Text

Submittal of Technical Specification Bases Changes
	ML051820228
Person / Time
Site:	Brunswick
Issue date:	06/22/2005
From:	O'Neil E; Progress Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 05-0082
	Download: ML051820228 (113)
	v • d • e

C43 Progress Energy JUN 2 2 2005 SERIAL: BSEP 05-0082 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

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

In accordance with Technical Specification (TS) 5.5.10 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc., is submitting Revisions 40 and 41 to the BSEP, Unit 1 TS Bases and Revisions 37 and 38 to the BSEP, Unit 2 TS Bases.

Please refer any questions regarding this submittal to Mr. Leonard R. Beller, Supervisor -

Licensing/Regulatory Programs, at (910) 457-2073.

Sincerely, Edward T. O'Neil Manager - Support Services Brunswick Steam Electric Plant MAT/mat

Enclosures:

1. Summary of Revisions to Technical Specification Bases

2. Page Replacement Instructions

3. Unit 1 Technical Specification Bases Replacement Pages

4. Unit 2 Technical Specification Bases Replacement Pages Progress Energy Carolinas, Inc.

Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 /

Document Control Desk BSEP 05-0082 / Page 2 cc (with enclosures):

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

ATIN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health

-North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 05-0082 Enclosure 1 Page I of 1

. Summary of Revisions to Technical Specification Bases RAffected Date Implemented Title/Description Revis-n -Unit 40 1 May 24,2005

Title:

Deletion of Hydrogen and Oxygen 37 2 Analyzer Requirements

Description:

Revision 40 for Unit 1 and 37 for Unit 2 incorporated changes to B 3.3.3.1, "PAM Instrumentation," associated with License Amendments 234 and 261 issued on February 2, 2005. These amendments revised the Unit 1 and Unit 2 Technical Specifications (TSs) by eliminating the requirements associated with hydrogen and oxygen monitors consistent with Technical Specification Task Force (TSTF) change 447, Revision 1.

41 1 June 16, 2005

Title:

Increased Flexibility In Mode 38 2 Restraints

Description:

Revision 41 for Unit 1 and 38 for Unit 2 incorporated changes to various sections of the TS Bases associated with License Amendments 233 and 260 issued on January 11, 2005.

These amendments modified the Unit 1 and Unit 2 TSs requirements to adopt the provisions of TSTF-359.

I Revision 40 for Unit 1 and Revision 37 for Unit 2 incorporated change package TSC-2004-01.

Revision 41 for Unit 1 and Revision 38 for Unit 2 incorporated change package TSC-2003-05

BSEP 05-0082 Enclosure 2 Page 1 of 4 Page Replacement Instructions - Unit 1 Remove Insert Unit 1 - Bases Book 1.-

Cover Page, Revision 39 Cover Page, Revision 41 LOEP-1, Revision 39 LOEP-I, Revision 41 LOEP-3, Revision 35 LOEP-3, Revision 41 B 3.0-5, Revision 31 B 3.0-5, Revision 41 B 3.0-6, Revision 31 B 3.0-6, Revision 41 B 3.0-7, Revision 31 B 3.0-7, Revision 41 B 3.0-8, Revision 31 B 3.0-8, Revision 41 B 3.0-9, Revision 31 B 3.0-9, Revision 41 B 3.0-10, Revision 31 B 3.0-10, Revision 41 B 3.0-11, Revision 31 B 3.0-11, Revision 41 B 3.0-12, Revision 31 B 3.0-12, Revision 41 B 3.0-13, Revision 31 B 3.0-13, Revision 41 B 3.0-14, Revision 31 B 3.0-14, Revision 41 B 3.0-15, Revision 31 B 3.0-15, Revision 41 B 3.0-16, Revision 31 B 3.0-16, Revision 41 N/A B 3.0-17, Revision 41 B 3.3.3.1-6, Revision 31 B 3.3.3.1-6, Revision 40 B 3.3.3.1-7, Revision 31 B 3.3.3.1-7, Revision 41 B 3.3.3.1-8, Revision 31 B 3.3.3.1-8, Revision 40 B 3.3.3.1-9, Revision 31 B 3.3.3.1-9, Revision 40 B 3.3.3.1-10, Revision 31 B 3.3.3.1-10, Revision 40 B 3.3.3.1-11, Revision 31 N/A B 3.3.3.1-12, Revision 31 N/A B 3.3.3.2-1, Revision 31 B 3.3.3.2-1, Revision 41 B 3.3.3.2-2, Revision 31 B 3.3.3.2-2, Revision 41 B 3.3.3.2-3, Revision 31 B 3.3.3.2-3, Revision 41 B 3.3.3.2-4, Revision 31 B 3.3.3.2-4, Revision 41 B 3.3.3.2-5, Revision 31 B 3.3.3.2-5, Revision 41 B 3.3.3.2-6, Revision 31 N/A

BSEP 05-0082 Enclosure 2 Page 2 of 4

-Page Replacement Instructions Unit 1,

-Remove Insert -

Unit 1 -BasesBook2- . :

LOEP-1, Revision 39 LOEP-1, Revision 41 LOEP-2, Revision 36 LOEP-2, Revision 41 LOEP-3, Revision 39 LOEP-3, Revision 41 B 3.4.5-3, Revision 31 B 3.4.5-3, Revision 41 B 3.4.5-4, Revision 31 B 3.4.5-4, Revision 41 B 3.4.5-5, Revision 31 N/A B 3.4.6-1, Revision 31 B 3.4.6-1, Revision 41 B 3.4.6-2, Revision 31 B 3.4.6-2, Revision 41 B 3.4.6-3, Revision 31 B 3.4.6-3, Revision 41 B 3.4.64, Revision 31 N/A B 3.4.7-3, Revision 31 B 3.4.7-3, Revision 41 B 3.4.7-4, Revision 31 B 3.4.7-4, Revision 41 B 3.4.7-5, Revision 31 B 3.4.7-5, Revision 41 B 3.5.1-6, Revision 31 B 3.5.1-6, Revision 41 B 3.5.3-2, Revision 31 B 3.5.3-2, Revision 41 B 3.6.2.3-2, Revision 31 B 3.6.2.3-2, Revision 41 B 3.6.2.3-3, Revision 31 B 3.6.2.3-3, Revision 41 B 3.6.2.3-4, Revision 31 B 3.6.2.3-4, Revision 41 B 3.6.3.2-3, Revision 31 B 3.6.3.2-3, Revision 41 B 3.6.3.2-4, Revision 31 B 3.6.3.24, Revision 41 B 3.6.3.2-5, Revision 36 B 3.6.3.2-5, Revision 41 B 3.7.1-3, Revision 31 B 3.7.1-3, Revision 41 B 3.7.1-4, Revision 31 B 3.7.1-4, Revision 41 B 3.7.1-5, Revision 31 B 3.7.1-5, Revision 41 B 3.7.1-6, Revision 31 N/A B 3.8.1-4, Revision 39 B 3.8.1-4, Revision 41 B 3.8.1-5, Revision 31 B 3.8.1-5, Revision 41

BSEP 05-0082 Enclosure 2 Page 3 of 4

Page Replacement lnstructions - Unit 2 Remove Insert Unit 2 - Bases Book l Cover Page, Revision 37 Cover Page, Revision 39 LOEP-1, Revision 37 LOEP-1, Revision 39 LOEP-3, Revision 35 LOEP-3, Revision 39 B 3.0-5, Revision 30 B 3.0-5, Revision 39 B 3.0-6, Revision 30 B 3.0-6, Revision 39 B 3.0-7, Revision 30 B 3.0-7, Revision 39 B 3.0-8, Revision 30 B 3.0-8, Revision 39 B 3.0-9, Revision 30 B 3.0-9, Revision 39 B 3.0-10, Revision 30 B 3.0-10, Revision 39 B 3.0-11, Revision 30 B 3.0-11, Revision 39 B 3.0-12, Revision 30 B 3.0-12, Revision 39 B 3.0-13, Revision 30 B 3.0-13, Revision 39 B 3.0-14, Revision 30 B 3.0-14, Revision 39 B 3.0-15, Revision 30 B 3.0-15, Revision 39 B 3.0-16, Revision 30 B 3.0-16, Revision 39 N/A B 3.0-17, Revision 39 B 3.3.3.1-6, Revision 30 B 3.3.3.1-6, Revision 38 B 3.3.3.1-7, Revision 30 B 3.3.3.1-7, Revision 39 B 3.3.3.1-8, Revision 30 B 3.3.3.1-8, Revision 38 B 3.3.3.1-9, Revision 30 B 3.3.3.1-9, Revision 38 B 3.3.3.1-10, Revision 30 B 3.3.3.1-10, Revision 38 B 3.3.3.1-11, Revision 30 N/A B 3.3.3.1-12, Revision 30 N/A B 3.3.3.2-1, Revision 30 B 3.3.3.2-1, Revision 39 B 3.3.3.2-2, Revision 30 B 3.3.3.2-2, Revision 39 B 3.3.3.2-3, Revision 30 B 3.3.3.2-3, Revision 39 B 3.3.3.2-4, Revision 30 B 3.3.3.2-4, Revision 39 B 3.3.3.2-5, Revision 30 B 3.3.3.2-5, Revision 39 B 3.3.3.2-6, Revision 30 N/A

q.

BSEP 05-0082 Enclosure 2 Page 4 of 4 Page Replacement Instructions - Unit 2 Remove Insert Unit2-Bases Book 2 LOEP-1, Revision 36 LOEP-1, Revision 39 LOEP-2, Revision 33 LOEP-2, Revision 39 LOEP-3, Revision 36 LOEP-3, Revision 39 B 3.4.5-3, Revision 30 B 3.4.5-3, Revision 39 B 3.4.5-4, Revision 30 B 3.4.5-4, Revision 39 B 3.4.5-5, Revision 30 N/A B 3.4.6-1, Revision 30 B 3.4.6-1, Revision 39 B 3.4.6-2, Revision 30 B 3.4.6-2, Revision 39 B 3.4.6-3, Revision 30 B 3.4.6-3, Revision 39 B 3.4.64, Revision 30 N/A B 3.4.7-3, Revision 30 B 3.4.7-3, Revision 39 B 3.4.74, Revision 30 B 3.4.7-4, Revision 39 B 3.4.7-5, Revision 30 B 3.4.7-5, Revision 39 B 3.5.1-6, Revision 30 B 3.5.1-6, Revision 39 B 3.5.3-2, Revision 30 B 3.5.3-2, Revision 39 B 3.6.2.3-2, Revision 30 B 3.6.2.3-2, Revision 39 B 3.6.2.3-3, Revision 30 B 3.6.2.3-3, Revision 39 B 3.6.2.3-4, Revision 30 B 3.6.2.3-4, Revision 39 B 3.6.3.2-3, Revision 30 B 3.6.3.2-3, Revision 39 B 3.6.3.24, Revision 30 B 3.6.3.24, Revision 39 B 3.6.3.2-5, Revision 33 B 3.6.3.2-5, Revision 39 B 3.7.1-3, Revision 30 B 3.7.1-3, Revision 39 B 3.7.14, Revision 30 B 3.7.14, Revision 39 B 3.7.1-5, Revision 30 B 3.7.1-5, Revision 39 B 3.7.1-6, Revision 30 N/A B 3.8.14, Revision 36 B 3.8.14, Revision 39 B 3.8.1-5, Revision 30 B 3.8.1-5, Revision 39

BSEP 05-0082 Enclosure 3 Unit 1 Technical Specification Bases Replacement Pages

Unit 1 - Bases Book 1 Replacement Pages

BASES TO THE FACILITY OPERATING LICENSE DPR-71 TECHNICAL SPECIFICATIONS FOR BRUNSWICK STEAM ELECTRIC PLANT UNIT 1 CAROLINA POWER & LIGHT COMPANY REVISION 41

