Text

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A.
	ML16287A415
Person / Time
Site:	Brunswick
Issue date:	09/28/2016
From:	William Gideon; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 16-0087, TSC-2016-07
	Download: ML16287A415 (133)
	v • d • e

William R. Gideon ef-..DUKE Vice President

~;ENERGYf? Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 September 28, 2016 Serial: BSEP 16-0087 TSC-2016-07 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A" Ladies and Gentlemen:

In accordance with the provisions of Title 1O of the Code of Federal Regulations (1 O CFR)

Section 50.90, Duke Energy Progress, LLC (Duke Energy), is submitting a request for an amendment to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Technical Specifications (TS) to incorporate the NRG-approved TSTF-423, Revision 1.

The proposed amendment would modify TS to risk-inform requirements regarding selected Required Action end states by incorporating the Boiling Water Reactor (BWR) Owners' Group (BWROG) approved Topical Report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants."

Additionally, the proposed amendment would modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (i.e., Mode 3) on reactor startup.

Enclosure 1 provides a description and assessment of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosures 2 and 3 provide marked-up pages of existing Unit 1 and Unit 2 TS, respectively, to show the proposed changes.

Enclosure 4 and 5 provide revised (i.e., typed) TS pages for Unit 1 and 2, respectively.

Enclosure 6 provides marked-up pages of existing Unit 1 TS Bases, for information only.

Enclosure 7 summarizes the regulatory commitments made in this submittal.

Duke Energy requests approval of the proposed license amendment by September 28, 2017, with the amendment being implemented within 120 days.

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

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory D\

Affairs, at (910) 457-2487. ~ 0

~~

U.S. Nuclear Regulatory Commission Page 2 of 3 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September 28, 2016.

Sincerely, William R. Gideon MAT/mat

Enclosures:

1. Description and Assessment of the Proposed Change

2. Marked-up Technical Specifications Pages - Unit 1

3. Marked-up Technical Specifications Pages - Unit 2

4. Revised Technical Specifications Pages - Unit 1

5. Revised Technical Specifications Pages - Unit 2

6. Marked-up Technical Specifications Bases Pages - Unit 1 (For Information Only)

7. Regulatory Commitments

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with enclosures):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)

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

BSEP 16-0087 Enclosure 1 Page 1 of 11 Description and Assessment of the Proposed Change

Subject:

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A" 1.0 Description The proposed amendment will modify Technical Specifications (TS) to risk-inform requirements regarding selected Required Action end states. Additionally, it will modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (Mode 3) on reactor startup. The changes are consistent with Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," dated December 22, 2009 (i.e., ADAMS Accession Number ML093570241) (Reference 1). The Federal Register notice published on February 18, 2011 (76 FR 34) (Reference 2) announced the availability of this TS improvement as part of the consolidated line item improvement process (CLllP).

2.0 Assessment 2.1 Applicability of Topical Report NEDC-32988-A, TSTF-423, and Model Safety Evaluation Duke Energy Progress, LLC, (Duke Energy) has reviewed Boiling Water Reactor (BWR)

Owners' Group (BWROG) topical report (TR) NEDC-32988-A (Reference 3), TSTF-423, Revision 1 (Reference 1), and the NRG staff's model safety evaluation (SE) (Reference 4) as part of the CLllP. Duke Energy has concluded that the information in TR NEDC-32988-A, TSTF-423, and the NRG staff's model SE are applicable to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, and justify this license amendment request (LAR) for the incorporation of the changes to the BSEP TSs.

2.2 Optional Changes and Variations Duke Energy is proposing variations or deviations from TR NEDC-32988-A, the TS changes described in TSTF-423, Revision 1, or the NRG staff's model SE referenced in the Federal Register on February 18, 2011 (76 FR 34) as part of the CLllP Notice of Availability. The proposed variations/deviations and their effects are discussed in the following table.

No. BSEPTS Title Variation/Deviation Comments

1. 3.3.8.2 Reactor No changes to BSEP The existing BSEP TS 3.3.8.2 Protection TS 3.3.8.2 are proposed. does not include a Required System (RPS) Action to be in Mode 4.

