were well below action levels prior to the planned maintenance outage.

Planning for the EDG 4 outage included the parts and resources necessary to accomplish the expected scope of work, including main bearing replacements, well within the current TS 3.8.1, Required Action D.5 Completion Times. Identification of the bowed EDG 4 crankshaft has resulted in additional work scope that cannot be completed within the current Completion Time.

There was no available data which could have indicated that the EDG 4 crankshaft was bowed.

Therefore, the need for this emergency license amendment request was unavoidable.

The extended Completion Times are necessary due to the complex and extensive nature of the work necessary to restore EDG 4 to operable status. This work includes additional bearing replacements as well as the crankshaft repair. Repair of the crankshaft is a first time maintenance activity for BSEP. A specialty vendor service has been contracted to correct the crankshaft bow. This has required additional disassembly within the crankcase to access and correct the condition and coordination of vendor resources and equipment necessary to perform the repairs.

If additional emergent issues preclude completion of the ongoing EDG 4 maintenance outage within the proposed Completion Time, a second, risk informed emergency license amendment will be submitted in a timely manner.

2.4 Cause Determination The direct cause of this event is degradation and failure of the affected EDG 4 bearings over time, as evidenced by the increasing aluminum trend in the EDG 4 lubricating oil. Preliminary investigation has indicated that two events in 2009 (i.e., EDG 4 overspeed and overload) put a higher than normal stress on the rotating mass of EDG 4. This is believed to be the initiator leading to the condition causing bearing degradation over time. Lubricating oil trends have been reviewed for all EDGs, and no other EDGs have any indications of elevated lead or aluminum (i.e., which would be indicative of EDG bearing degradation), or other adverse performance trends. As such, there is no similar degraded condition of other EDG bearings or crankshafts and no common cause exists.

BSEP 17-0108 Enclosure Page 6 of 15 2.5 Description of the Proposed Change The proposed change adds the following Note to the Completion Time for TS 3.8.1, Required Action D.5.

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

Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, the 14 day and 17 day Completion Times are extended to 30 days and 33 days, respectively.

Duke Energy is also requesting to suspend monthly testing of EDGs 1, 2, and 3 per SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 during the period when EDG 4 is inoperable. Because the surveillances are being suspended rather than extending their Frequencies, the proposed change adds notes, similar to the following, to each of the affected SRs.

NOTE(S)---------------------------------------------

Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR [3.8.1.2] for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

The specific changes to the Unit 1 and 2 TSs are provided in the marked-up and retyped TS pages provided in Attachments 1 and 2, respectively.

3. TECHNICAL EVALUATION 3.1 Deterministic Evaluation During the proposed Completion Time extensions, Units 1 and 2 will be in Mode 1. Neither EDGs 1, 2, and 3 or offsite power sources are affected by the EDG 4 maintenance and are operable. As such, sufficient offsite power supplies remain available to complete their intended safety function. The SUPP-DG, installed to support a 14 day completion time for an inoperable EDG, is available. The SUPP-DG is rated at 4000 kW, 4160 V, and can be connected to the 4160 V emergency busses (i.e., E1, E2, E3, or E4) in approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In addition, BSEP has two permanently installed FLEX diesels. Each FLEX diesel is rated at 500 kW, 480 V, and can be connected to the 480 V emergency busses (i.e., E6 or E8) in less than one hour.

EDG capacity is such that any three of the four diesels can supply all required loads for the safe shutdown of one unit and a design basis accident on the other unit without offsite power. Each of the four EDGs can supply one of the four separate Class 1E emergency buses. Each is started automatically on a loss of offsite power (LOOP) or LOCA. The EDG arrangement provides adequate capacity to supply the ESF loads for the Design Basis Accident, assuming the failure of a single active component in the system.

Since the EDGs can accommodate a single failure, the one-time extension of the Completion Times for an inoperable EDG has no impact on the system design basis. Safety analyses acceptance criteria as provided in the Updated Final Safety Analysis Report (UFSAR) are not

BSEP 17-0108 Enclosure Page 7 of 15 impacted by this change. AC power sources credited in the accident analyses will remain the same.

To ensure that the single failure design criterion is met, LCOs are specified in the plant TS requiring all redundant components of the onsite power system to be operable. In the event that a EDG is inoperable in Modes 1, 2, and 3, existing TS 3.8.1 Condition D requires verification of the operability of the offsite circuits on a more frequent basis. When the required redundancy is not maintained, action is required within the specified Completion Times to initiate a plant shutdown. The Completion Time provides a limited time to restore equipment to operable status and represents a balance between the risk associated with continued plant operation with less than the required system or component redundancy and the risk associated with initiating a plant transient while transitioning the unit to a shutdown condition. Thus, the acceptability of the maximum length of the extended Completion Time interval relative to the potential occurrences of design basis events is considered. Since extending the Completion Times for a single inoperable EDG does not change the design basis for the standby emergency power system (i.e., EDGs), the one-time extension of the Required Action D.5 Completion Times is acceptable.

BSEPs coping time during SBO is not affected by the proposed change. The coping time is calculated based on guidance provided in Nuclear Utility Management and Resource Council (NUMARC) 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, Revision 1, August 1991 (i.e., Reference 1). During a SBO, the most significant requirement is to quickly restore AC power to the 125 VDC battery chargers. To extend battery capacity to the four hour coping duration, battery chargers are required to be energized within one hour by one of the following methods:

Cross-tying of 4160 volt emergency buses with the non blacked out unit, powered from offsite power or EDGs, and if necessary cross-tie 480 V emergency buses Aligning a FLEX diesel generator to the Division II 480 V emergency bus and if necessary cross-tie 480 V emergency buses Aligning the Supplemental diesel generator o Via the BOP 4160 V bus to the associated 4160 V emergency bus o If necessary, cross-tie to the other unit's 4160 V emergency bus o If necessary, cross-tie 480 V emergency buses To accomplish the above, SBO flow charts and associated text procedures provide instructions for coping with a SBO or an Extended Loss of All AC Power (ELAP) when no EDGs are available, when one EDG is available, when two EDGs are available, or when offsite power is available to one unit, supplying either one or two 4160 V emergency buses. These coping methodologies are not changed by the proposed one-time extension of the Required Action D.5 Completion Times. If an offsite power source or an additional EDG becomes inoperable or if the SUPP-DG becomes unavailable during the proposed Completion Time extensions, the appropriate TS 3.8.1 Condition will be entered and Required Actions taken.