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

Title Page 41 B 3.1.1-6 31 I B 3.1.2-1 31 List of Effective Pages - Book 1 B 3.1.2-2 31 B 3.1.2-3 31 LOEP-1 41 B 3.1.2-4 31 I LOEP-2 36 B 3.1.2-5 31 LOEP-3 41 B 3.1.3-1 31 I LOEP-4 36 B 3.1.3-2 31 B 3.1.3-3 31 31 B 3.1.3-4 31 i.

ii 31 B 3.1.3-5 31 B 3.1.3-6 31 B 2.1.1-1 31 B 3.1.3-7 31 B 2.1.1-2 31 B 3.1.3-8 31 B 2.1.1-3 31 B 3.1.3-9 31 B 2.1.1-4 31 B 3.1.4-1 31 B 2.1.1-5 31 B 3.1.4-2 31 B 2.1.2-1 31 B 3.1.4-3 31 B 2.1.2-2 31 B 3.1.4-4 31 B 2.1.2-3 31 B 3.1.4-5 31 B 3.1.4-6 31 B 3.0-1 31 B 3.1.4-7 31 B 3.0-2 31 B 3.1.5-1 31 B 3.0-3 31 B 3.1.5-2 31 B 3.0-4 31 B 3.1.5-3 31 B 3.0-5 41 B 3.1.5-4 31 B 3.0-6 41 B 3.1.5-5 31 B 3.0-7 41 B 3.1.6-1 31 B 3.0-8 41 B 3.1.6-2 31 B 3.0-9 41 B 3.1.6-3 31 B 3.0-10 41 B 3.1.6-4 31 B 3.0-11 41 B 3.1.6-5 31 B 3.0-12 41 B 3.1.7-1 34 B 3.0-13 41 B 3.1.7-2 31 B 3.0-14 41 B 3.1.7-3 31 B 3.0-15 41 B 3.1.7-4 31 B 3.0-16 41 B 3.1.7-5 31 B 3.0-17 41 B 3.1.7-6 34 B 3.1.8-1 31 B 3.1.1-1 31 B 3.1.8-2 37 B 3.1.1-2 31 B 3.1.8-3 37 B 3.1.1-3 31 B 3.1.8-4 31 B 3.1.1-4 31 B 3.1.8-5 31 B 3.1.1-5 31 (continued)

Brunswick Unit 1 LOEP-1 Revision 41 l

LST OF EFFECTIVE PAGES - BASES (continued) . tj j,,

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

B 3.3.3.1-4 31 B 3.3.5.1-17 31 B 3.3.3.1-5 31 B 3.3.5.1-18 36 B 3.3.3.1-6 40 B 3.3.5.1-19 36 B 3.3.3.1-7 41 B 3.3.5.1-20 31 I B 3.3.3.1-8 40 B 3.3.5.1-21 31 B 3.3.3.1-9 40 B 3.3.5.1-22 31 B 3.3.3.1 -10 40 B 3.3.5.1-23 31 B 3.3.3.2-1 41 B 3.3.5.1-24 31 B 3.3.3.2-2 41 B 3.3.5.1-25 31 B 3.3.3.2-3 41 B 3.3.5.1-26 31 B 3.3.3.2-4 41 B 3.3.5.1-27 31 B 3.3.3.2-5 41 B 3.3.5.1-28 31 B 3.3.4.1-1 31 B 3.3.5.1-29 31 B 3.3.4.1-2 31 B 3.3.5.1-30 31 B 3.3.4.1-3 31 B 3.3.5.1-31 36 B 3.3.4.1-4 31 B 3.3.5.2-1 31 B 3.3.4.1-5 31 B 3.3.5.2-2 31 B 3.3.4.1-6 31 B 3.3.5.2-3 31 B 3.3.4.1-7 31 B 3.3.5.2-4 31 B 3.3.4.1-8 31 B 3.3.5.2-5 31 B 3.3.4.1-9 31 B 3.3.5.2-6 31 B 3.3.5.1-1 31 B 3.3.5.2-7 31 B 3.3.5.1-2 31 B 3.3.5.2-8 31 B 3.3.5.1-3 31 B 3.3.5.2-9 31 B 3.3.5.1-4 36 B 3.3.5.2-1 0 31 B 3.3.5.1-5 31 B 3.3.5.2-11 31 B 3.3.5.1-6 31 B 3.3.6.1-1 31 B 3.3.5.1-7 31 B 3.3.6.1-2 31 B 3.3.5.1-8 31 B 3.3.6.1-3 31 B 3.3.5.1-9 31 B 3.3.6.1-4 31 B 3.3.5.1 -10 31 B 3.3.6.1-5 31 B 3.3.5.1-11 31 B 3.3.6.1-6 31 B 3.3.5.1-12 31 B 3.3.6.1-7 31 B 3.3.5.1-13 36 B 3.3.6.1-8 32 B 3.3.5.1-14 36 B 3.3.6.1-9 31 B 3.3.5.1-15 36 B 3.3.6.1-10 31 B 3.3.5.1-16 36 B 3.3.6.1 -11 31 B 3.3.6.1-12 31 B 3.3.6.1-13 31 B 3.3.6.1-14 31 (continued)

Brunswick Unit 1 LOEP-3 Revision 41 l

LCO Applicability B3.0 BASES LCO 3.0.3 LCO 3.7.7 has an Applicability of "During movement of irradiated fuel (continued) assemblies in the spent fuel storage pool." Therefore, this LCO can be' applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the l

Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The (continued)

Brunswick Unit 1 B 3.0-5 Revision No. 41 l

LCO Applicability B3.0 BASES LCO 3.0.4 risk assessments will be conducted using the procedures and guidance (continued) endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not (continued)

Brunswick Unit 1 B 3.0-6 Revision No. 41 l

LCO Applicability B 3.0 BASES LCO 3.0.4 been performed. This allowance may apply to all the ACTIONS or to a (continued) specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

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

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

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

I LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

(continued)

Brunswick Unit 1 B 3.0-7 Revision No. 41 l

LCO Applicability B 3.0 BASES LCO 3.0.5 The administrative controls ensure the time the equipment is returned to (continued) service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system's LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system's LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability.

(continued)

Brunswick Unit 1 B 3.0-8 Revision No. 41 l

LCO Applicability B 3.0 BASES LCO 3.0.6 However, it is not necessary to enter into the supported systems' (continued) Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.11, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

(continued)

Brunswick Unit 1 B 3.0-9 Revision No. 41 l

LCO Applicability B3.0

. .t BASES (continued)

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

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

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

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

Brunswick Unit 1 B 3.0-1 0 Revision No. 41 l

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

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

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

a. The systems or components are known to be inoperable, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

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

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

(continued)

Brunswick Unit 1 B 3.0-1 1 Revision No. 41 l

SR Applicability B3.0 BASES SR 3.0.1 Surveillances, including Surveillances invoked by Required Actions, (continued) do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

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

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > 800 psi. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 800 psi to perform other necessary testing.

b. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

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

(continued)

Brunswick Unit 1 B 3.0-12 Revision No. 41 l

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

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

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

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

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

(continued)

Brunswick Unit 1 B 3.0-1 3 Revision No. 41 l

SR Applicability B3.0 BASES (continued)

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

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

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

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

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

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

Brunswick Unit 1 B 3.0-14 Revision No. 41 l

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

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

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

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

(continued)

Brunswick Unit 1 B 3.0-1 5 Revision No. 41 l

SR Applicability B3.0 BASES (continued)

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

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

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

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

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

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

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

(continued)

Brunswick Unit 1 B 3.0-16 Revision No. 41 l

SR Applicability B3.0 BASES SR 3.0.4 The precise requirements for performance of SRs are specified such that (continued) exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such I that it is not "due" until the specific conditions needed are met.

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

I Brunswick Unit 1 B 3.0-1 7 Revision No. 41 l

PAM Instrumentation B 3.3.3.1 BASES LCO 7. Drywell Temperature (continued) by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

8. Primary Containment Isolation Valve (PCIV) Position PCIV position, a Category I variable, is provided for verification of containment integrity. In the case of PCIV position, the important information is the isolation status of the containment penetration. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

The PCIV position PAM instrumentation consists of position switches, associated wiring and control room indication for active PCIVs (check valves and manual valves are not required to have position indication).

Therefore, the PAM Specification deals specifically with these instrument channels.

9. (Not Used)

10. Drvwell Area Radiation Drywell area radiation is a Category I variable provided to monitor the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. Post accident drywell area radiation levels are monitored by four instruments, each with a range of 1 R/hr to 107 R/hr.

The outputs of these channels are indicated and recorded in the control room. Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

Brunswick Unit 1 B 3.3.3.1-6 Revision No. 40 l

PAM Instrumentation B 3.3.3.1 BASES (continued)

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS A Note has been provided to modify the ACTIONS related to PAM I instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable PAM instrumentation channels provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable PAM Function.

A.1 When one or more Functions have one required channel that is inoperable, the required inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channels, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval.

(continued)

Brunswick Unit 1 B 3.3.3.1-7 Revision No. 41 l

PAM Instrumentation B 3.3.3.1 BASES ACTIONS 8.1 (continued)

If a channel has not been restored to OPERABLE status in 30 days, this Required Action specifies initiation of action in accordance with Specification 5.6.6, which requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This Required Action is appropriate in lieu of a shutdown requirement, since another OPERABLE channel is monitoring the Function, and given the likelihood of plant conditions that would require information provided by this instrumentation.

C.1 When one or more Functions have two required channels that are inoperable (i.e., two channels inoperable in the same Function), one channel in the Function should be restored to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information.

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

D.1 This Required Action directs entry into the appropriate Condition referenced in Table 3.3.3.1-1. The applicable Condition referenced in the Table is Function dependent. Each time an inoperable channel has not met the Required Action of Condition C and the associated Completion Time has expired, Condition D is entered for that channel and provides for transfer to the appropriate subsequent Condition.

E.1 For the majority of Functions in Table 3.3.3.1-1, if any Required Action and associated Completion Time of Condition C is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 1 B 3.3.3.1-8 Revision No. 40 l

PAM Instrumentation B 3.3.3.1 BASES ACTIONS F.1 (continued)

Since alternate means of monitoring primary containment area radiation are available, the Required Action is not to shut down the plant, but rather to follow the directions of Specification 5.6.6. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.

SURVEILLANCE As noted at the beginning of the SRs, the following SRs apply to each REQUIREMENTS PAM instrumentation Function in Table 3.3.3.1-1.

SR 3.3.3.1.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel against a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar plant instruments located throughout the plant.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The Frequency of 31 days is based upon plant operating experience, with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31 day interval is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the channels required by the LCO.

(continued)

Brunswick Unit 1 B 3.3.3.1-9 Revision No. 40 l

PAM Instrumentation B 3.3.3.1 BASES SURVEILLANCE SR 3.3.3.1.2 REQUIREMENTS (continued) Not Used.

SR 3.3.3.1.3 This SR requires a CHANNEL CALIBRATION to be performed.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured parameter with the necessary range and accuracy. I For Function 10, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.

The 24 month Frequency for CHANNEL CALIBRATION of PAM I Instrumentation of Table 3.3.3.1-1 is based on operating experience and consistency with the BNP refueling cycles.

REFERENCES 1. Regulatory Guide 1.97, Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, December 1980.

2. NRC Safety Evaluation Report, Conformance to Regulatory Guide 1.97, Rev. 2, Brunswick Steam Electric Plant, Units 1 and 2, May 14, 1985.

3. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 1 B 3.3.3.1 -10 Revision No. 40 l

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 B 3.3 INSTRUMENTATION B 3.3.3.2 Remote Shutdown Monitoring Instrumentation BASES BACKGROUND The remote shutdown monitoring instrumentation provides the control room operator with sufficient instrumentation to support placing and maintaining the plant in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility of the control room becoming inaccessible. A safe shutdown condition is defined as MODE 3. With the plant in MODE 3, the Reactor Core Isolation Cooling (RCIC) System, the safety/relief valves, and the Residual Heat Removal (RHR) System can be used to remove core decay heat and meet all safety requirements. The long term supply of water for the RCIC System and the ability to operate shutdown cooling from outside the control room allow extended operation in MODE 3.