Electrical Power Therefore, no change is Monitoring necessary.

BSEP 16-0087 Enclosure 1 Page 2 of 11 No. BSEPTS Title Variation/Deviation Comments

2. 3.4.3 Safety/Relief No changes to BSEP The Standard TS, Condition A Valves (SRVs) TS 3.4.3 are proposed. is not applicable to BSEP.

BSEP TS 3.4.3, Condition A, corresponds to the proposed Condition C in TSTF-423; which includes the Mode 4 requirement. Therefore, no changes are proposed to BSEP TS 3.4.3.

3. 3.5.1 ECCS- Condition C of BSEP TS 3.5.1 Condition A of the Standard Operating is proposed to be revised per TS and Condition A of the TSTF-423; however, it applies BSEP TS 3.5.1 are when Conditions A or B are equivalent.

not met.

BSEP TS 3.5.1 includes Conditions in BSEP TS 3.5.1 Condition B for one Low are numbered differently from Pressure Coolant Injection the Standard TS Conditions. (LPCI) pump and one Core Spray (CS) subsystem inoperable concurrently. The justification provided in the topical report and model Safety Evaluation for this change is also applicable to Condition B of the BSEP TS 3.5.1.

4. N/A Low-Low Set No changes corresponding to The BSEP TSs do not include (LLS) Valves Standard TS 3.6.1 .6 are a specification for LLS proposed. Valves.

5. 3.6.1.5 Reactor Building- BSEP TS 3.6.1.5 corresponds BSEP TS 3.6.1.5 includes to-Suppression to Standard TS 3.6.1.7. New Conditions C and D, which Chamber Condition F, applicable to address the Nitrogen Backup Vacuum Condition E is added. System. Similar Conditions Breakers are not included in the BSEP TS 3.6.1.5 Conditions Standard TS 3.6.1 .7. The for which Mode 4 shutdown proposed BSEP change is remains applicable are equivalent to the change to included in renumbered Standard TS 3.6.1.7 in Condition G.

TSTF-423, in that it applies to one line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

BSEP TS 3.6.1 .5 Conditions for which Mode 4 shutdown remains applicable are included in renumbered

BSEP 16-0087 Enclosure 1 Page 3 of 11

o

_No. Variation/Devi~tion _con, merits* .

BSEP TS : .Title .. ..

Condition G. This is equivalent to the intent of the change to renumbered Condition F TSTF-423 for Standard TS 3.6.1.7.

6. 3.6.1.6 Suppression BSEP TS 3.6.1.6 corresponds The changes proposed to Chamber-to- to Standard TS 3.6.1.8. BSEP TS 3.6.1.6 are Drywall Vacuum equivalent to the change to Breakers the Standard TS 3.6.1.8 in TSTF-423. Only the TS number differs.

7. N(A Main Steam No changes corresponding to The BSEP TSs do not include Isolation Valve Standard TS 3.6.1 .9 are

a specification for an MSIV (MSIV) Leakage proposed. LCS.

Control System (LCS)

8. N/A Residual Heat No changes corresponding to The BSEP TSs do not include Removal (AHR) Standard TS 3.6.2.4 are a specification for an AHR Suppression Pool proposed. Suppression Pool Spray.

Spray

9. 3.6.4.3 Standby Gas The changes associated with Standard TS 3.6.4.3 Condition Treatment (SGT) Standard TS 3.6.4.3, A applies to inoperability of System Required Action D.1 are one SGT subsystem.

reflected in the Required Standard TS 3.6.4.3 Condition Actions for BSEP TS 3.6.4.3 D applies to inoperability of Condition B. two SGT subsystems. The changes to the Standard TS 3.6.4.3 in TSTF-423 allows the unit to remain in Mode 3 under these conditions.

BSEP TS 3.6.4.3 addresses inoperability of one SGT subsystem in Condition A.

BSEP TS 3.6.4.3 Condition B provides the shutdown requirements for failure to meet the Completion Time of Condition A and for inoperability of two SGT subsystems. As such, only BSEP TS 3.6.4.3 Condition B is revised to provide equivalent changes to those in TSTF-423 for Standard TS 3.6.4.3.