The proposed suspension of SR 3.8.1.2 and SR 3.8.1.3 testing requirements during the proposed extended Completion Times minimizes risk by maintaining defense-in-depth.

Performance of SR 3.8.1.2 or SR 3.8.1.3 requires the affected EDG to be declared inoperable.

For EDGs 1 and 3, this is a short duration inoperability which occurs when the EDGs are being

BSEP 17-0108 Enclosure Page 8 of 15 barred. The existing EDG 2 governor will not automatically return the EDG to ready-to-load operation when the EDG is in manual mode. During performance of SR 3.8.1.2 or SR 3.8.1.3, EDG 2 is in manual mode for approximately four hours. With EDG 4 inoperable, a second EDG made inoperable for testing requires both Unit 1 and Unit 2 to enter TS 3.8.1, Condition G. If the EDG being tested is not restored to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , Condition H would be entered and both units would be required to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . SR 3.8.1.6 verifies the fuel oil transfer system transfers fuel oil from the day fuel oil storage tank to the engine mounted tank. This SR is performed in conjunction with the EDG operation when fuel is consumed from the engine mounted tank. This amendment requests that these Surveillance Requirements for EDG 1, 2, and 3 be suspended during the proposed extended Completion Times.

3.2 Nuclear Risk Insights The proposed amendment is a one-time, deterministic emergency license amendment to extend the 14 day and 17 day Completion Times associated with TS 3.8.1, Required Action D.5. The risk of the extended completion time has been assessed and will be managed in accordance with the requirements of 10 CFR 50.65(a)(4) and Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants (i.e., Reference 2).

The change is based upon the defense-in-depth guidance of NUREG-0800, Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions.(i.e., Reference 3). Therefore, it is not a risk-informed request and a risk evaluation was not needed. However, to provide additional information, Duke Energy is providing risk insights related to the proposed Completion Time change. Duke Energy has calculated the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) for the plant-specific configuration that includes the proposed Completion Time extension for EDG 4. Based on the risk evaluation, the 30 day Unit 2 ICCDP and ICLERP are 1.86E-07 and 4.06E-09, respectively. Unit 2 is bounding with respect to the proposed Required Action D.5 Completion Time extensions. These risk values are below the risk acceptance guidelines in Regulatory Guide 1.177, An Approach for Plant-Specific, Risk Informed Decisionmaking: Technical Specifications, Revision 1 (i.e.,

Reference 4). Based on these results, the risk evaluation for the proposed Completion Time extension for EDG 4 is acceptable for the purposes of supporting the deterministic evaluation.

The NRC has previously reviewed the technical adequacy of the BESP Probabilistic Risk Assessment (PRA) models identified in this application, with routine maintenance updates applied, for:

Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program, approved on May 24, 2017, ADAMS Accession No. ML17096A129, cited the Internal Events, Internal Flood, Fire, External Flood, and High Winds models. (i.e.,

Reference 5)

License Amendment to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, approved on January 28, 2015, ADAMS Accession No. ML14310A808. (i.e., Reference 6)

The overall risk of not performing SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 during the period of EDG 4 inoperability is minimal. The time period is short and historical routine performances of these surveillances have demonstrated good performance of the EDGs. There is no indication

BSEP 17-0108 Enclosure Page 9 of 15 of degraded performance of EDGs 1, 2, or 3. The proposed suspension of performing the SRs is consistent with the philosophy of SR 3.0.3 in that it is based on the consideration of unit conditions and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the requirements.

3.3 Compensatory Actions The following compensatory measures were implemented to support proposed extended Completion Times of Required Action D.5. They will remain in place during the proposed extended Completion Time.

Diesel Generators 1, 2, and 3 shall be protected during the extended EDG Completion Times authorized by the proposed license amendment.

The SUPP-DG, FLEX diesel generators, station batteries, battery chargers, switchyard, and transformer yard shall be protected, as defense-in-depth, during the extended EDG Completion Times authorized by the proposed license amendment.

Component testing or maintenance of safety systems in the off-site power systems and important non-safety equipment in the off-site power systems which can increase the likelihood of a plant transient or LOOP, as determined by plant management, will be avoided during the extended EDG Completion Times authorized by the proposed license amendment.

Discretionary switchyard maintenance shall not be allowed during the extended EDG Completion Times authorized by the proposed licensed amendment.

The High Pressure Coolant Injection (HPCI) pump, Reactor Core Isolation Cooling (RCIC) pump, and the Residual Heat Removal (RHR) pump associated with the operable EDG will not be removed from service for elective maintenance activities during the extended EDG Completion Times authorized by the proposed license amendment.

The system load dispatcher shall be contacted once per day to determine if any significant grid perturbations (i.e., high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended Completion Times authorized by the proposed license amendment. If significant grid perturbations are expected, station managers will assess the conditions and determine the best course for the plant.

During the extended EDG Completion Times authorized by the proposed license amendment, weather conditions shall be monitored each shift to determine if forecasts are predicting severe weather conditions (e.g., thunderstorm or tornado warnings). If severe weather is expected, station managers will assess the conditions and determine the best course for the plant.

Additionally, the following compensatory actions associated with the Operations staff will be implemented during the proposed extended Completion Times of Required Action D.5.

During the extended EDG Completion Times authorized by the proposed license amendment, designated non-licensed operators (NLOs) shall be briefed, each shift, regarding cross tying the 4160 V emergency bus E2 to 4160 V emergency bus E4 per plant procedure 0AOP-36.1, Loss of Any 4kV OR 480V Bus.