In the event that the control room becomes inaccessible, the operators can monitor the status of the reactor and primary containment and the operation of the RCIC and RHR Systems at the remote shutdown panel and place and maintain the plant in MODE 3. Controls and selector switches will have to be operated locally at the switchgear, motor control panels, or other local stations. The plant is in MODE 3 following a plant shutdown and can be maintained safely in MODE 3 for an extended period of time.

The OPERABILITY of the remote shutdown monitoring instrumentation Functions ensures that there is sufficient information available on selected plant parameters to place and maintain the plant in MODE 3 should the control room become inaccessible.

APPLICABLE The remote shutdown monitoring instrumentation is required to provide SAFETY ANALYSES equipment at appropriate locations outside the control room with a design capability to monitor the prompt shutdown of the reactor to MODE 3, including the necessary instrumentation to support maintaining the plant in a safe condition in MODE 3.

The criteria governing the design and the specific system requirements of the remote shutdown monitoring instrumentation are located in the UFSAR (Ref. 1).

The Remote Shutdown Monitoring Instrumentation is considered an important contributor to reducing the risk of accidents; as such, it meets Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).

(continued)

Brunswick Unit 1 B 3.3.3.2-1 Revision No. 41 l

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 BASES (continued)

LCO The Remote Shutdown Monitoring Instrumentation LCO provides the requirements for the OPERABILITY of the monitoring instrumentation necessary to support placing and maintaining the plant in MODE 3 from a location other than the control room. The monitoring instrumentation required are listed in Table B 3.3.3.2-1.

The monitoring instrumentation are those required for:

Reactor pressure vessel (RPV) pressure control;

Decay heat removal; and

RPV inventory control.

The remote shutdown monitoring instrumentation is OPERABLE if all instrument channels needed to support the remote shutdown monitoring function are OPERABLE with readouts displayed external to the control room.

The remote shutdown monitoring instruments covered by this LCO do not need to be energized to be considered OPERABLE. This LCO is intended to ensure that the instruments will be OPERABLE if plant conditions require that the remote shutdown monitoring instrumentation be placed in operation.

APPLICABILITY The Remote Shutdown Monitoring Instrumentation LCO is applicable in MODES 1 and 2. This is required so that the plant can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.

This LCO is not applicable in MODES 3, 4, and 5. In these MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument Functions if control room instruments or control becomes unavailable. Consequently, the LCO does not require OPERABILITY in MODES 3,4, and 5.

(continued)

Brunswick Unit 1 B 3.3.3.2-2 Revision No. 41 l

Remote Shutdown Monitoring Instrumentation i.B 3.3.3.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to Remote Shutdown Monitoring Instrumentation Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown Monitoring Instrumentation Functions provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown Monitoring Instrumentation Function.

A.1 Condition A addresses the situation where one or more required Functions of the remote shutdown monitoring instrumentation is inoperable. This includes any Function listed in Table B 3.3.3.2-1. The Required Action is to restore the Function (all required channels) to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

B.1 If the Required Action and associated Completion Time of Condition A are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 1 B 3.3.3.2-3 Revision No. 41 l

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 BASES (continued)

SURVEILLANCE SR 3.3.3.2.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels that are normally energized. For Function 2 of Table B 3.3.3.2-1, the CHANNEL CHECK requirement does not apply to the N01 7 instrument loop since this instrument loop has no displayed indication. The CHANNEL CHECK requirement does apply to the remaining instruments of Function 2.

The Frequency is based upon plant operating experience that demonstrates channel failure is rare.

SR 3.3.3.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.

The 24 month Frequency is based upon operating experience and consistency with the BNP refueling cycle.

REFERENCES 1. UFSAR, Section 7.4.4.

2. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 1 B 3.3.3.2-4 Revision No. 41 l

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 Table B 3.3.3.2-1 (page 1 of 1)

Remote Shutdown Monitoring Instrumentation REQUIRED READOUT NUMBER OF FUNCTION LOCATION CHANNELS

1. Reactor Vessel Pressure (a) 1

2. Reactor Vessel Water Level (a) 1

3. Suppression Chamber Water Level (a) 1

4. Suppression Chamber Water Temperature (a) 1

5. Drywell Pressure (a) 1

6. Drywell Temperature (a) 1

7. Residual Heat Removal System Flow (a) 1 (a) Remote Shutdown Panel, Reactor Building 20 ft. Elevation.

Brunswick Unit 1 B 3.3.3.2-5 Revision No. 41 l

Unit 1 - Bases Book 2 Replacement Pages

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

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

Brunswick Unit 1 LOEP-1 Revision 41 l

LIST OF EFFECTIVE PAGES - BASES (continued) j, Page No. Revision No. Page No. Revision No.

B 3.5.3-3 31 B 3.6.1.5-6 31 B 3.5.3-4 31 B 3.6.1.5-7 31 B 3.5.3-5 31 B 3.6.1.5-8 36 B 3.5.3-6 31 B 3.6.1.5-9 31 B 3.5.3-7 31 B 3.6.1.6-1 31 B 3.6.1.6-2 31 B 3.6.1.1-1 31 B 3.6.1.6-3 31 B 3.6.1.1-2 31 B 3.6.1.6-4 31 B 3.6.1.1-3 31 B 3.6.1.6-5 31 B 3.6.1.1-4 31 B 3.6.1.6-6 31 B 3.6.1.1-5 31 B 3.6.2.1 -1 31 B 3.6.1.1-6 31 B 3.6.2.1-2 31 B 3.6.1.2-1 31 B 3.6.2.1-3 31 B 3.6.1.2-2 31 B 3.6.2.1-4 31 B 3.6.1.2-3 31 B 3.6.2.1-5 31 B 3.6.1.2-4 31 B 3.6.2.2-1 31 B 3.6.1.2-5 31 B 3.6.2.2-2 31 B 3.6.1.2-6 31 B 3.6.2.2-3 31 B 3.6.1.2-7 31 B 3.6.2.3-1 31 B 3.6.1.2-8 31 B 3.6.2.3-2 41 B 3.6.1.2-9 31 B 3.6.2.3-3 41 B 3.6.1.3-1 31 B 3.6.2.3-4 41 B 3.6.1.3-2 31 B 3.6.3.1 -1 31 B 3.6.1.3-3 31 B 3.6.3.1-2 31 B 3.6.1.3-4 31 B 3.6.3.1-3 31 B 3.6.1.3-5 31 B 3.6.3.2-1 31 B 3.6.1.3-6 31 B 3.6.3.2-2 31 B 3.6.1.3-7 31 B 3.6.3.2-3 41 B 3.6.1.3-8 31 B 3.6.3.2-4 41 B 3.6.1.3-9 31 B 3.6.3.2-5 41 B 3.6.1.3-1 0 31 B 3.6.4.1 -1 31 B 3.6.1.3-11 31 B 3.6.4.1-2 31 B 3.6.1.3-12 31 B 3.6.4.1-3 31 B 3.6.1.3-13 31 B 3.6.4.1-4 31 B 3.6.1.3-14 31 B 3.6.4.1-5 31 B 3.6.1.3-15 31 B 3.6.4.2-1 31 B 3.6.1.4-1 31 B 3.6.4.2-2 31 B 3.6.1.4-2 31 B 3.6.4.2-3 31 B 3.6.1.4-3 31 B 3.6.4.2-4 31 B 3.6.1.5-1 31 B 3.6.4.2-5 31 B 3.6.1.5-2 31 B 3.6.4.2-6 31 B 3.6.1.5-3 31 B 3.6.4.3-1 31 B 3.6.1.5-4 31 B 3.6.4.3-2 31 B 3.6.1.5-5 31 B 3.6.4.3-3 31 (continued)

Brunswick Unit 1 LOEP-2 Revision 41 l

LIST OF EFFECTIVE PAGES - BASES (continued)

. 1, Page No. Revision No. Page No. Revision No.

B 3.6.4.3-4 31 B 3.7.7-1 31 B 3.6.4.3-5 31 B 3.7.7-2 31 B 3.6.4.3-6 31 B 3.7.7-3 31 B 3.7.1-1 31 B 3.8.1-1 31 B 3.7.1-2 31 B 3.8.1-2 31 B 3.7.1-3 41 B 3.8.1-3 36 B 3.7.1-4 41 B 3.8.1-4 41 B 3.7.1-5 41 B 3.8.1-5 41 B 3.7.2-1 31 B 3.8.1-6 31 B 3.7.2-2 31 B 3.8.1-7 31 B 3.7.2-3 31 B 3.8.1-8 31 B 3.7.2-4 31 B 3.8.1-9 31 B 3.7.2-5 31 B 3.8.1-10 31 B 3.7.2-6 31 B 3.8.1-11 31 B 3.7.2-7 31 B 3.8.1-12 31 B 3.7.2-8 31 B 3.8.1-13 31 B 3.7.2-9 31 B 3.8.1-14 31 B 3.7.2-1 0 31 B 3.8.1-15 31 B 3.7.2-11 31 B 3.8.1-16 31 B 3.7.2-12 31 B 3.8.1-17 31 B 3.7.2-13 31 B 3.8.1-18 31 B 3.7.2-14 31 B 3.8.1-19 31 B 3.7.3-1 31 B 3.8.1-20 31 B 3.7.3-2 36 B 3.8.1-21 31 B 3.7.3-3 31 B 3.8.1-22 31 B 3.7.3-4 31 B 3.8.1-23 31 B 3.7.3-5 31 B 3.8.1-24 31 B 3.7.3-6 31 B 3.8.1-25 31 B 3.7.3-7 36 B 3.8.1-26 31 B 3.7.4-1 31 B 3.8.1-27 31 B 3.7.4-2 31 B 3.8.1-28 38 B 3.7.4-3 31 B 3.8.1-29 31 B 3.7.4-4 31 B 3.8.1-30 31 B 3.7.4-5 31 B 3.8.1-31 31 B 3.7.5-1 31 B 3.8.1-32 31 B 3.7.5-2 31 B 3.8.1-33 36 B 3.7.5-3 31 B 3.8.1-34 31 B 3.7.6-1 31 B 3.8.2-1 31 B 3.7.6-2 31 B 3.8.2-2 31 B 3.7.6-3 31 B 3.8.2-3 31 B 3.7.6-4 31 B 3.8.2-4 31 B 3.8.2-5 31 (continued)

Brunswick Unit 1 LOEP-3 Revision 41 l

RCS Leakage Detection Instrumentation B 3.4.5 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4.

ACTIONS A.1 With the drywell floor drain sump flow monitoring system inoperable, no other required instrumentation can provide the equivalent information to quantify LEAKAGE. However, the primary containment atmosphere radioactivity monitor will provide indication of changes in LEAKAGE.

With the drywell floor drain sump flow monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (SR 3.4.4.1), operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available.

B.1 and B.2 With both gaseous and particulate primary containment atmosphere radioactivity monitoring channels inoperable (i.e., the required primary containment atmosphere monitoring system), grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic LEAKAGE information. Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be operated for up to 30 days to allow restoration of at least one of the required monitors.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available.

C.1 and C.2 If any Required Action and associated Completion Time of Condition A or B cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems.

D.1 With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

(continued)

Brunswick Unit 1 B 3.4.5-3 Revision No. 41 l

RCS Leakage Detection Instrumentation B 3.4.5 BASES (continued)

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere radioactivity monitoring system. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.5.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies, for the radioactivity monitoring channels only, the required alarm setpoint and relative accuracy of the instrument string.

The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 3.4.5.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 24 months is consistent with the Brunswick refueling cycle and considers channel reliability. Operating experience has proven this Frequency is acceptable.