BSEP 16-0087 Enclosure 1 Page 4 of 11 No. BSEP TS Title Variation/Deviation Comments

10. 3.7.1 Residual Heat The addition of the new Both the BSEP and the Removal Service Condition D in Standard Standard TS 3.7.1 Water (RHRSW) TS 3.7.1 is proposed as a Condition A addresses System new Condition C in BSEP inoperability of one RHRSW TS3.7.1. pump. Standard TS 3.7.1 Condition B addresses Conditions in BSEP TS 3.7.1 inoperability of one RHRSW are numbered differently from pump in each subsystem.

the Standard TS 3.7.1 Standard TS 3.7.1 Conditions.

Condition C addresses inoperability of a RHRSW for reasons other than Condition A.

BSEP TS 3.7.1 does not have a Condition equivalent to Standard TS 3.7.1 Condition B. Rather, BSEP TS 3.7.1 Condition B addresses inoperability of a RHRSW for reasons other than Condition A (i.e., which would include inoperability of one RHRSW pump in each subsystem). As such, adding the new BSEP TS 3.7.1 Condition C provides an equivalent change to that in TSTF 423 for Standard TS 3.7.1.

11. 3.7.2 Service Water No changes to BSEP The justification provided in (SW) System and TS 3.7.2 are proposed. the topical report and model Ultimate Heat Safety Evaluation for changes Sink (UHS) to Standard TS 3.7.2 are based on a typical two subsystem configuration. The BSEP SW system consists of four site nuclear service water pumps and three conventional service water pumps per plant. Based on the significant differences, no changes to BSEP TS 3.7.2 are proposed.

BSEP 16-0087 Enclosure 1 Page 5 of 11 No. BSEP TS Title Variation/Deviation Comments

12. 3.7.3 Control Room BSEP TS 3.7.3 corresponds Standard TS 3.7.4 Emergency to Standard TS 3.7.4. Condition A applies to Ventilation inoperability of one Main The changes associated with (GREV) System Control Room Environmental Standard TS 3.7.4, Required Control (MCREC) subsystem.

Action E.1 and E.2 are Standard TS 3.7.4 reflected in the Required Condition E applies to Actions for BSEP TS 3.7.3 inoperability of two MCREC Condition C.

subsystems. The changes to the Standard TS 3.7.4 in TSTF-423 allow the unit to remain in Mode 3 under these conditions.

BSEP TS 3.7.3 addresses inoperability of one GREV subsystem (i.e., plant specific nomenclature corresponding to MCREC) in Condition A.

BSEP TS 3.7.3 Condition C provides the shutdown requirements for failure to meet the Completion Time of Condition A, Condition B, and for inoperability of two GREV subsystems. As such, only BSEP TS 3.7.3 Condition C is revised to provide equivalent changes to those in TSTF-423 for Standard TS 3.7.4.

13. 3.7.4 Control Room Air BSEP TS 3.7.4 corresponds Standard TS 3.7.5 applies to Conditioning (AC) to Standard TS 3.7.5. a typical Control Room AC System system which consists of two BSEP TS 3.7.4 is revised to independent, redundant allow the units to remain in subsystems. The BSEP Mode 3 when three Control Room AC system subsystems of the Control consists of three 50 percent Room AC system are capacity subsystems and inoperable.

BSEP TS 3.7.4 reflects this Conditions in BSEP TS 3.7.4 design. The justification are numbered differently from provided in the topical report the Standard TS Conditions. and model Safety Evaluation for changes to Standard TS 3.7.5 allows a unit to remain in Mode 3 when both subsystems of the Control Room AC system are inoperable. The proposed changes to BSEP TS 3.7.4 remain consistent with

BSEP 16-0087 Enclosure 1 Page 6 of 11 No. BSEP TS Title Variation/Deviation Comments TSTF-423 by allowing the units to remain in Mode 3 under the loss of function condition.

14. 3.7.5 Main Condenser BSEP TS 3.7.5 corresponds The only variation is Off gas to Standard TS 3.7.6. associated with the TS number. The changes to the Standard TS 3.7.6 in TSTF-423 were incorporated, as presented, in the proposed change to BSEP TS 3.7.5.