BSEP 17-0108 Enclosure Page 10 of 15 During the extended EDG Completion Times authorized by the proposed license amendment, designated NLOs will be briefed, each shift, regarding cross-tying 480 V E7 bus to the 480 V E8 bus per 0AOP-36.1, Loss of Any 4kV OR 480V Bus.

During the extended EDG Completion Times authorized by the proposed license amendment, designated NLOs will be briefed, each shift, regarding starting and tying the SUPP-DG to 4160 V emergency bus E4 per plant procedure 0EOP-01-SBO-08, Supplemental DG Alignment.

During the extended EDG Completion Times authorized by the proposed license amendment, designated NLOs will be briefed, each shift, regarding load shed procedures and alignment of the FLEX diesel generators.

During the extended EDG Completion Times authorized by the proposed license amendment, a continuous fire watch shall be established for the Unit 1 and Unit 2 Cable Spread Rooms and for the Balance of Plant busses in the Unit 1 and Unit 2 Turbine Building 20 foot elevations.

During the extended EDG Completion Times authorized by the proposed license amendment, the FLEX pump and FLEX Unit 2 hose trailer shall be staged at the south side of the Unit 2 Condensate Storage Tank to support rapid deployment in the event the FLEX pump is needed for Unit 2 inventory control.

For the compensatory measures described above, Duke Energy is providing operating license conditions to be included in Appendix B, Additional Conditions, of the Renewed Facility Operating Licenses for BSEP, Units 1 and 2. These license conditions describe compensatory measures being implemented during the proposed extended Completion Time. Attachment 3 to this letter provides the updated Operating License, Appendix B pages for each unit.

Consistent with the Bases for TS 3.8.1, Required Action D.2, the SUPP-DG availability was verified within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of entering the 14 day Completion Time and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

SUPP-DG availability requires that:

The load test has been performed within 30 days of entry into the extended Completion Time.

The SUPP-DG fuel tank test is verified locally to be greater than or equal to a 24-hour supply; and SUPP-DG supporting system parameters for starting and operating are verified to be within required limits for functional availability.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c)(2)(ii), stipulates that a TS Limiting Condition for Operation must be established for each item meeting one or more of the following criteria:

1. Installed instrumentation that is used to detect, and indicate in the Control Room, a significant abnormal degradation of the reactor coolant pressure boundary.

BSEP 17-0108 Enclosure Page 11 of 15

2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to the integrity of a fission product barrier.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. A structure, system, or component which operating experience or PRA has shown to be significant to public health and safety.

The proposed changes do not modify any plant equipment that provides emergency power to the safety-related emergency buses. Evaluation of the proposed changes has determined that the reliability of AC electrical sources is not significantly affected by the proposed changes and that applicable regulations and requirements continue to be met.

The BSEP design was reviewed for construction under the General Design Criteria for Nuclear Power Plant Construction, issued for comment by the AEC in July 1967 and is committed to meet the intent of the General Design Criteria (GDC), published in the Federal Register on May 21, 1971, as Appendix A to 10 CFR Part 50. GDC 17 requires that that nuclear power plants have onsite and offsite electric power systems to permit the functioning of SSCs that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. The proposed change does not affect BSEP's compliance with the intent of GDC 17.

GDC 18, Inspection and testing of electric power systems, states that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing of important areas and features, such as insulation and connections to assess the continuity of the systems and the condition of their components. The proposed change does not affect BSEPs compliance with the intent of GDC 18.

Section 50.63(a) of 10 CFR, "Loss of all alternating current power," requires that each lightwater-cooled nuclear power plant licensed to operate be able to withstand for a specified duration and recover from a station blackout. The proposed change does not affect BSEP's compliance with 10 CFR 50.63(a).

NUREG-0800, Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions, provides guidance to the NRC staff in reviewing amendment requests for licensees proposing a one-time or permanent TS change to extend an EDG Completion Times to beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The BTP 8-8 emphasizes that more defense-in-depth is needed for SBO scenarios which are more likely to occur as compared to the likely occurrence of the large and medium size LOCA scenarios. The proposed amendment is consistent with the guidance of BTP 8-8.

Therefore, based on the considerations discussed above:

1. There is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner;

BSEP 17-0108 Enclosure Page 12 of 15

2. Such activities will be conducted in compliance with the Commission's regulations; and

3. Issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Duke Energy has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the TS, and does not affect conformance with the intent of any GDC differently than described in the Safety Analysis Report.

4.2 Precedent The proposed license amendment was developed using relevant information from an approved change (i.e., Reference 7) at another nuclear station.

4.3 No Significant Hazards Consideration Determination Analysis Duke Energy Progress, LLC (Duke Energy), is requesting that, on a one-time basis, the Completion Time for Technical Specification 3.8.1, Required Action D.5, be extended from 14 days to 30 days. A commensurate change is also proposed to extend the maximum Completion Time of Required Action D.5 (i.e., from 17 days to 33 days). In addition, Duke Energy is requesting to suspend monthly testing of EDGs 1, 2, and 3 per Surveillance Requirement (SR) 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 during the proposed extended Completion Times.

Duke Energy has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) 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 license amendment provides a deterministic one-time 30 day Completion Time allowance in TS 3.8.1, Required Action D.5 for one EDG and a commensurate change to extend the maximum Completion Time of Required Action D.5 (i.e., from 17 days to 33 days) and suspension of SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6. These changes will have no effect on accident probabilities since the EDGs are not considered accident initiators. The proposed Completion Times and surveillance suspension do not require any physical plant modifications. Since no individual precursors of an accident are affected, the proposed amendment does not increase the probability of a previously analyzed event.

The consequences of an evaluated accident are determined by the operability of plant systems designed to mitigate those consequences. The EDGs are backup power to components that mitigate the consequences of accidents. The current TSs permit a single EDG to be inoperable for up to 14 days. This is acceptable provided the Supplemental Diesel Generator is available. The proposed license amendment extends the current Completion Times for EDG 4, on a one-time basis, to no more than a total of 30 days with a corresponding maximum completion time of 33 days. The proposed change does not affect any of the assumptions used in deterministic safety analysis. Likewise, the

BSEP 17-0108 Enclosure Page 13 of 15 temporary suspension of SR 3.8.1.2, SR 3.8.1.3 and SR 3.8.1.6 has no impact on any of the assumptions used in deterministic safety analysis Granting the proposed change will not adversely affect the consequences of an accident previously evaluated.