REFERENCES 1. UFSAR, Section 5.2.5.

2. Regulatory Guide 1.45, May 1973.

3. GEAP-5620, Failure Behavior in ASTM Al 06B Pipes Containing Axial Through-Wall Flaws, April 1968.

4. NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping in Boiling Water Reactors, October 1975.

5. UFSAR, Section 5.2.5.2.2.

6. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 1 B 3.4.5-4 Revision No. 41 l

RCS Specific Activity B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Specific Activity BASES BACKGROUND During circulation, the reactor coolant acquires radioactive materials due to release of fission products from fuel leaks into the reactor coolant and activation of corrosion products in the reactor coolant. These radioactive materials in the reactor coolant can plate out in the RCS, and, at times, an accumulation will break away to spike the normal level of radioactivity. The release of coolant during a Design Basis Accident (DBA) could send radioactive materials into the environment.

Limits on the maximum allowable level of radioactivity in the reactor coolant are established to ensure that in the event of a release of any radioactive material to the environment during a DBA, radiation doses are maintained within the limits of 10 CFR 50.67 (Ref. 1).

This LCO contains iodine specific activity limits. The iodine isotopic activities per gram of reactor coolant are expressed in terms of a DOSE EQUIVALENT 1-131. The allowable levels are intended to limit the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months radiation dose to an individual at the site boundary to a small fraction of the 10 CFR 50.67 limit.

APPLICABLE Analytical methods and assumptions involving radioactive material in the SAFETY ANALYSES primary coolant are presented in References 2 and 3. The specific activity in the reactor coolant (the source term) is an initial condition for evaluation of the consequences of an accident due to a main steam line break (MSLB) outside containment. No fuel damage is postulated in the MSLB accident, and the release of radioactive material to the environment is assumed to end when the main steam isolation valves (MSIVs) close completely.

This MSLB release forms the basis for determining offsite doses (Ref. 2).

The limits on the specific activity of the primary coolant, assumed in the Reference 3 analyses, ensure that the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid and whole body doses at the site boundary, resulting from an MSLB outside containment during steady state operation, will not exceed 10% of the dose guidelines of 10 CFR 50.67.

RCS specific activity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 4).

(continued)

Brunswick Unit 1 B 3.4.6-1 Revision No. 41 l

RCS Specific Activity B 3.4.6 BASES (continued)

LCO The specific iodine activity is limited to

0.2 pCVgm DOSE EQUIVALENT 1-131. This limit ensures the source term assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 50.67 limits.

APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment.

In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced.

ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT 1-131 limit, but is

4.0 pCVgm, samples must be analyzed for DOSE EQUIVALENT 1-131 at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In addition, the specific activity must be restored to the LCO limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on the time needed to take and analyze a sample. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems. The upper limit of 4.0 pCi/gm ensures that the thyroid dose from an MSLB will not exceed the dose guidelines of 10 CFR 50.67 or control room operator dose limits specified in GDC 19 of 10 CFR 50, Appendix A (Ref. 5).

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

(continued)

Brunswick Unit 1 B 3.4.6-2 Revision No. 41 l

RCS Specific Activity B 3.4.6 BASES ACTIONS B.1, B.2.1. B.2.2.1, and B.2.2.2 (continued)

If the DOSE EQUIVALENT 1-131 cannot be restored to < 0.2 pCVgm within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if at any time it is > 4.0 pCi/gm, it must be determined at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and all the main steam lines must be isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 50.67 during a postulated MSLB accident.

Alternatively, the plant can be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable.

The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the time needed to take and analyze a sample. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This Surveillance is performed to ensure iodine remains within limit during normal operation. The 7 day Frequency is adequate to trend changes in the iodine activity level.

This SR is modified by a Note that requires this Surveillance to be performed only in MODE 1 because the level of fission products generated in other MODES is much less.

REFERENCES 1. 10 CFR 50.67.

2. UFSAR, Section 15.6.3.

3. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, dated September 1995.

4. 10 CFR 50.36(c)(2)(ii).

5. 10 CFR 50, Appendix A, GDC 19.

Brunswick Unit 1 B 3.4.6-3 Revision No. 41 l

RHR Shutdown Cooling System-Hot Shutdown

,.:. B 3.4.7 BASES APPLICABILITY condensing the steam in the main condenser. Additionally, in MODE 2 (continued) below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS-Operating") do not allow placing an RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR)-High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR)-Low Water Level."

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry Into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1, A.2, and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided.

With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

(continued)

Brunswick Unit 1 B 3.4.7-3 Revision No. 41 l

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES ACTIONS A.1. A.2, and A.3 (continued)

The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods are described in plant procedures.

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required to reduce the reactor coolant temperature to the point where MODE 4 is entered.

B.1. B.2. and B.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by an RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

(continued)

Brunswick Unit 1 B 3.4.7-4 Revision No. 41 l

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES (continued)

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after the pressure setpoint that isolates the shutdown cooling mode of the RHR System is reset, or for placing a recirculation pump in operation. The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

REFERENCES 1. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 1 B 3.4.7-5 Revision No. 41 l

ECCS-Operating B 3.5.1 BASES (continued)

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 If any one low pressure ECCS injection/spray subsystem is inoperable or if one LPCI pump in each subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days (e.g., if one LPCI pump in each subsystem is inoperable, both pumps must be restored within 7 days). In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e.,

Completion Times).

B.1 and B.2 If any CS subsystem is inoperable concurrent with one LPCI pump, the CS subsystem or the LPCI pump must be restored in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this condition, the remaining OPERABLE low pressure ECCS subsystems and the remaining pump in the inoperable LPCI subsystem provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single active component failure in any of the low pressure ECCS subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on the ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e.,

Completion Times).

(continued)

Brunswick Unit 1 B 3.5.1-6 Revision No. 41

RCIC System B 3.5.3 BASES BACKGROUND The RCIC pump is provided with a minimum flow bypass line, which (continued) discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is maintained full of water using a "keep fill" system.

APPLICABLE The function of the RCIC System is to respond to transient events by SAFETY ANALYSES providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the system satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 3) and is therefore included in the Technical Specifications.

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure S 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is verified immediately to be OPERABLE, the RCIC System must be restored to (contiinuedi Brunswick Unit 1 B 3.5.3-2 Revision No. 41 l

RHR Suppression Pool Cooling B 3.6.2.3 BASES (continued)

APPLICABLE References 1 and 2 contain the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break LOCAs. The intent of the analyses is to demonstrate that the heat removal capacity of the RHR Suppression Pool Cooling System is adequate to maintain the primary containment conditions within design limits. The suppression pool temperature is calculated to remain below the design limit.

The RHR Suppression Pool Cooling System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

LCO During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Refs. 1 and 2). To ensure that these requirements are met, two independent RHR suppression pool cooling subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool cooling subsystem is OPERABLE when two pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause both a release of radioactive material to the primary containment and a heatup and pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.

ACTIONS A.1 With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

I (continued)

Brunswick Unit 1 B 3.6.2.3-2 Revision No. 41 l

RHR Suppression Pool Cooling

-- B 3.6.2.3 BASES ACTIONS B.1 (continued)

With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available.

C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

(continued)

Brunswick Unit 1 B 3.6.2.3-3 Revision No. 41 l

RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE SR 3.6.2.3.2 REQUIREMENTS (continued) Verifying that each RHR pump develops a flow rate 2 7700 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment pressure and temperature can be maintained below the design limits during a DBA (Ref. 2). The normal test of centrifugal pump performance required by ASME Code, Section Xl (Ref. 4) is covered by the requirements of LCO 3.5.1, FECCS-Operating." This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such tests confirm component OPERABILITY, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is 92 days.

REFERENCES 1. UFSAR, Section 6.2.1.1.3.2.

2. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.

3. 10 CFR 50.36(c)(2)(ii).

4. ASME, Boiler and Pressure Vessel Code, Section Xl.

Brunswick Unit 1 B 3.6.2.3-4 Revision No. 41 l

CAD System B 3.6.3.2 BASES APPLICABILITY In MODE 3, both the hydrogen and oxygen production rates and (continued) the total amounts produced after a LOCA would be less than those calculated for the Design Basis Accident LOCA. Thus, if the analysis were to be performed starting with a LOCA in MODE 3, the time to reach a flammable concentration would be extended beyond the time conservatively calculated for MODE 1. The extended time would allow hydrogen removal from the primary containment atmosphere by other means and also allow repair of an inoperable CAD subsystem, if CAD were not available. Therefore, the CAD System is not required to be OPERABLE in MODE 3.

In MODES 4 and 5, the probability and consequences of a LOCA are reduced due to the pressure and temperature limitations of these MODES. Therefore, the CAD System is not required to be OPERABLE in MODES 4 and 5.

ACTIONS A.1 If the CAD System (one or both subsystems) is inoperable, it must be restored to OPERABLE status within 31 days. In this Condition, the oxygen control function of the CAD System is lost. However, alternate oxygen control capabilities may be provided by the Containment Inerting System. The 31 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flammability limit, the amount of time available after the event for operator action to prevent exceeding this limit, and the availability of other hydrogen mitigating systems.

I B.1 If Required Action A.1 cannot be met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 1 B 3.6.3.2-3 Revision No. 41 l

CAD System B 3.6.3.2 BASES (continued)

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS Verifying that there is > 4350 gal of liquid nitrogen supply in the CAD System will ensure at least 29 days of post-LOCA CAD operation. This minimum volume of liquid nitrogen allows sufficient time after an accident to replenish the nitrogen supply for long term inerting. This is verified every 31 days to ensure that the system is capable of performing its intended function when required. The 31 day Frequency is based on operating experience, which has shown 31 days to be an acceptable period to verify the liquid nitrogen supply and on the availability of other hydrogen mitigating systems.

SR 3.6.3.2.2 Verifying the correct alignment for manual, power operated, and automatic valves in each of the CAD subsystem flow paths provides assurance that the proper flow paths exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable because the CAD System is manually initiated. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day Frequency is appropriate because the valves are operated under procedural control, improper valve position would only affect a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system.

(continued)

Brunswick Unit 1 B 3.6.3.2-4 Revision No. 41 l

CAD System B 3.6.3.2 BASES SURVEILLANCE SR 3.6.3.2.3 REQUIREMENTS (continued) Cycling each power operated valve, excluding automatic valves, in the CAD System flow path through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. While this Surveillance may be performed with the reactor at power, the 24 month Frequency of the Surveillance is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1. Safety Guide 7, March 1971.

2. UFSAR, Section 6.2.5.3.2.1, Amendment No. 9.

3. 10 CFR 50.36(c)(2)(ii).

4. UFSAR, Table 6-11.

Brunswick Unit 1 B 3.6.3.2-5 Revision No. 41 l

RHRSW System B 3.7.1 BASES LCO the two RHRSW loops to be connected) must be available to (continued) provide the ability to isolate one subsystem from the other subsystem in the event of an RHRSW System suction line break.

The RHRSW cross tie valve may be opened provided the cross tie valve is capable of being closed from the control room.

The SW System must be capable of providing the proper RHRSW suction pressure for an RHRSW subsystem to be considered OPERABLE. The requirements for an adequate suction source are addressed in LCO 3.7.2, "Service Water (SW) System and Ultimate Heat Sink (UHS)".

APPLICABILITY In MODES 1, 2, and 3, the RHRSW System is required to be OPERABLE to support the OPERABILITY of the RHR System for primary containment cooling (LCO 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling" and decay heat removal (LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown"). The Applicability is therefore consistent with the requirements of these systems.

In MODES 4 and 5, the OPERABILITY requirements of the RHRSW System are determined by the systems it supports.