15. 3.8.1 AC Sources - Condition H of BSEP TS 3.8.1 Standard TS 3.8.1 applies to Operating is proposed to be revised per typical AC source design.

TSTF-423. As a result, the BSEP TS 3.8.1 reflects the TSTF-423 changes will be unique BSEP AC source applied to BSEP TS 3.8.1, design and, as a result, Conditions A and B, which requires two Unit 1 and two are plant specific and not Unit 2 qualified circuits and included in Standard four separate and TS 3.8.1. independent diesel generators to be operable Conditions in BSEP TS 3.8.1 when in Modes 1, 2, or 3. To are numbered differently from accommodate maintenance the Standard TS Conditions.

activities, BSEP TS 3.8.1, Conditions A and B, are specific to AC sources primarily associated with the opposite unit (e.g., Conditions A and B of BSEP Unit 1 TS 3.8.1 are applicable to offsite circuits and diesel generators primarily associated with Unit 2). The proposed changes to BSEP TS 3.8.1 remain consistent with TSTF-423 in that an affected unit will be allowed to remain in Mode 3 given I

similar level degradation of AC sources. The justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.8.1 is applicable to BSEP.

BSEP 16-0087 Enclosure 1 Page 7 of 11 No. BSEPTS Title Variation/Deviation Comments

16. 3.8.4 DC Sources - The changes associated with Standard TS 3.8.4 includes Operating Standard TS 3.8.4, Required Conditions associated with Action D.1 and D.2 are battery chargers, discrete reflected in the Required batteries, and DC electrical Actions for BSEP TS 3.8.4 power subsystems. BSEP Condition B. TS 3.8.4 is applicable only to the DC electrical power The existing BSEP TS 3.8.4 subsystem level.

Condition B addresses the failure to complete Condition Standard TS 3.8.4 does not A within the allowed address inoperability of Completion Time and multiple DC electrical power inoperability of more than one subsystems but BSEP DC electrical power TS 3.8.4 does. Also, the subsystem. This Condition Standard TS 3.8.4 reflects a has been revised to address typical configuration only the failure to complete consisting of two DC electrical Condition A within the allowed power subsystems. The Completion Time. A new BSEP configuration requires Condition C addresses both the Unit 1 and Unit 2 DC inoperability of more than one electrical power subsystems DC electrical power to be operable with a unit in subsystem. The changes Modes 1, 2, or 3. Consistent associated with Standard with the TSTF-423 changes TS 3.8.4 are not applicable to to Standard TS 3.8.4, the the new BSEP TS 3.8.4 allowance to remain in Condition C. Mode 3 with one inoperable DC electrical power subsystem is applied to the revised BSEP TS 3.8.4 Condition B. Under both the Standard TS 3.8.4 configuration and the BSEP configuration, loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed. Therefore, the justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.8.4 is applicable to BSEP.

17. N/A Inverters - No changes corresponding to The BSEP TSs do not include Operating Standard TS 3.8.7 are a specification for Inverters.

proposed.

BSEP 16-0087 Enclosure 1 Page 8 of 11 No. BSEP TS Title Variation/Deviation Comments

18. 3.8.7 Distribution BSEP TS 3.8.7 corresponds Standard TS 3.8.9 applies to System - to Standard TS 3.8.9. typical Distribution system Operating design. BSEP TS 3.8.7 Condition D of BSEP TS 3.8.7 reflects the unique BSEP is proposed to be revised per Distribution system design TSTF-423. As a result, the and, as a result, requires TSTF-423 changes will be emergency bus 1 (i.e., E1 ),

applied to BSEP TS 3.8.7, E2, E3, and E4 load groups to Condition A which is plant be operable when the unit is specific and not included in in Modes 1, 2, or 3. Load Standard TS 3.8.9.

groups E1 and E2 primarily Conditions in BSEP TS 3.8.7 serve Unit 1 loads and load are numbered differently from groups E3 and E4 load the Standard TS 3.8.9 groups primarily serve Unit 2 Conditions. loads.