Therefore, the proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No Creation of the possibility of a new or different kind of accident requires creating one or more new accident precursors. New accident precursors may be created by modifications of plant configuration, including changes in allowable modes of operation.

The proposed amendment provides a deterministic one-time allowance of a 30 day Completion Time for TS 3.8.1, Required Action D.5 and a commensurate change to extend the maximum Completion Time of Required Action D.5 (i.e., from 17 days to 33 days). In conjunction, the proposed amendment provides a temporary suspension of SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6. These changes do not involve a modification or the physical configuration of the plant (i.e., no new equipment will be installed), create any new failure modes for existing equipment, or create any new limiting single failures. The plant equipment considered available when evaluating the existing Completion Times remains unchanged. The extended Completion Times and the temporary suspension of SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 will permit completion of repair activities without incurring transient risks associated with performing a dual unit shutdown with the EDG unavailable.

Therefore, the proposed amendments do 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 license amendment provides a deterministic one-time allowance of a 30 day Completion Time for TS 3.8.1, Required Action D.5. A commensurate change is also proposed to extend the maximum Completion Time of Required Action D.5 (i.e., from 17 days to 33 days). A deterministic evaluation of the proposed Completion Times demonstrates there is sufficient margin to safety during the extended EDG Completion Time period. During the extended completion times, sufficient compensatory measures including availability of the Supplemental Diesel Generator will be established to maintain the defense-in-depth design philosophy to ensure the electrical power system meets its design safety function. The Supplemental Diesel Generator has the capacity to bring an affected unit to cold shutdown, if needed.

The overall risk of not performing SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 during the extended Completion Times is minimal and is consistent with defense-in-depth philosophy. The time period of the temporary suspension is short and historical routine performances of SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 have demonstrated good

BSEP 17-0108 Enclosure Page 14 of 15 performance of the EDGs. The proposed suspension of performing SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.6 is consistent with the philosophy of SR 3.0.3 in that it is based on the consideration of unit conditions and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the requirements.

Therefore, the proposed amendments do not result in a significant reduction in the margin of safety.

Based on the above, Duke Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents 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.

6. REFERENCES

1. Nuclear Utility Management and Resource Council (NUMARC) 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, Revision 1, August 1991

2. Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3, dated May 2012

3. NUREG-0800, Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions, dated February 2012 (i.e., ADAMS Accession No. ML113640138)

4. Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications, Revision 1, dated May 2011

5. Letter from the NRC to BSEP, Issuance of Amendments Regarding request to Relocate Specific Surveillance Frequencies to Licensee Controlled Program, May 24, 2017 (ADAMS Accession No. ML ML17096A129)

BSEP 17-0108 Enclosure Page 15 of 15

6. Letter from NRC to BSEP, Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance With 10 CFR 50.48(c), dated January 28, 2015, (ADAMS Accession Number ML14310A808)

7. Letter from NRC to Palo Verde Nuclear Generating Station, Unit 3, Issuance of Amendment Regarding Revision to Technical Specification 3.8.1, "AC [Alternating Current] Sources - Operating" (Emergency Circumstances), dated December 23, 2016, (ADAMS Accession Number ML16358A676)

BSEP 17-00108 Enclosure Attachment 1 Proposed Technical Specification Changes (Mark-Up)

Units 1 and 2

AC SourcesOperating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE ---------NOTE----------

status. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, the 14 day and 17 day Completion Times are extended to 30 days and 33 days, respectively.

7 days from discovery of unavailability of SUPP-DG AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure to meet LCO 3.8.1.a or b (continued)

Brunswick Unit 1 3.8-5 Amendment No. 264

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 -------------------------------NOTES-------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

3. A single test at the specified Frequency will satisfy this Surveillance for both units.

4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage 3750 V and 4300 V the Surveillance and frequency 58.8 Hz and 61.2 Hz. Frequency Control Program (continued)

Brunswick Unit 1 3.8-7 Amendment No. 276

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------------------NOTES-------------------------------

1. DG loadings may include gradual loading.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

5. A single test at the specified Frequency will satisfy this Surveillance for both units.

6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG is synchronized and loaded and In accordance with operates for 60 minutes at a load 2800 kW and the Surveillance 3500 kW. Frequency Control Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of In accordance with fuel oil. the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance with engine mounted tank. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.8-8 Amendment No. 276

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------

Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from the day fuel oil storage tank to the engine the Surveillance mounted tank. Frequency Control Program SR 3.8.1.7 -------------------------------NOTES------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each DG starts from standby condition and In accordance with achieves, in 10 seconds, voltage 3750 V and the Surveillance frequency 58.8 Hz, and after steady state conditions Frequency Control are reached, maintains voltage 3750 V and 4300 V Program and frequency 58.8 Hz and 61.2 Hz.

(continued)

Brunswick Unit 1 3.8-9 Amendment No. 276

AC SourcesOperating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE ---------NOTE----------

status. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, the 14 day and 17 day Completion Times are extended to 30 days and 33 days, respectively.

7 days from discovery of unavailability of SUPP-DG AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure to meet LCO 3.8.1.a or b (continued)

Brunswick Unit 2 3.8-5 Amendment No. 292

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 -------------------------------NOTES-------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

3. A single test at the specified Frequency will satisfy this Surveillance for both units.

4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage 3750 V and 4300 V the Surveillance and frequency 58.8 Hz and 61.2 Hz. Frequency Control Program (continued)

Brunswick Unit 2 3.8-7 Amendment No. 304

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 ----------------------------NOTES----------------------------------

1. DG loadings may include gradual loading.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

5. A single test at the specified Frequency will satisfy this Surveillance for both units.

6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG is synchronized and loaded and In accordance with operates for 60 minutes at a load 2800 kW and the Surveillance 3500 kW. Frequency Control Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of In accordance with fuel oil. the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance with engine mounted tank. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.8-8 Amendment No. 304

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------

Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from the day fuel oil storage tank to the engine the Surveillance mounted tank. Frequency Control Program SR 3.8.1.7 ----------------------------NOTES----------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each DG starts from standby condition and In accordance with achieves, in 10 seconds, voltage 3750 V and the Surveillance frequency 58.8 Hz, and after steady state conditions Frequency Control are reached, maintains voltage 3750 V and 4300 V Program and frequency 58.8 Hz and 61.2 Hz.