ACTIONS A.1 With one RHRSW pump inoperable, the inoperable pump must be restored to OPERABLE status within 14 days. With the unit in this condition, the remaining OPERABLE RHRSW pumps are adequate to perform the RHRSW heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced RHRSW capability. A risk based analysis was performed and determined that an allowable out of service time of 14 days (Ref. 6) is acceptable to permit restoration of an inoperable RHRSW pump to OPERABLE status.

I (continued)

Brunswick Unit 1 B 3.7.1-3 Revision No. 41 1

. -RHRSW System

' :.B3.7.1 BASES ACTIONS B.1 (continued)

Required Action B.1 is intended to handle the inoperability of one RHRSW subsystem for reasons other than Condition A. The Completion Time of 7 days is allowed to restore the RHRSW subsystem to OPERABLE status. With the unit in this condition, the remaining OPERABLE RHRSW subsystem is adequate to perform the RHRSW heat removal function.

However, the overall reliability is reduced because a single failure in the OPERABLE RHRSW subsystem could result in loss of RHRSW function.

The 7 day Completion Time is based on the Completion Time provided for the RHR suppression pool cooling function, the redundant RHRSW capabilities afforded by the OPERABLE subsystem, and the low probability of an event occurring requiring RHRSW during this period.

A Note to the Required Action indicates that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

C.1 With both RHRSW subsystems inoperable (e.g., one or two RHRSW pumps inoperable in each subsystem), the RHRSW System is not capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for restoring one RHRSW subsystem to OPERABLE status, is based on the Completion Time provided for the RHR suppression pool cooling function.

The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7, be entered and Required-Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

D.1 and D.2 If the RHRSW subsystems cannot be not restored to OPERABLE status within the associated Completion Times, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

Brunswick Unit 1 B 3.7.1-4 Revision No. 41 1

RHRSW System i.pr B3.7.1 BASES (continued)

SURVEILLANCE SR 3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual, power operated, and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths exist for RHRSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

REFERENCES 1. UFSAR, Section 9.2.1.2.

2. UFSAR, Chapter 6.2.

3. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995; and Supplement 1, March 1996.

4. Letter BR5-96-074, Long Term Suppression Pool Temperature-Suppression Pool Cooling Mode for Long Term Containment Cooling, from M. E. Ball (GE) to R. E. Helme (CP&L),

September 19, 1996.

5. 10 CFR 50.36(c)(2)(ii).

6. GENE-B2100565-09, Technical Specification Improvements to the Emergency Core Cooling System for the Carolina Power and Light Brunswick Steam Electric Plant Units 1 and 2, Revision 1, October 1996.

Brunswick Unit 1 B 3.7.1-5 Revision No. 41 l

AC Sources-Operating B 3.8.1 BASES LCO shutdown condition after an anticipated operational occurrence (AOO)

(continued) or a postulated DBA.

Qualified offsite circuits are those that are described in the UFSAR (Ref. 2), and are part of the licensing basis for the unit.

Each offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the emergency buses. An OPERABLE qualified offsite circuit consists of the incoming breakers and disconnects from the respective 230 kV switchyard to and including the SAT or UAT, the respective circuit path to and including the BOP buses, and the circuit path to two 4.16 kV emergency buses including associated feeder (master/slave) breakers.

Each DG must be capable of starting, accelerating to minimum acceptable frequency and voltage, and connecting to its respective emergency bus on detection of bus undervoltage. This sequence must be accomplished within 10.5 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the emergency buses. These capabilities are required to be met from a variety of initial conditions, such as DG in standby with the engine at ambient condition.

Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to ready-to-load status on an ECCS signal while operating in parallel test mode. Each DG is required to have an OPERABLE air start system. Additionally, proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

The AC sources must be separate and independent (to the extent possible) of other AC sources. For the DGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practical. An offsite circuit may be connected to more than one emergency bus, with manual transfer capability to the other offsite circuit available, and not violate separation criteria. If the preferred offsite circuit (i.e., the circuit path from a 230 kV bus through the SAT to the associated onsite Class 1E emergency buses) is not connected to an emergency bus, the circuit is required to have OPERABLE fast transfer capability to two emergency buses to support OPERABILITY of that circuit.

(continued)

Brunswick Unit 1 B 3.8.1-4 Revision No. 41 l

I AC Sources-Operating

>EB 3.8.1 BASES (continued)

APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in LCO 3.8.2, "AC Sources-Shutdown."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 The offsite circuits for two of the four 4.16 kV emergency buses utilize the opposite unit's SAT and UAT. Therefore, this Required Action provides a 45 day time period to perform maintenance on one of the opposite unit's transformers. This is acceptable because performing maintenance on the transformer will increase the reliability of the offsite circuit. However, if a second Unit 1 or 2 offsite circuit becomes inoperable, Conditions C and E are entered.

The 45 day Completion Time takes into account the capacity and capability of the remaining AC sources and a reasonable time for performance of maintenance.

The Note to Condition A only allows the 45 day Completion Time to be used when the opposite unit is in MODE 4 or 5. When a Unit 2 offsite circuit becomes inoperable while Unit 2 is in MODE 1, 2, or 3, Condition C of Unit 1 Specification 3.8.1 must be entered and the associated Required Actions performed.

(continued)

Brunswick Unit 1 B 3.8.1-5 Revision No. 41 l

BSEP 05-0082 Enclosure 4 Unit 2 Technical Specification Bases Replacement Pages

Unit 2 - Bases Book I Replacement Pages

BASES TO THE FACILITY OPERATING LICENSE DPR-62 TECHNICAL SPECIFICATIONS FOR BRUNSWICK STEAM ELECTRIC PLANT UNIT 2 CAROLINA POWER & LIGHT COMPANY REVISION 39

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

Title Page 39 B 3.1.1-6 30 I B 3.1.2-1 30 List of Effective Pages - Book 1 B 3.1.2-2 30 B 3.1.2-3 30 LOEP-1 39 B 3.1.2-4 30 LOEP-2 39 B 3.1.2-5 30 LOEP-3 39 B 3.1.3-1 30 LOEP-4 35 B 3.1.3-2 30 B 3.1.3-3 30 30 B 3.1.3-4 30 ii 30 B 3.1.3-5 30 B 3.1.3-6 30 B 2.1.1-1 30 B 3.1.3-7 30 B 2.1.1-2 30 B 3.1.3-8 30 B 2.1.1-3 30 B 3.1.3-9 30 B 2.1.1-4 30 B 3.1.4-1 30 B 2.1.1-5 30 B 3.1.4-2 30 B 2.1.2-1 30 B 3.1.4-3 30 B 2.1.2-2 30 B 3.1.4-4 30 B 2.1.2-3 30 B 3.1.4-5 30 B 3.1.4-6 30 B 3.0-1 30 B 3.1.4-7 30 B 3.0-2 30 B 3.1.5-1 30 B 3.0-3 30 B 3.1.5-2 30 B 3.0-4 30 B 3.1.5-3 30 B 3.0-5 39 B 3.1.5-4 30 B 3.0-6 39 B 3.1.5-5 30 B 3.0-7 39 B 3.1.6-1 30 B 3.0-8 39 B 3.1.6-2 30 B 3.0-9 39 B 3.1.6-3 30 B 3.0-10 39 B 3.1.6-4 30 B 3.0-11 39 B 3.1.6-5 30 B 3.0-12 39 B 3.1.7-1 30 B 3.0-13 39 B 3.1.7-2 30 B 3.0-14 39 B 3.1.7-3 30 B 3.0-15 39 B 3.1.7-4 30 B 3.0-16 39 B 3.1.7-5 30 B 3.0-17 39 B 3.1.7-6 30 B 3.1.8-1 30 B 3.1.1-1 30 B 3.1.8-2 34 B 3.1.1-2 30 B 3.1.8-3 34 B 3.1.1-3 30 B 3.1.8-4 30 B 3.1.1-4 30 B 3.1.8-5 30 B 3.1.1-5 30 (continued)

Brunswick Unit 2 LOEP-1 Revision 39 l

LIST OF EFFECTIVE PAGES - BASES (continued)

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

B 3.3.3.1-4 30 B 3.3.5.1-17 30 B 3.3.3.1-5 30 B 3.3.5.1-18 33 B 3.3.3.1-6 38 B 3.3.5.1-19 33 B 3.3.3.1-7 39 B 3.3.5.1-20 30 I B 3.3.3.1-8 38 B 3.3.5.1-21 30 B 3.3.3.1-9 38 B 3.3.5.1-22 30 B 3.3.3.1 -10 38 B 3.3.5.1-23 30 B 3.3.3.2-1 39 B 3.3.5.1-24 30 B 3.3.3.2-2 39 B 3.3.5.1-25 30 B 3.3.3.2-3 39 B 3.3.5.1-26 30 B 3.3.3.2-4 39 B 3.3.5.1-27 30 B 3.3.3.2-5 39 B 3.3.5.1-28 30 B 3.3.4.1-1 30 B 3.3.5.1-29 30 B 3.3.4.1-2 30 B 3.3.5.1-30 30 B 3.3.4.1-3 30 B 3.3.5.1-31 33 B 3.3.4.1-4 30 B 3.3.5.2-1 30 B 3.3.4.1-5 30 B 3.3.5.2-2 30 B 3.3.4.1-6 30 B 3.3.5.2-3 30 B 3.3.4.1-7 30 B 3.3.5.2-4 30 B 3.3.4.1-8 30 B 3.3.5.2-5 30 B 3.3.4.1-9 30 B 3.3.5.2-6 30 B 3.3.5.1-1 30 B 3.3.5.2-7 30 B 3.3.5.1-2 30 B 3.3.5.2-8 30 B 3.3.5.1-3 30 B 3.3.5.2-9 30 B 3.3.5.1-4 33 B 3.3.5.2-10 30 B 3.3.5.1-5 30 B 3.3.5.2-11 30 B 3.3.5.1-6 30 B 3.3.6.1 -1 30 B 3.3.5.1-7 30 B 3.3.6.1-2 30 B 3.3.5.1 -8 30 B 3.3.6.1-3 30 B 3.3.5.1-9 30 B 3.3.6.1-4 30 B 3.3.5.1 -10 30 B 3.3.6.1-5 30 B 3.3.5.1-11 30 B 3.3.6.1-6 30 B 3.3.5.1-12 30 B 3.3.6.1-7 30 B 3.3.5.1-13 33 B 3.3.6.1-8 31 B 3.3.5.1-14 33 B 3.3.6.1-9 30 B 3.3.5.1-15 33 B 3.3.6.1 -10 30 B 3.3.5.1-16 33 B 3.3.6.1 -11 30 B 3.3.6.1-12 30 B 3.3.6.1-13 30 B 3.3.6.1-14 30 (continued)

Brunswick Unit 2 LOEP-3 Revision 39 1

LCO Applicability

-ad; B3.0 BASES LCO 3.0.3 LCO 3.7.7 has an Applicability of "During movement of irradiated fuel (continued) assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in l

accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The (continued)

Brunswick Unit 2 B 3.0-5 Revision No. 39 l

LCO Applicability B3.0 BASES LCO 3.0.4 risk assessments will be conducted using the procedures and guidance (continued) endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.' These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not (continued)

Brunswick Unit 2 B 3.0-6 Revision No. 39 l

LCO Applicability B3.0 BASES LCO 3.0.4 been performed. This allowance may apply to all the ACTIONS or to a (continued) specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

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

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

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

I LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

(continued)

Brunswick Unit 2 B 3.0-7 Revision No. 39 l

LCO Applicability B 3.0 BASES LCO 3.0.5 The administrative controls ensure the time the equipment is returned to (continued) service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system's LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system's LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability.