To accommodate maintenance activities, BSEP TS 3.8.7, Condition A, is specific to load groups primarily associated with the opposite unit (e.g.,

Condition A of BSEP Unit 1 TS 3.8.7 is applicable to Load Groups 3 and 4, primarily associated with Unit 2). The proposed changes to BSEP TS 3.8. 7 remain consistent with TSTF-423 in that an affected unit will be allowed to remain in Mode 3 given similar level degradation. The justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.8.9 is applicable to BSEP.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Analysis Duke Energy has evaluated the proposed changes to the Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Description of Amendment Request: A change is proposed to the TS of the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, consistent with TSTF-423, Revision 1, to allow, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed consistent with the program in place for complying with the

BSEP 16-0087 Enclosure 1 Page 9 of 11 requirements of 10 CFR 50.65(a)(4). Changes proposed in TSTF-423 will be made to the BSEP TSs for selected Required Action end states.

Basis for no significant hazards consideration determination: As required by 10 CFR 50.91 (a),

Duke Energy analysis of the issue of no significant hazards consideration is presented below:

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

Response: No The proposed change allows a change to certain required end states when the TS Completion Times for remaining in power operation will be exceeded. Most of the requested TS changes are to permit an end state of hot shutdown (Mode 3) rather than an end state of cold shutdown (Mode 4) contained in the current TS. The request was limited to: (1) those end states where entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. Risk insights from both the qualitative and quantitative risk assessments were used in specific TS assessments. Such assessments are documented in Section 6 of topical report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants." They provide an integrated discussion of deterministic and probabilistic issues, focusing on specific TSs, which are used to support the proposed TS end state and associated restrictions. The NRC staff finds that the risk insights support the conclusions of the specific TS assessments. Therefore, the probability of an accident previously evaluated is not significantly increased, if at all. The consequences of an accident after adopting TSTF-423 are no different than the consequences of an accident prior to adopting TSTF-423. Therefore, the consequences of an accident previously evaluated are not significantly affected by this change. The addition of a requirement to assess and manage the risk introduced by this change will further minimize possible concerns.

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

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

Response: No The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). If risk is assessed and managed, allowing a change to certain required end states when the TS Completion Times for remaining in power operation are exceeded (i.e., entry into hot shutdown rather than cold shutdown to repair equipment) will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated. The addition of a requirement to assess and manage the risk introduced by this change and the commitment by the

BSEP 16-0087 Enclosure 1 Page 10 of 11 licensee to adhere to the guidance in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A,'" will further minimize possible concerns.

Thus, based on the above, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

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

Response: No The proposed change allows, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed. The BWROG's risk assessment approach is comprehensive and follows NRC staff guidance as documented in Regulatory Guides (RG) 1.174 and 1.177. In addition, the analyses show that the criteria of the three-tiered approach for allowing TS changes are met. The risk impact of the proposed TS changes was assessed following the three-tiered approach recommended in RG 1.177. A risk assessment was performed to justify the proposed TS changes. The net change to the margin of safety is insignificant.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, Duke Energy concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."

3.2 Verifications, Commitments, and Additional Information Needed Duke Energy commits to the regulatory commitments in Enclosure 7. In addition, Duke Energy has proposed TS Bases consistent with TSTF-423, Revision 1, which provide guidance and details on how to implement the new requirements. Implementation of TSTF-423 requires that risk be managed and assessed, and the licensee's configuration risk management program is adequate to satisfy this requirement. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more systems are not able to perform their associated function. Finally, Duke Energy has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

4.0 Environmental Evaluation The proposed change would change a requirement with respect to installation or use of a facility c9mponent located \Nithin the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occup2tional radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in i O CFR 51.22(c)(9).

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

BSEP 16-0087 Enclosure 1 Page 11 of 11 5.0 References

1. TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," dated December 22, 2009 (ADAMS Accession No. ML093570241 ).

2. Federal Register, Vol. 76, No. 34, p.9614, "Notice of Availability of the Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A,' for Boiling Water Reactor Plants Using the Consolidated Line Item Improvement Process," (ADAMS Accession No. ML102730585).

3. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants," December 2002 (ADAMS Package Accession No. ML030170090).

4. NRC Model Safety Evaluation of TSTF-423, Revision 1, dated February 18, 2011 (ADAMS Accession No. ML102730688).

BSEP 16-0087 Enclosure 2 Marked-up Technical Specifications Pages - Unit 1 Enclosure 2 Contains the following Marked-up Unit 1 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36

EC CS-Operating

N0 TE------------ 3.5.1 LCO 3.0.4.a is not ACTIOt\

applicable when entering MODE 3.

I\

~,EQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met. AN9

~ Be iR MGQE 4. de t:ie1::1Fs D. HPCI System inoperable. D.1 Verify by administrative Immediately means RCIC System is OPERABLE.

AND D.2 Restore HPCI System to 14 days OPERABLE status.

E. HPCI System inoperable. E.1 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND OR One low pressure ECCS injection/spray subsystem is E.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. ECCS injection/spray subsystem to OPERABLE status.

F. One required ADS valve F.1

Restore required ADS valve 14 days inoperable. to OPERABLE status.

(continued)

Brunswick Unit 1 3.5-2 Amendment No. ~

ECCS-Operating 3.5.1 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME G. One required ADS valve G.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR One low pressure ECCS G.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status.

H. One required ADS valve H.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR HPCI System inoperable. H.2 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

Required Aotion and -h4 K - @

Be in]MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months assooiated Completion Time of Condition D, E, F, G, or H AND J .1 not met.

~ Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

150 psig .

Two or more required ADS valves inoperable.

(continued)

I. Required Action and 1.1 - - - - -NOTE associated Completion Time of LCO 3.0.4 .a is not Condition D, E, F, G, or H not applicable when met. entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.5-3 Amendment No. ~

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Two or more low pressure J4 Enter LCO 3.0.3. Immediately ECCS injection/spray subsystems inoperable for reasons other than Condition A or B.

HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem , the 31 days piping is filled with water from the pump discharge valve to the injection valve.

(continued)

Brunswick Unit 1 3.5-4 Amendment No. ~

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig .

ACTIONS

NOl"E ~--------------------------------------------------------

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLEl"ION TIME A. RCIC System inoperable. A. 1 Verify by administrative Immediately means High Pressure Coolant Injection System is

NOTE------------ OPERABLE .

LCO 3.0.4.a is not

~

applicable when AND entering MODE 3.

A.2 Restore RCIC System to 14 days OPERABLE status .

~

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion l"ime not met. ANG

~ Reeluee FeaeteF steam 36 h9UFS eleR'te prnssurn ta 5 ~§9 psi§ .

Brunswick Unit 1 3.5-12 Amendment No. 2-33 I

Reactor Building-to-Suppression Chamber Vaccum Breakers 3.6.1.5 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two reactor building- D.1 Restore one vacuum 7 days to-suppression chamber breaker to OPERABLE vacuum breakers inoperable status.

due to inoperable nitrogen backup subsystems.

E. One line with one or more E.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months reactor building-to- breaker(s) to OPERABLE suppression chamber status.

vacuum breakers inoperable for opening for reasons other than Condition C.

~ Two lines with one or more F-,.+ Restore all vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reactor building-to- ~rs in one line to suppression chamber RABLE status .

vacuum breakers inoperable for opening for reasons 1 other than Condition D.

G. Required Action and G:4 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND~

associated Completion Time not met.

I I\ ~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

~-

\ H.2 Lf ot Condition A , B, C, D, F, or G I F. Required Action and F.1 - - -NOTE- - -

associated Completion Time of LCO 3.0.4.a is not Condition E not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.6-16 Amendment No. ~

Suppression Chamber-to-Drywell Vaccum Breakers 3.6.1 .6 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening .

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

APPLICABILITY: MODES 1, 2, and 3.

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

~---.C .

e suppression chamber- &.+ Close the open vacuum 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to-drywell vacuum breaker breaker.

not closed .