(continued)

Brunswick Unit 2 3.8-9 Amendment No. 304

BSEP 17-00108 Enclosure Attachment 2 Revised (Typed) Technical Specification Pages Units 1 and 2

AC SourcesOperating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE ---------NOTE----------

status. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, the 14 day and 17 day Completion Times are extended to 30 days and 33 days, respectively.

7 days from discovery of unavailability of SUPP-DG AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure to meet LCO 3.8.1.a or b (continued)

Brunswick Unit 1 3.8-5 Amendment No. 264

AC SourcesOperating 3.8.1 ACTIONS (continued)

E. Two or more offsite circuits E.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable for reasons other inoperable when the discovery of than Condition B. redundant required Condition E feature(s) are inoperable. concurrent with inoperability of redundant required feature(s)

AND E.2 Restore all but one offsite 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months circuit to OPERABLE status.

(continued)

Brunswick Unit 1 3.8-5a Amendment No. XXX

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 -------------------------------NOTES------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

3. A single test at the specified Frequency will satisfy this Surveillance for both units.

4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage 3750 V and 4300 V the Surveillance and frequency 58.8 Hz and 61.2 Hz. Frequency Control Program (continued)

Brunswick Unit 1 3.8-7 Amendment No. 276

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------------------NOTES------------------------------

1. DG loadings may include gradual loading.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

5. A single test at the specified Frequency will satisfy this Surveillance for both units.

6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

In accordance with Verify each DG is synchronized and loaded and the Surveillance operates for 60 minutes at a load 2800 kW and Frequency Control 3500 kW.

Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of In accordance with fuel oil. the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance with engine mounted tank. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.8-8 Amendment No. 276

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------

Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from the day fuel oil storage tank to the engine the Surveillance mounted tank. Frequency Control Program SR 3.8.1.7 -------------------------------NOTES------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each DG starts from standby condition and In accordance with achieves, in 10 seconds, voltage 3750 V and the Surveillance frequency 58.8 Hz, and after steady state conditions Frequency Control are reached, maintains voltage 3750 V and 4300 V Program and frequency 58.8 Hz and 61.2 Hz.

(continued)

Brunswick Unit 1 3.8-9 Amendment No. 276

AC SourcesOperating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE ---------NOTE----------

status. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, the 14 day and 17 day Completion Times are extended to 30 days and 33 days, respectively.

7 days from discovery of unavailability of SUPP-DG AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure to meet LCO 3.8.1.a or b (continued)

Brunswick Unit 2 3.8-5 Amendment No. 292

AC SourcesOperating 3.8.1 ACTIONS (continued)

E. Two or more offsite circuits E.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable for reasons other inoperable when the discovery of than Condition B. redundant required Condition E feature(s) are inoperable. concurrent with inoperability of redundant required feature(s)

AND E.2 Restore all but one offsite 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months circuit to OPERABLE status.

(continued)

Brunswick Unit 2 3.8-5a Amendment No. XXX

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 ----------------------------NOTES----------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

3. A single test at the specified Frequency will satisfy this Surveillance for both units.

4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage 3750 V and 4300 V the Surveillance and frequency 58.8 Hz and 61.2 Hz. Frequency Control Program (continued)

Brunswick Unit 2 3.8-7 Amendment No. 304

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 ----------------------------NOTES----------------------------------

1. DG loadings may include gradual loading.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

5. A single test at the specified Frequency will satisfy this Surveillance for both units.

6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify each DG is synchronized and loaded and In accordance with operates for 60 minutes at a load 2800 kW and the Surveillance 3500 kW. Frequency Control Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of In accordance with fuel oil. the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance with engine mounted tank. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.8-8 Amendment No. 304

AC SourcesOperating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------

Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 4 operability or December 20, 2017, whichever occurs first.

Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from the day fuel oil storage tank to the engine the Surveillance mounted tank. Frequency Control Program SR 3.8.1.7 ----------------------------NOTES----------------------------------

1. All DG starts may be preceded by an engine prelube period.

2. A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each DG starts from standby condition and In accordance with achieves, in 10 seconds, voltage 3750 V and the Surveillance frequency 58.8 Hz, and after steady state conditions Frequency Control are reached, maintains voltage 3750 V and 4300 V Program and frequency 58.8 Hz and 61.2 Hz.

(continued)

Brunswick Unit 2 3.8-9 Amendment No. 304

BSEP 17-00108 Enclosure Attachment 3 Revised (Typed) Operating License Pages - Units 1 and 2

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 282, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 282

3. Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 282, are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Additional Conditions.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1. Unit 1 - Technical Specifications - Appendices A and B Date of Issuance: June 26, 2006 Renewed License No. DPR-71 Amendment No. 282

Amendment Additional Conditions Implementation Number Date 262 The fuel channel bow standard deviation Upon implementation of component of the channel bow model Amendment No. 262.

uncertainty used by ANP-10307PA, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors (i.e., TS 5.6.5.b.11) to determine the Safety Limit Minimum Critical Power Ratio shall be increased by the ratio of channel fluence gradient to the nearest channel fluence gradient bound of the channel measurement database, when applied to channels with fluence gradients outside the bounds of the measurement database from which the model uncertainty is determined.

282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, Diesel Amendment No. 282.

Generators 1, 2, and 3 shall be protected.

282 The SUPP-DG, FLEX diesel generators, station Upon implementation of batteries, battery chargers, switchyard, and Amendment No. 282.

transformer yard shall be protected, as defense-in-depth, during the extended EDG Completion Times authorized by Amendment No. 282.