(continued)

Brunswick Unit 2 B 3.0-8 Revision No. 39 l

LCO Applicability B3.0 BASES LCO 3.0.6 However, it is not necessary to enter into the supported systems' (continued) Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.11, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

(continued)

Brunswick Unit 2 B 3.0-9 Revision No. 39 l

LCO Applicability IJ:-#, ;: B 3.0 BASES (continued)

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

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

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

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

Brunswick Unit 2 B 3.0-1 0 Revision No. 39 l

SR Applicability 6 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

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

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

a. The systems or components are known to be inoperable, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

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

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

(continued)

Brunswick Unit 2 B 3.0-1 1 Revision No. 39 l

SR Applicability B3.0 BASES SR 3.0.1 Surveillances, including Surveillances invoked by Required Actions, (continued) do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.

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

Some examples of this process are:

a. Control Rod Drive maintenance during refueling that requires scram testing at > 800 psi. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 800 psi to perform other necessary testing.

b. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

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

(continued)

Brunswick Unit 2 B 3.0-1 2 Revision No. 39 l

SR Applicability B3.0 BASES SR 3.0.2 SR 3.0.2 permits a 25% extension of the interval specified in the (continued) Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

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

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

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

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

(continued)

Brunswick Unit 2 B 3.0-1 3 Revision No. 39 l

SR Applicability B3.0 BASES (continued)

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

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

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

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

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

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

Brunswick Unit 2 B 3.0-14 Revision No. 39 l

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

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

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

(continued)

Brunswick Unit 2 B 3.0-1 5 Revision No. 39 l

SR Applicability B3.0 BASES (continued)

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

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

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

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

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

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

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

(continued)

Brunswick Unit 2 B 3.0-1 6 Revision No. 39 l

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

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

I Brunswick Unit 2 B 3.0-17 Revision No. 39 l

j PAM Instrumentation B 3.3.3.1

8 ,. , , a .1 BASES LCO 7. DrvwellTemperature (continued) by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

8. Primary Containment Isolation Valve (PCIV) Position PCIV position, a Category I variable, is provided for verification of containment integrity. In the case of PCIV position, the important information is the isolation status of the containment penetration. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

The PCIV position PAM instrumentation consists of position switches, associated wiring and control room indication for active PCIVs (check valves and manual valves are not required to have position indication).

Therefore, the PAM Specification deals specifically with these instrument channels.

9. (Not Used)

10. Drywell Area Radiation Drywell area radiation is a Category I variable provided to monitor the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. Post accident drywell area radiation levels are monitored by four instruments, each with a range of 1 R/hr to 107 R/hr.

The outputs of these channels are indicated and recorded in the control room. Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

Brunswick Unit 2 B 3.3.3.1-6 Revision No. 38 l

PAM Instrumentation B 3.3.3.1 BASES (continued)

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS A Note has been provided to modify the ACTIONS related to PAM instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable PAM instrumentation channels provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable PAM Function.

A.1 When one or more Functions have one required channel that is inoperable, the required inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channels, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval.

(continued)

Brunswick Unit 2 B 3.3.3.1-7 Revision No. 39 l

PAM Instrumentation

-:,~~~ &,;- B3.3.3.1 BASES ACTIONS B.1 (continued)

If a channel has not been restored to OPERABLE status in 30 days, this Required Action specifies initiation of action in accordance with Specification 5.6.6, which requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This Required Action is appropriate in lieu of a shutdown requirement, since another OPERABLE channel is monitoring the Function, and given the likelihood of plant conditions that would require information provided by this instrumentation.

C.1 When one or more Functions have two required channels that are inoperable (i.e., two channels inoperable in the same Function), one channel in the Function should be restored to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information.

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

D.1 This Required Action directs entry into the appropriate Condition referenced in Table 3.3.3.1-1. The applicable Condition referenced in the Table is Function dependent. Each time an inoperable channel has not met the Required Action of Condition C and the associated Completion Time has expired, Condition D is entered for that channel and provides for transfer to the appropriate subsequent Condition.

E.1 For the majority of Functions in Table 3.3.3.1-1, if any Required Action and associated Completion Time of Condition C is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 2 B 3.3.3.1 -8 Revision No. 38 l

PAM Instrumentation B 3.3.3.1 BASES ACTIONS F.1 (continued)

Since alternate means of monitoring primary containment area radiation are available, the Required Action is not to shut down the plant, but rather to follow the directions of Specification 5.6.6. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.

SURVEILLANCE As noted at the beginning of the SRs, the following SRs apply to each REQUIREMENTS PAM instrumentation Function in Table 3.3.3.1-1.

SR 3.3.3.1.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel against a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar plant instruments located throughout the plant.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The Frequency of 31 days is based upon plant operating experience, with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31 day interval is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the channels required by the LCO.

(continued)

Brunswick Unit 2 B 3.3.3.1-9 Revision No. 38 l

PAM Instrumentation

; I B 3.3.3.1 BASES SURVEILLANCE SR 3.3.3.1.2 REQUIREMENTS (continued) Not Used.

SR 3.3.3.1.3 This SR requires a CHANNEL CALIBRATION to be performed.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured parameter with the necessary range and accuracy. I For Function 10, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.

The 24 month Frequency for CHANNEL CALIBRATION of PAM I Instrumentation of Table 3.3.3.1-1 is based on operating experience and consistency with the BNP refueling cycles.

REFERENCES 1. Regulatory Guide 1.97, Instrumentation for Lighi Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, December 1980.

2. NRC Safety Evaluation Report, Conformance to Regulatory Guide 1.97, Rev. 2, Brunswick Steam Electric Plant, Units 1 and 2, May 14, 1985.

3. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 2 B 3.3.3.1 -1 0 Revision No. 38 l

-1 Remote Shutdown Monitoring Instrumentation

,A -.;4,

.1I:,

B 3.3.3.2 B 3.3 INSTRUMENTATION B 3.3.3.2 Remote Shutdown Monitoring Instrumentation BASES BACKGROUND The remote shutdown monitoring instrumentation provides the control room operator with sufficient instrumentation to support placing and maintaining the plant in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility of the control room becoming inaccessible. A safe shutdown condition is defined as MODE 3. With the plant in MODE 3, the Reactor Core Isolation Cooling (RCIC) System, the safety/relief valves, and the Residual Heat Removal (RHR) System can be used to remove core decay heat and meet all safety requirements. The long term supply of water for the RCIC System and the ability to operate shutdown cooling from outside the control room allow extended operation in MODE 3.

In the event that the control room becomes inaccessible, the operators can monitor the status of the reactor and primary containment and the operation of the RCIC and RHR Systems at the remote shutdown panel and place and maintain the plant in MODE 3. Controls and selector switches will have to be operated locally at the switchgear, motor control panels, or other local stations. The plant is in MODE 3 following a plant shutdown and can be maintained safely in MODE 3 for an extended period of time.

The OPERABILITY of the remote shutdown monitoring instrumentation Functions ensures that there is sufficient information available on selected plant parameters to place and maintain the plant in MODE 3 should the control room become inaccessible.

APPLICABLE The remote shutdown monitoring instrumentation is required to provide SAFETY ANALYSES equipment at appropriate locations outside the control room with a design capability to monitor the prompt shutdown of the reactor to MODE 3, including the necessary instrumentation to support maintaining the plant in a safe condition in MODE 3.

The criteria governing the design and the specific system requirements of the remote shutdown monitoring instrumentation are located in the UFSAR (Ref. 1).

The Remote Shutdown Monitoring Instrumentation is considered an important contributor to reducing the risk of accidents; as such, it meets Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).

(continued)

Brunswick Unit 2 B 3.3.3.2-1 Revision No. 39 l

Remote Shutdown Monitoring Instrumentation

. .. B 3.3.3.2 BASES (continued)

LCO The Remote Shutdown Monitoring Instrumentation LCO provides the requirements for the OPERABILITY of the monitoring instrumentation necessary to support placing and maintaining the plant in MODE 3 from a location other than the control room. The monitoring instrumentation required are listed in Table B 3.3.3.2-1.

The monitoring instrumentation are those required for:

Reactor pressure vessel (RPV) pressure control;

Decay heat removal; and

RPV inventory control.

The remote shutdown monitoring instrumentation is OPERABLE if all instrument channels needed to support the remote shutdown monitoring function are OPERABLE with readouts displayed external to the control room.

The remote shutdown monitoring instruments covered by this LCO do not need to be energized to be considered OPERABLE. This LCO is intended to ensure that the instruments will be OPERABLE if plant conditions require that the remote shutdown monitoring instrumentation be placed in operation.

APPLICABILITY The Remote Shutdown Monitoring Instrumentation LCO is applicable in MODES 1 and 2. This is required so that the plant can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.

This LCO is not applicable in MODES 3, 4, and 5. In these MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument Functions if control room instruments or control becomes unavailable. Consequently, the LCO does not require OPERABILITY in MODES 3,4, and 5.

(continued)

Brunswick Unit 2 B 3.3.3.2-2 Revision No. 39 l

Remote Shutdown Monitoring Instrumentation

'B 3.3.3.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to Remote Shutdown Monitoring Instrumentation Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown Monitoring Instrumentation Functions provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown Monitoring Instrumentation Function.

A.1 Condition A addresses the situation where one or more required Functions of the remote shutdown monitoring instrumentation is inoperable. This includes any Function listed in Table B 3.3.3.2-1. The Required Action is to restore the Function (all required channels) to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

B.1 If the Required Action and associated Completion Time of Condition A are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 2 B 3.3.3.2-3 Revision No. 39 l

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 BASES (continued)

SURVEILLANCE SR 3.3.3.2.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels that are normally energized. For Function 2 of Table B 3.3.3.2-1, the CHANNEL CHECK requirement does not apply to the NO17 instrument loop since this instrument loop has no displayed indication. The CHANNEL CHECK requirement does apply to the remaining instruments of Function 2.

The Frequency is based upon plant operating experience that demonstrates channel failure is rare.

SR 3.3.3.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.

The 24 month Frequency is based upon operating experience and consistency with the BNP refueling cycle.

REFERENCES 1. UFSAR, Section 7.4.4.

2. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 2 B 3.3.3.2-4 Revision No. 39 l

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 Table B 3.3.3.2-1 (page 1 of 1)

Remote Shutdown Monitoring Instrumentation REQUIRED READOUT NUMBER OF FUNCTION LOCATION CHANNELS

1. Reactor Vessel Pressure (a) 1

2. Reactor Vessel Water Level (a) 1

3. Suppression Chamber Water Level (a) 1

4. Suppression Chamber Water Temperature (a) 1

5. Drywell Pressure (a) 1

6. Drywell Temperature (a) 1

7. Residual Heat Removal System Flow (a) 1 (a) Remote Shutdown Panel, Reactor Building 20 ft. Elevation Brunswick Unit 2 B 3.3.3.2-5 Revision No. 39 l

Unit 2 - Bases Book 2 Replacement Pages

LIST OF EFFECTIVE PAGES - BASES '- .4 Page No. Revision No. Page No. Revision No.

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

Brunswick Unit 2 LOEP-1 Revision 39 l

LIST OF EFFECTIVE PAGES

.z

- BASES (continued)

Paqe No. Revision No. Pane No. Revision No.