282 Component testing or maintenance of safety Upon implementation of systems in the off-site power systems and Amendment No. 282.

important non-safety equipment in the off-site power systems which can increase the likelihood of a plant transient or LOOP, as determined by plant management, will be avoided during the extended EDG Completion Times authorized by Amendment No. 282.

282 Discretionary switchyard maintenance shall not Upon implementation of be allowed during the extended EDG Amendment No. 282.

Completion Times authorized by Amendment No. 282.

Brunswick Unit 1 App. B-2 Amendment No. 282

Amendment Additional Conditions Implementation Number Date 282 The High Pressure Coolant Injection (HPCI) Upon implementation of pump, Reactor Core Isolation Cooling (RCIC) Amendment No. 282.

pump, and the Residual Heat Removal (RHR) pump associated with the operable EDGs will not be removed from service for elective maintenance activities during the extended EDG Completion Times authorized by Amendment No. 282.

282 The system load dispatcher shall be contacted Upon implementation of once per day to determine if any significant grid Amendment No. 282.

perturbations (i.e., high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended Completion Times authorized by Amendment No. 282. If significant grid perturbations are expected, station managers will assess the conditions and determine the best course for the plant.

282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, weather Amendment No. 282.

conditions shall be monitored each shift to determine if forecasts are predicting severe weather conditions (e.g., thunderstorm or tornado warnings). If severe weather is expected, station managers will assess the conditions and determine the best course for the plant.

282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, designated Amendment No. 282.

non-licensed operators (NLOs) shall be briefed, each shift, regarding cross tying the 4160 V emergency bus E2 to 4160 V emergency bus E4 per plant procedure 0AOP-36.1, Loss of Any 4kV OR 480V Bus.

Brunswick Unit 1 App. B-3 Amendment No. 282

Amendment Additional Conditions Implementation Number Date 282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, designated Amendment No. 282.

NLOs will be briefed, each shift, regarding cross-tying 480 V E7 bus to the 480 V E8 bus per 0AOP-36.1, Loss of Any 4kV OR 480V Bus.

282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, designated Amendment No. 282.

NLOs will be briefed, each shift, regarding starting and tying the SUPP-DG to 4160 V emergency bus E4 per plant procedure 0EOP-01-SBO-08, Supplemental DG Alignment.

282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, designated Amendment No. 282.

NLOs will be briefed, each shift, regarding load shed procedures and alignment of the FLEX diesel generators.

282 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 282, a Amendment No. 282.

continuous fire watch shall be established for the Unit 1 Cable Spread Room and for the Balance of Plant busses in the Unit 1 Turbine Building 20 foot elevation.

Brunswick Unit 1 App. B-4 Amendment No. 282

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 310, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 310

M. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(1) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (2) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (3) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders N. The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

3. Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 310, are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Additional Conditions.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1. Unit 2 - Technical Specifications - Appendices A and B Date of Issuance: June 26, 2006 Renewed License No. DPR-62 Amendment No. 310

Amendment Number Additional Conditions Implementation Date 276 Upon implementation of Amendment No. 276 As described in adopting TSTF-448, Revision 3, the determination paragraphs (a), (b),

of control room envelope (CRE) unfiltered air and (c) of this inleakage as required by SR 3.7.3.3, in accordance Additional Condition.

with TS 5.5.13.c.(i), the assessment of CRE habitability as required by Specification 5.5.13.c.(ii),

and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met.

Following implementation:

(a) The first performance of SR 3.7.3.3, in accordance with Specification 5.5.13.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from June 11, 2004, the date of the most recent successful tracer gas test.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.13.c.(ii), shall be within the next 9 months.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.13.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test.

290 The fuel channel bow standard deviation Upon implementation of component of the channel bow model uncertainty Amendment No. 290 used by ANP-10307PA, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors (i.e.,

TS 5.6.5.b.11) to determine the Safety Limit Minimum Critical Power Ratio shall be increased by the ratio of channel fluence gradient to the nearest channel fluence gradient bound of the channel measurement database, when applied to channels with fluence gradients outside the bounds of the measurement database from which the model uncertainty is determined.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, Diesel Amendment No. 310.

Generators 1, 2, and 3 shall be protected.

Brunswick Unit 2 App. B-2 Amendment No. 310

Amendment Number Additional Conditions Implementation Date 310 The SUPP-DG, FLEX diesel generators, station Upon implementation of batteries, battery chargers, switchyard, and Amendment No. 310.

transformer yard shall be protected, as defense-in-depth, during the extended EDG Completion Times authorized by Amendment No. 310.

310 Component testing or maintenance of safety Upon implementation of systems in the off-site power systems and Amendment No. 310.

important non-safety equipment in the off-site power systems which can increase the likelihood of a plant transient or LOOP will be avoided during the extended EDG Completion Times authorized by Amendment No. 310.

310 Discretionary switchyard maintenance shall not be Upon implementation of allowed during the extended EDG Completion Amendment No. 310.

Times authorized by Amendment No. 310.

310 The High Pressure Coolant Injection (HPCI) pump, Upon implementation of Reactor Core Isolation Cooling (RCIC) pump, and Amendment No. 310.

the Residual Heat Removal (RHR) pump associated with the operable EDGs will not be removed from service for elective maintenance activities during the extended EDG Completion Times authorized by Amendment No. 310.

310 The system load dispatcher shall be contacted Upon implementation of once per day to determine if any significant grid Amendment No. 310.

perturbations (i.e., high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended Completion Times authorized by Amendment No. 310. If significant grid perturbations are expected, station managers will assess the conditions and determine the best course for the plant.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, weather Amendment No. 310.

conditions shall be monitored each shift to determine if forecasts are predicting severe weather conditions (e.g., thunderstorm or tornado warnings). If severe weather is expected, station managers will assess the conditions and determine the best course for the plant.

Brunswick Unit 2 App. B-3 Amendment No. 310

Amendment Number Additional Conditions Implementation Date 310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, dedicated non- Amendment No. 310.

licensed operators (NLOs) shall be briefed, each shift, regarding cross tying the 4160 V emergency bus E2 to 4160 V emergency bus E4 per plant procedure 0AOP-36.1, Loss of Any 4kV OR 480V Bus.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, dedicated Amendment No. 310.

NLOs will be briefed, each shift, regarding cross-tying 480 V E7 bus to the 480 V E8 bus per 0AOP-36.1, Loss of Any 4kV OR 480V Bus.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, dedicated Amendment No. 310.

NLOs will be briefed, each shift, regarding starting and tying the SUPP-DG to 4160 V emergency bus E4 per plant procedure 0EOP-01-SBO-08, Supplemental DG Alignment.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, designated Amendment No. 310.

NLOs will be briefed, each shift, regarding load shed procedures and alignment of the FLEX diesel generators.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, a continuous Amendment No. 310.

fire watch shall be established for the Unit 2 Cable Spread Room and for the Balance of Plant busses in the Unit 2 Turbine Building 20 foot elevation.

310 During the extended EDG Completion Times Upon implementation of authorized by Amendment No. 310, the FLEX Amendment No. 310.

pump and FLEX Unit 2 hose trailer shall be staged at the south side of the Unit 2 Condensate Storage Tank to support rapid deployment in the event the FLEX pump is needed for Unit 2 inventory control.

Brunswick Unit 2 App. B-4 Amendment No. 310

BSEP 17-0108 Enclosure Attachment 4 Risk Insights Related to One-Time Extended Completion Time

BSEP 17-0108 Enclosure Attachment 4 Appendix A Page 1 Risk Insights Related to One-Time Extended Completion Time TABLE OF CONTENTS 1 Introduction ............................................................................................................................ 2 2 Evaluation of Risk Impacts .................................................................................................... 2 2.1 Tier 1: Probabilistic Risk Assessment Capability and Insights ....................................... 2 2.2 Tier 2: Avoidance of Risk Significant Plant Configuration............................................... 2 2.3 Tier 3: Risk Informed Configuration Management .......................................................... 3 3 References ............................................................................................................................ 4

BSEP 17-0108 Enclosure Attachment 4 Appendix A Page 2 1 Introduction The risk associated with extending the BNP #4 Emergency Diesel Generator (EDG) one-time Technical specification completion time from the current 14 days to 30 days has been evaluated with a PRA model that meets the scope and quality requirements in Regulatory Guide 1.200, Revision 2 (Reference 1) to Capability Category II. This plant-specific risk assessment followed the guidance in RG 1.177, Revision 1 (Reference 2).

2 Evaluation of Risk Impacts 2.1 Tier 1: Probabilistic Risk Assessment Capability and Insights The total CDF and LERF results meet the NRC RG 1.174, Revision 2 (Reference 2) acceptance criteria for risk-informed licensing changes (i.e., CDF less than 1E-4 per year and LERF less than 1E-5 per year). The total CDF and LERF contributions from the PRA models are provided in Table 1. The results are comprised of Internal Events, Internal Flooding, and Fire PRA quantification results. The risk impact associated with a 30-day total (AOT + extension) #4 EDG out of service is provided in Table 2. These results have significant margin to the acceptance criteria in RG 1.177, Revision 1 (Reference 4).

Table 1: Total CDF and LERF Unit Total CDF Total LERF Unit 1 1.69E-06 0.00E+00 Unit 2 2.26E-06 4.94E-08 Table 2: ICCDP and ICLERP for Technical Specification Extension Configuration ICCDP (30 Day) ICLERP (30 Day)

Unit 2 - #4 EDG Out of Service 1.86E-07 4.06E-09 Configuration The only compensatory measure in the PRA model that is given quantitative credit is the protection of the supplemental diesel generator. In the risk impact evaluation, the Common Cause Failure (CCF) probabilities for all common cause failure events in the CCF group with EDGs 1, 2, 3, and 4 were increased by a factor of 5 to account for the increased potential for the other diesel generators to fail from a common factor.

2.2 Tier 2: Avoidance of Risk Significant Plant Configurations The dominant risk scenarios associated with unavailability of the #4 EDG include:

BSEP 17-0108 Enclosure Attachment 4 Appendix A Page 3 For Internal events, the primary sequences of the faulted case are dominated by loss of DC power sequences with failures of either the battery chargers or the batteries coupled with initiating events that fail the opposite train of DC power. These lead to loss of ECCS system functionality. Loss of offsite power from switchyard-related activities are the most common initiating events in the results. Ensuring restriction of switchyard activities, as well as ensuring that the station batteries and battery chargers maintain protected during the course of the extended technical specification outage time will minimize plant risk for internal events.

For Internal flooding, results are driven by operators accomplishing DC load shed in response to various flooding initiating events. Component failure results are dominated by failures of the battery chargers.

For all PRA models, maintain protection of the EDGs 1, 2 and 3 as well as the Supplemental Diesel and Offsite power sources. Additionally, the failure to crosstie due to equipment failure or human error are important contributors to risk.

Fires in the Main Control Room, the Cable Spread Room, and the RHR rooms are the highest contributors to risk. Fires in the battery room or near the 1D or 2D Switchgear are also important. Operators failing to extend RCIC operation by managing HCTL curves and defeating trips is the largest human action contributor to the overall results. Fires impacted the most due to the #4 EDG unavailability include fires starting from Buses 1D or 2D. Sequences result in loss of suppression pool cooling requiring the operators to maintain RCIC operation for extended period with no cooling to the suppression pool. Failure to stay below the HCTL curve or defeat HPCI protective trips may result in a need for emergency depressurization and long term makeup from RHR/SW or fire water.

2.3 Tier 3: Risk Informed Configuration Management 10 CFR 50.65(a)(4), RG 1.160 (Reference 5), RG 1.182 (Reference 6), and NUMARC 93-01 (Reference 7) require that prior to performing maintenance activities, risk assessments shall be performed to assess and manage the increase in risk that may result from proposed maintenance activities. These requirements are applicable for all plant modes. NUMARC 91-01 (Reference 7) requires utilities to assess and manage the risks that occur during the performance of outages.