B 3.5.3-3 30 B 3.6.1.5-6 30 B 3.5.3-4 30 B 3.6.1.5-7 30 B 3.5.3-5 30 B 3.6.1.5-8 33 B 3.5.3-6 30 B 3.6.1.5-9 30 B 3.5.3-7 30 B 3.6.1.6-1 30 B 3.6.1.6-2 30 B 3.6.1.1-1 30 B 3.6.1.6-3 30 B 3.6.1.1-2 30 B 3.6.1.6-4 30 B 3.6.1.1-3 30 B 3.6.1.6-5 30 B 3.6.1.1-4 30 B 3.6.1.6-6 30 B 3.6.1.1-5 30 B 3.6.2.1 -1 30 B 3.6.1.1-6 30 B 3.6.2.1-2 30 B 3.6.1.2-1 30 B 3.6.2.1-3 30 B 3.6.1.2-2 30 B 3.6.2.1-4 30 B 3.6.1.2-3 30 B 3.6.2.1-5 30 B 3.6.1.2-4 30 B 3.6.2.2-1 30 B 3.6.1.2-5 30 B 3.6.2.2-2 30 B 3.6.1.2-6 30 B 3.6.2.2-3 30 B 3.6.1.2-7 30 B 3.6.2.3-1 30 B 3.6.1.2-8 30 B 3.6.2.3-2 39 B 3.6.1.2-9 30 B 3.6.2.3-3 39 B 3.6.1.3-1 30 B 3.6.2.3-4 39 B 3.6.1.3-2 30 B 3.6.3.1 -1 30 B 3.6.1.3-3 30 B 3.6.3.1-2 30 B 3.6.1.3-4 30 B 3.6.3.1-3 30 B 3.6.1.3-5 30 B 3.6.3.2-1 30 B 3.6.1.3-6 30 B 3.6.3.2-2 30 B 3.6.1.3-7 30 B 3.6.3.2-3 39 B 3.6.1.3-8 30 B 3.6.3.2-4 39 B 3.6.1.3-9 30 B 3.6.3.2-5 39 B 3.6.1.3-10 30 B 3.6.4.1 -1 30 B 3.6.1.3-11 30 B 3.6.4.1-2 30 B 3.6.1.3-12 30 B 3.6.4.1-3 30 B 3.6.1.3-13 30 B 3.6.4.1-4 30 B 3.6.1.3-14 30 B 3.6.4.1-5 30 B 3.6.1.3-15 30 B 3.6.4.2-1 30 B 3.6.1.4-1 30 B 3.6.4.2-2 30 B 3.6.1.4-2 30 B 3.6.4.2-3 30 B 3.6.1.4-3 30 B 3.6.4.2-4 30 B 3.6.1.5-1 30 B 3.6.4.2-5 30 B 3.6.1.5-2 30 B 3.6.4.2-6 30 B 3.6.1.5-3 30 B 3.6.4.3-1 30 B 3.6.1.5-4 30 B 3.6.4.3-2 30 B 3.6.1.5-5 30 B 3.6.4.3-3 30 (continued)

Brunswick Unit 2 LOEP-2 Revision 39 l

LIST OF EFFECTIVE PAGES - BASES (continued) .:

? I , k k Paae No. Revision No. Page No. Revision No.

B 3.6.4.3-4 30 B 3.7.7-1 30 B 3.6.4.3-5 30 B 3.7.7-2 30 B 3.6.4.3-6 30 B 3.7.7-3 30 B3.7.1-1 30 B 3.8.1-1 30 B 3.7.1-2 30 B3.8.1-2 30 B 3.7.1-3 39 B 3.8.1-3 33 B 3.7.1-4 39 B 3.8.1-4 39 B 3.7.1-5 39 B 3.8.1-5 39 B 3.7.2-1 30 B 3.8.1-6 30 B 3.7.2-2 30 B3.8.1-7 30 B 3.7.2-3 30 B 3.8.1-8 30 B 3.7.2-4 30 B 3.8.1-9 30 B 3.7.2-5 30 B 3.8.1 -10 30 B 3.7.2-6 30 B 3.8.1-11 30 B 3.7.2-7 30 B 3.8.1-12 30 B 3.7.2-8 30 B 3.8.1-13 30 B 3.7.2-9 30 B 3.8.1-14 30 B 3.7.2-10 30 B 3.8.1-15 30 B 3.7.2-11 30 B 3.8.1-16 30 B 3.7.2-12 30 B 3.8.1-17 30 B 3.7.2-13 30 B 3.8.1-18 30 B 3.7.2-14 30 B 3.8.1-19 30 B 3.7.3-1 30 B 3.8.1-20 30 B 3.7.3-2 33 B 3.8.1-21 30 B 3.7.3-3 30 B 3.8.1-22 30 B 3.7.3-4 30 B 3.8.1-23 30 B 3.7.3-5 30 B 3.8.1-24 30 B 3.7.3-6 30 B 3.8.1-25 30 B 3.7.3-7 33 B 3.8.1-26 30 B 3.7.4-1 30 B 3.8.1-27 30 B 3.7.4-2 30 B 3.8.1-28 35 B 3.7.4-3 30 B 3.8.1-29 30 B 3.7.4-4 30 B 3.8.1-30 30 B 3.7.4-5 30 B 3.8.1-31 30 B 3.7.5-1 30 B 3.8.1-32 30 B 3.7.5-2 30 B 3.8.1-33 33 B 3.7.5-3 30 B 3.8.1-34 30 B 3.7.6-1 30 B 3.8.2-1 30 B 3.7.6-2 30 B 3.8.2-2 30 B 3.7.6-3 30 B 3.8.2-3 30 B 3.7.6-4 30 B 3.8.2-4 30 B 3.8.2-5 30 (continued)

Brunswick Unit 2 LOEP-3 Revision 39 l

RCS Leakage Detection Instrumentation

' ;B 3.4.5 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4.

ACTIONS A.1 With the drywell floor drain sump flow monitoring system inoperable, no other required instrumentation can provide the equivalent information to quantify LEAKAGE. However, the primary containment atmosphere radioactivity monitor will provide indication of changes in LEAKAGE.

With the drywell floor drain sump flow monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (SR 3.4.4.1), operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available.

B.1 and B.2 With both gaseous and particulate primary containment atmosphere radioactivity monitoring channels inoperable (i.e., the required primary containment atmosphere monitoring system), grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic LEAKAGE information. Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be operated for up to 30 days to allow restoration of at least one of the required monitors.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available.

C.1 and C.2 If any Required Action and associated Completion Time of Condition A or B cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems.

D.1 With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

(continued)

Brunswick Unit 2 B 3.4.5-3 Revision No. 39 l

RCS Leakage Detection Instrumentation B 3.4.5 BASES (continued)

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere radioactivity monitoring system. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.5.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies, for the radioactivity monitoring channels only, the required alarm setpoint and relative accuracy of the instrument string.

The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 3.4.5.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 24 months is consistent with the Brunswick refueling cycle and considers channel reliability. Operating experience has proven this Frequency is acceptable.

REFERENCES 1. UFSAR, Section 5.2.5.

2. Regulatory Guide 1.45, May 1973.

3. GEAP-5620, Failure Behavior in ASTM Al 06B Pipes Containing Axial Through-Wall Flaws, April 1968.

4. NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping in Boiling Water Reactors, October 1975.

5. UFSAR, Section 5.2.5.2.2.

6. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 2 B 3.4.5-4 Revision No. 39 l

RCS Specific Activity B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Specific Activity BASES BACKGROUND During circulation, the reactor coolant acquires radioactive materials due to release of fission products from fuel leaks into the reactor coolant and activation of corrosion products in the reactor coolant. These radioactive materials in the reactor coolant can plate out in the RCS, and, at times, an accumulation will break away to spike the normal level of radioactivity. The release of coolant during a Design Basis Accident (DBA) could send radioactive materials into the environment.

Limits on the maximum allowable level of radioactivity in the reactor coolant are established to ensure that in the event of a release of any radioactive material to the environment during a DBA, radiation doses are maintained within the limits of 10 CFR 50.67 (Ref. 1).

This LCO contains iodine specific activity limits. The iodine isotopic activities per gram of reactor coolant are expressed in terms of a DOSE EQUIVALENT 1-131. The allowable levels are intended to limit the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months radiation dose to an individual at the site boundary to a small fraction of the 10 CFR 50.67 limit.

APPLICABLE Analytical methods and assumptions involving radioactive material in the SAFETY ANALYSES primary coolant are presented in References 2 and 3. The specific activity in the reactor coolant (the source term) is an initial condition for evaluation of the consequences of an accident due to a main steam line break (MSLB) outside containment. No fuel damage is postulated in the MSLB accident, and the release of radioactive material to the environment is assumed to end when the main steam isolation valves (MSIVs) close completely.

This MSLB release forms the basis for determining offsite doses (Ref. 2).

The limits on the specific activity of the primary coolant, assumed in the Reference 3 analyses, ensure that the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid and whole body doses at the site boundary, resulting from an MSLB outside containment during steady state operation, will not exceed 10% of the dose guidelines of 10 CFR 50.67.

RCS specific activity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 4).

(continued)

Brunswick Unit 2 B 3.4.6-1 Revision No. 39 l

RCS Specific Activity B 3.4.6

. It~

(',*

BASES (continued)

LCO The specific iodine activity is limited to

0.2 pCVgm DOSE EQUIVALENT 1-131. This limit ensures the source term assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 50.67 limits.

APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment.

In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced.

ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT 1-131 limit, but is

4.0 pCVgm, samples must be analyzed for DOSE EQUIVALENT 1-131 at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In addition, the specific activity must be restored to the LCO limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on the time needed to take and analyze a sample. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems. The upper limit of 4.0 pCVgm ensures that the thyroid dose from an MSLB will not exceed the dose guidelines of 10 CFR 50.67 or control room operator dose limits specified in GDC 19 of 10 CFR 50, Appendix A (Ref. 5).

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

(continued)

Brunswick Unit 2 B 3.4.6-2 Revision No. 39 l

RCS Specific Activity B 3.4.6

.1 -

BASES ACTIONS B.1, B.2.1, B.2.2.1. and B.2.2.2 (continued)

If the DOSE EQUIVALENT 1-131 cannot be restored to

0.2 pCVgm within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if at any time it is > 4.0 pCigm, it must be determined at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and all the main steam lines must be isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 50.67 during a postulated MSLB accident.

Alternatively, the plant can be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable.

The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the time needed to take and analyze a sample. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This Surveillance is performed to ensure iodine remains within limit during normal operation. The 7 day Frequency is adequate to trend changes in the iodine activity level.

This SR is modified by a Note that requires this Surveillance to be performed only in MODE 1 because the level of fission products generated in other MODES is much less.

REFERENCES 1. 10 CFR 50.67.

2. UFSAR, Section 15.6.3.

3. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, dated September 1995.

4. 10 CFR 50.36(c)(2)(ii).

5. 10 CFR 50, Appendix A, GDC 19.

Brunswick Unit 2 B 3.4.6-3 Revision No. 39 1

'RHRShutdown Cooling System-Hot Shutdown II B 3.4.7 S ES I- i- !

BASES APPLICABILITY condensing the steam in the main condenser. Additionally, in MODE 2 (continued) below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS-Operating") do not allow placing an RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR)-High Water Level"; and LCO 3.9.8, 'Residual Heat Removal (RHR)-Low Water Level."

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1. A.2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided.

With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

(continued)

Brunswick Unit 2 B 3.4.7-3 Revision No. 39 l

RHR Shutdown Cooling System-Hot Shutdown

- ¢B 3.4.7 BASES ACTIONS A.1. A.2, and A.3 (continued)

The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods are described in plant procedures.

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required to reduce the reactor coolant temperature to the point where MODE 4 is entered.

B.1, B.2, and B.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each

-occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by an RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

(continued)

Brunswick Unit 2 B 3.4.7-4 Revision No. 39 l

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES (continued)

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after the pressure setpoint that isolates the shutdown cooling mode of the RHR System is reset, or for placing a recirculation pump in operation. The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be Onot met" at the time of entry into the Applicability.

REFERENCES 1. 10 CFR 50.36(c)(2)(ii).

Brunswick Unit 2 B 3.4.7-5 Revision No. 39 l

ECCS-Operating B 3.5.1 BASES (continued)

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 If any one low pressure ECCS injection/spray subsystem is inoperable or if one LPCI pump in each subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days (e.g., if one LPCI pump in each subsystem is inoperable, both pumps must be restored within 7 days). In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e.,

Completion Times).

B.1 and B.2 If any CS subsystem is inoperable concurrent with one LPCI pump, the CS subsystem or the LPCI pump must be restored in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this condition, the remaining OPERABLE low pressure ECCS subsystems and the remaining pump in the inoperable LPCI subsystem provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single active component failure in any of the low pressure ECCS subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on the ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e.,

Completion Times).

(continued)

Brunswick Unit 2 B 3.5.1-6 Revision No. 39 l

RCIC System

, t B 3.5.3

-, j I.",'

BASES BACKGROUND The RCIC pump is provided with a minimum flow bypass line, which (continued) discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is maintained full of water using a "keep fill" system.

APPLICABLE The function of the RCIC System is to respond to transient events by SAFETY ANALYSES providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the system satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 3) and is therefore included in the Technical Specifications.

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure < 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is verified immediately to be OPERABLE, the RCIC System must be restored to (continued)

Brunswick Unit 2 B 3.5.3-2 Revision No. 39 l

RHR Suppression Pool Cooling B 3.6.2.3 4L ),

BASES (continued)

APPLICABLE References 1 and 2 contain the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break LOCAs. The intent of the analyses is to demonstrate that the heat removal capacity of the RHR Suppression Pool Cooling System is adequate to maintain the primary containment conditions within design limits. The suppression pool temperature is calculated to remain below the design limit.

The RHR Suppression Pool Cooling System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

LCO During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Refs. 1 and 2). To ensure that these requirements are met, two independent RHR suppression pool cooling subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool cooling subsystem is OPERABLE when two pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause both a release of radioactive material to the primary containment and a heatup and pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.

ACTIONS A.1 With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

I (continued)

Brunswick Unit 2 B 3.6.2.3-2 Revision No. 39 l

RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS B.1 (continued)

With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available.

C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

(continued)

Brunswick Unit 2 B 3.6.2.3-3 Revision No. 39 l

RHR Suppression Pool Cooling i.. i' f.-

B 3.6.2.3 t'..;,,

BASES SURVEILLANCE SR 3.6.2.3.2 REQUIREMENTS (continued) Verifying that each RHR pump develops a flow rate 2 7700 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment pressure and temperature can be maintained below the design limits during a DBA (Ref. 2). The normal test of centrifugal pump performance required by ASME Code, Section Xl (Ref . 4) is covered by the requirements of LCO 3.5.1, "ECCS-Operating." Thistest confirms one point on the pump design curve, and the results are indicative of overall performance. Such tests confirm component OPERABILITY, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is 92 days.

REFERENCES 1. UFSAR, Section 6.2.1.1.3.2.

2. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.

3. 10 CFR 50.36(c)(2)(ii).

4. ASME, Boiler and Pressure Vessel Code, Section Xl.

Brunswick Unit 2 B 3.6.2.3-4 Revision No. 39 l

.. . I .

CAD System B 3.6.3.2

-ur.-, .

BASES APPLICABILITY In MODE 3, both the hydrogen and oxygen production rates and (continued) the total amounts produced after a LOCA would be less than those calculated for the Design Basis Accident LOCA. Thus, if the analysis were to be performed starting with a LOCA in MODE 3, the time to reach a flammable concentration would be extended beyond the time conservatively calculated for MODE 1. The extended time would allow hydrogen removal from the primary containment atmosphere by other means and also allow repair of an inoperable CAD subsystem, if CAD were not available. Therefore, the CAD System is not required to be OPERABLE in MODE 3.

In MODES 4 and 5, the probability and consequences of a LOCA are reduced due to the pressure and temperature limitations of these MODES. Therefore, the CAD System is not required to be OPERABLE in MODES 4 and 5.

ACTIONS A.1 If the CAD System (one or both subsystems) is inoperable, it must be restored to OPERABLE status within 31 days. In this Condition, the oxygen control function of the CAD System is lost. However, alternate oxygen control capabilities may be provided by the Containment Inerting System. The 31 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flammability limit, the amount of time available after the event for operator action to prevent exceeding this limit, and the availability of other hydrogen mitigating systems.

I B.1 If Required Action A.1 cannot be met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 2 B 3.6.3.2-3 Revision No. 39 l

CAD System B 3.6.3.2 BASES (continued)

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS Verifying that there is 2 4350 gal of liquid nitrogen supply in the CAD System will ensure at least 29 days of post-LOCA CAD operation. This minimum volume of liquid nitrogen allows sufficient time after an accident to replenish the nitrogen supply for long term inerting. This is verified every 31 days to ensure that the system is capable of performing its intended function when required. The 31 day Frequency is based on operating experience, which has shown 31 days to be an acceptable period to verify the liquid nitrogen supply and on the availability of other hydrogen mitigating systems.

SR 3.6.3.2.2 Verifying the correct alignment for manual, power operated, and automatic valves in each of the CAD subsystem flow paths provides assurance that the proper flow paths exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable because the CAD System is manually initiated. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day Frequency is appropriate because the valves are operated under procedural control, improper valve position would only affect a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system.

(continued)

Brunswick Unit 2 B 3.6.3.2-4 Revision No. 39 1

.-: : -. - : -- Arc.-::-

I>. +>, Oti ; s~ ~

CAD System B 3.6.3.2

,,.Ji.,.w.,4 BASES SURVEILLANCE SR 3.6.3.2.3 REQUIREMENTS (continued) Cycling each power operated valve, excluding automatic valves, in the CAD System flow path through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. While this Surveillance may be performed with the reactor at power, the 24 month Frequency of the Surveillance is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1. Safety Guide 7, March 1971.

2. UFSAR, Section 6.2.5.3.2.1, Amendment No. 9.

3. 10 CFR 50.36(c)(2)(ii).

4. UFSAR, Table 6-11.

Brunswick Unit 2 B 3.6.3.2-5 Revision No. 39 l

I I 41 RHRSW System B 3.7.1 BASES LCO the two RHRSW loops to be connected) must be available to (continued) provide the ability to isolate one subsystem from the other subsystem in the event of an RHRSW System suction line break.

The RHRSW cross tie valve may be opened provided the cross tie valve is capable of being closed from the control room.

The SW System must be capable of providing the proper RHRSW suction pressure for an RHRSW subsystem to be considered OPERABLE. The requirements for an adequate suction source are addressed in LCO 3.7.2, "Service Water (SW) System and Ultimate Heat Sink (UHS)".

APPLICABILITY In MODES 1, 2, and 3, the RHRSW System is required to be OPERABLE to support the OPERABILITY of the RHR System for primary containment cooling (LCO 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling' and decay heat removal (LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown"). The Applicability is therefore consistent with the requirements of these systems.

In MODES 4 and 5, the OPERABILITY requirements of the RHRSW System are determined by the systems it supports.

ACTIONS A.1 With one RHRSW pump inoperable, the inoperable pump must be restored to OPERABLE status within 14 days. With the unit in this condition, the remaining OPERABLE RHRSW pumps are adequate to perform the RHRSW heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced RHRSW capability. A risk based analysis was performed and determined that an allowable out of service time of 14 days (Ref. 6) is acceptable to permit restoration of an inoperable RHRSW pump to OPERABLE status.

I (continued)

Brunswick Unit 2 B 3.7.1-3 Revision No. 39 l

RHRSW System B 3.7.1 BASES ' .. - .: - ,

ACTIONS B.1 (continued)

Required Action B.1 is intended to handle the inoperability of one RHRSW subsystem for reasons other than Condition A. The Completion Time of 7 days is allowed to restore the RHRSW subsystem to OPERABLE status. With the unit in this condition, the remaining OPERABLE RHRSW subsystem is adequate to perform the RHRSW heat removal function.

However, the overall reliability is reduced because a single failure in the OPERABLE RHRSW subsystem could result in loss of RHRSW function.

The 7 day Completion Time is based on the Completion Time provided for the RHR suppression pool cooling function, the redundant RHRSW capabilities afforded by the OPERABLE subsystem, and the low probability of an event occurring requiring RHRSW during this period.

A Note to the Required Action indicates that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

C.1 With both RHRSW subsystems inoperable (e.g., one or two RHRSW pumps inoperable in each subsystem), the RHRSW System is not capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for restoring one RHRSW subsystem to OPERABLE status, is based on the Completion Time provided for the RHR suppression pool cooling function.

The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

D.1 and D.2 If the RHRSW subsystems cannot be not restored to OPERABLE status within the associated Completion Times, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

Brunswick Unit 2 B 3.7.1-4 Revision No. 39 1

-- RHRSW System B 3.7.1 BASES (continued)

SURVEILLANCE SR 3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual, power operated, and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths exist for RHRSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

REFERENCES 1. UFSAR, Section 9.2.1.2.

2. UFSAR, Chapter 6.2.

3. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995; and Supplement 1, March 1996.

4. Letter BR5-96-074, Long Term Suppression Pool Temperature-Suppression Pool Cooling Mode for Long Term Containment Cooling, from M. E. Ball (GE) to R. E. Helme (CP&L),

September 19, 1996.

5. 10 CFR 50.36(c)(2)(ii).

6. GENE-B2100565-09, Technical Specification Improvements to the Emergency Core Cooling System for the Carolina Power and Light Brunswick Steam Electric Plant Units 1 and 2, Revision 1, October 1996.

Brunswick Unit 2 B 3.7.1-5 Revision No. 39 l

AC Sources-Operating B 3.8.1 BASES -

LCO shutdown condition after an anticipated operational occurrence (AOO)

(continued) or a postulated DBA.

Qualified offsite circuits are those that are described in the UFSAR (Ref. 2), and are part of the licensing basis for the unit.

Each offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the emergency buses. An OPERABLE qualified offsite circuit consists of the incoming breakers and disconnects from the respective 230 kV switchyard to and including the SAT or UAT, the respective circuit path to and including the BOP buses, and the circuit path to two 4.1 6 kV emergency buses including associated feeder (master/slave) breakers.

Each DG must be capable of starting, accelerating to minimum acceptable frequency and voltage, and connecting to its respective emergency bus on detection of bus undervoltage. This sequence must be accomplished within 10.5 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the emergency buses. These capabilities are required to be met from a variety of initial conditions, such as DG in standby with the engine at ambient condition.

Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to ready-to-load status on an ECCS signal while operating in parallel test mode. Each DG is required to have an OPERABLE air start system. Additionally, proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

The AC sources must be separate and independent (to the extent possible) of other AC sources. For the DGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practical. An offsite circuit may be connected to more than one emergency bus, with manual transfer capability to the other offsite circuit available, and not violate separation criteria. If the preferred offsite circuit (i.e., the circuit path from a 230 kV bus through the SAT to the associated onsite Class 1E emergency buses) is not connected to an emergency bus, the circuit is required to have OPERABLE fast transfer capability to two emergency buses to support OPERABILITY of that circuit.

(continued)

Brunswick Unit 2 B 3.8.1-4 Revision No. 39 l

,trt in? ->-iz, i* -;. q AC Sources-Operating B 3.8.1 BASES (continued) -. ,4 APPLICABILITY The AC sburces are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in LCO 3.8.2, 'AC Sources-Shutdown.'

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 The offsite circuits for two of the four 4.16 kV emergency buses utilize the opposite unit's SAT and UAT. Therefore, this Required Action provides a 45 day time period to perform maintenance on one of the opposite unit's transformers. This is acceptable because performing maintenance on the transformer will increase the reliability of the offsite circuit. However, if a second Unit 1 or 2 offsite circuit becomes inoperable, Conditions C and E are entered.

The 45 day Completion Time takes into account the capacity and capability of the remaining AC sources and a reasonable time for performance of maintenance.

The Note to Condition A only allows the 45 day Completion Time to be used when the opposite unit is in MODE 4 or 5. When a Unit 1 offsite circuit becomes inoperable while Unit 1 is in MODE 1, 2, or 3, Condition C of Unit 2 Specification 3.8.1 must be entered and the associated Required Actions performed.

(continued)

Brunswick Unit 2 B 3.8.1-5 Revision No. 39 l

BSEP 05-0082, Submittal of Technical Specification Bases Changes

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BSEP 05-0082, Submittal of Technical Specification Bases Changes

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