The proposed LAR will not result in any significant changes to the current configuration risk management program. The Brunswick on-line computerized risk software (Equipment Out Of Service or EOOS) considers internal initiating events including LOOP events (including weather and grid related). Thus, the overall change in plant risk during maintenance activities is expected to be addressed adequately considering the proposed amendment.

Brunswick has several Administrative (AD) procedures in place to ensure that risk significant plant configurations are avoided. These documents are used to address the Maintenance Rule requirements, including the on-line (and off-line) Maintenance Policy requirement to control the safety impact of combinations of equipment removed from service. The key documents are as follows:

BSEP 17-0108 Enclosure Attachment 4 Appendix A Page 4

AD-WC-ALL-0410, Work Activity Integrated Risk Management (Reference 8),

0AP-025, "BNP Integrated Scheduling" (Reference 9)

AD-NF-ALL-0501, "Electronic Risk Assessment Tool (ERAT)" (Reference 10)

More specifically, the ADs referenced above address the process, define the program and state individual group responsibilities to ensure compliance with the Maintenance Rule. The Work Process Manual procedures provide a consistent process for utilizing the computerized software assessment tool, EOOS, which manages the risk associated with equipment inoperability.

EOOS is a Windows-based computer program used to facilitate risk informed decision making associated with station work activities. Its guidelines are independent of the requirements of the Technical Specifications and Technical Requirements Document and are based on probabilistic risk assessment studies and deterministic approaches.

Additionally, prior to the release of work for execution, Operations personnel must consider the effects of severe weather and grid instabilities on plant operations. Responses to actual plant risk due to severe weather or grid instabilities are programmatically incorporated into applicable plant emergency or response procedures.

The key safety significant systems impacted by this proposed LAR are currently included in the Maintenance Rule program, and as such, availability and reliability performance criteria have been established to assure that they perform adequately.

3 References

1. Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 2, dated March 2009

2. Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Revision 2, dated April 2015.

3. NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, dated September 2005

4. Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications, Revision 1, dated May 2011.

5. Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3, dated May 2012.

6. Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants, dated May 2000.

BSEP 17-0108 Enclosure Attachment 4 Appendix A Page 5

7. NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4A, dated April 2011.

8. AD-WC-ALL-0410, Revision 4, Work Activity Integrated Risk Management.

9. 0AP-025, Revision 56, BNP Integrated Scheduling.

10. AD-NF-ALL-0501, Revision 0, Electronic Risk Assessment Tool (ERAT).

BSEP 17-0108 Enclosure Attachment 4 Appendix B Page 1 BNP-PSA-107, Rev. 0 APPENDIX B Review of Dominant Faulted Case Sequences

BSEP 17-0108 Enclosure Attachment 4 Appendix B Page 2 Methodology A review of the faulted case sequences (where the faulted Diesel Generator 4 was present in the results) for Internal Events, Internal Flooding, and Fire was performed. The following sequences were shown to be large contributors to plant risk. Each sequence is matched to a set of mitigating actions that are being performed as a part of the extended completion time compensatory measures that will have an impact on the results of each sequence.

Dominant Sequences and Contributors to Risk Sequence 1: Switchyard-centered LOOP initiating event, with failure to depressurize the RCS to utilize low pressure pumps, followed by failure to cross-tie power to support long-term suppression pool cooling.

Mitigating Action: Designated non-licensed operators (NLOs) will be briefed, each shift, regarding cross tying the 4160 V, or cross tying 480 V power, to recover long term cooling. No discretionary switchyard maintenance will be allowed during the extended EDG Completion Times.

Sequence 2: Turbine Trip initiating event with failure of SAT breaker to align offsite power followed by failure to load shed DC loads leading to battery depletion when offsite power is not recovered and backup power from Supplemental Diesel and FLEX Diesels to the battery chargers are not aligned.

Mitigating Action: Designated non-licensed operators (NLOs) will be briefed, each shift, regarding load shed procedures and alignment of Supplemental and FLEX Diesel Generators.

Sequence 3: Fire event in Switchgear Bus 2D results in Station Blackout followed by failure to cross-tie power to support long-term suppression pool cooling followed by failure to align Fire Water injection.

Mitigating Action: Designated non-licensed operators (NLOs) will be briefed, each shift, regarding cross tying the 4160 V, or cross tying 480 V power, to recover long term cooling. A continuous fire watch shall be established for the Unit 1 and Unit 2 Cable

BSEP 17-0108 Enclosure Attachment 4 Appendix B Page 3 Spread Rooms and for the Balance of Plant busses in the Unit 1 and Unit 2 Turbine Building 20 foot elevations.

Operators have recently completed training on HPCI, RCIC, RFP Operation Post-Scram (i.e., LOT-AOP-100). The training was focused on HPCI, RCIC, and RFPs for controlling reactor level and pressure post-scram. The training was sufficient for maintaining operator proficiency in the use of RCIC by managing the HCTL and defeating pump trips. No additional action is required to address RCIC use.

Sequence 4: Fire event in Control Room cabinet leading to a loss of offsite power followed by failure to cross-tie power to support long-term suppression pool cooling.

Mitigating Action: Designated non-licensed operators (NLOs) will be available to start and align Supplement D/G to restore long term cooling.

Operators have recently completed training on HPCI, RCIC, RFP Operation Post-Scram (i.e., LOT-AOP-100). The training was focused on HPCI, RCIC, and RFPs for controlling reactor level and pressure post-scram. The training was sufficient for maintaining operator proficiency in the use of RCIC by managing the HCTL and defeating pump trips. No additional action is required to address RCIC use.

v t e Letter Sequence Request
EPID:L-2017-LLA-0392, TSTF-448 (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers 24 November 2017 Results Approval Other:
MONTHYEAR2017-11-24 [Table View]

BSEP 17-0108, Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements

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BSEP 17-0108, Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements

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