G. Required Action and &. ~ Be~ODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ciated Completion Time met. AND '~

. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

= = =====t of Condition C f!!!!!!!!'=='==::d~!!ioi;;:;~

8. Required Action and 8 .1 ----------NOTE----------

associated Completion Time of LCO 3 0.4.a is not Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.6-18 Amendment No. ~ I

RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool A.1 Restore RHR suppression 7 days cooling subsystem pool cooling subsystem to inoperable. OPERABLE status.

&.- Two RHR suppression pool B4 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months cooling subsystems suppression pool cooling inoperable. subsystem to OPERABLE status .

G:- Required Action and G:+ Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND~

sociated Completion Time met.

. ~ Be in MODE 4 . 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

8. Required Action and 8 .1 --------NOTE----------

associated Completion Time of LCO 3.0.4 .a is not Condition A not met. applicable when entering MODE 3.

Be in MOOE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.6-24 Amendment No. 33 I

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3,

N 0 TE------------ During movement of recently irradiated fuel assemblies in the secondary LCO 3.0.4.a is not containment, applicable when During operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs) .

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment Restore secondary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in MODE 1, 2, containment to OPERABLE or 3. status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. ANG

~ Be iR MGQE: 4. a0 l=lel:lFs C. Secondary containment C.1 --------------NOTE-------------

inoperable during movement LCO 3.0.3 is not applicable.

of recently irradiated fuel ----------------------------------

assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 1 3.6-28 Amendment No. ~

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3,

N 0 TE------------ During movement of recently irradiated fuel assemblies in the secondary LCO 3.0.4 .a is not containment, applicable when During operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs) .

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SGT subsystem Restore SGT subsystem to 7 days inoperable in MODE 1, 2 or OPERABLE status.

3.

B. Required Action and Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. ANG Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Two SGT subsystems inoperable in MODE 1, 2, or 3.

(continued)

Brunswick Unit 1 3.6-33 Amendment No. ~

RHRSW System 3.7.1 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME B. One RHRSW subsystem B.1 --------------N0 TE--------------

inoperable for reasons other Enter applicable Conditions than Condition A. and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

Restore RHRSW 7 days subsystem to OPERABLE status .

&.- Both RHRSW subsystems G4 --------------NOTE--------------

~ble Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status .

(continued)

C. Required Action and C.1 - - - -NOTE- - -

associated Completion Time of LCO 3.0.4 .a is not Condition A or B not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.7-2 Amendm ent No. ~

RHRSW System 3.7.1 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME

~ Required Action and Q.:4 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND~

ociated Completion Time met.

. ~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months of Condition D SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and 31 days automatic valve in the flow path, that is not locked, sealed , or otherwise secured in position , is in the correct position or can be aligned to the correct position .

Brunswick Unit 1 3.7-3 Amendment No. ~

N 0 TE------------

LCO 3.0.4.a is not r

CREV System applicable when 3.7.3 entering MODE 3.

ACTIONS (continued) --------------------------------

COMPLETION CONDITION , / REQUIRED ACTION TIME C. Required Action and C.1 VI' Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time ANG of Condition A or B not met in MODE 1, 2, or 3. ~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

D. Required Action and -------------------N 0 TE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met ------------------------------------------------

during movement of D.1 Place OPERABLE CREV Immediately irradiated fuel assemblies in subsystem in the secondary containment, radiation/smoke protection during CORE mode.

ALTERATIONS, or during OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately AL TERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

(continued)

Brunswick Unit 1 3.7-12 Amendment No. -248 I

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary

N 0 TE------------ containment, LCO 3.0.4.a is not During CORE ALTERATIONS, applicable when During operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs).

ACTIONS REQUIRED ACTION COMPLETION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable. subsystem to OPERABLE status.

B. Two control room AC Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystems inoperable. control room AC subsystem to OPERABLE status.

C. Required Action and Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met ANG in MODE 1, 2, or 3.

Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Brunswick Unit 1 3.7-15 Amendment No. ~

Control Room AC System 3.7.4 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and --------------------NOTE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met -------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE control Immediately the secondary containment, room AC subsystem(s) in during CORE operation.

AL TERATIONS , or during OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

N 0 TE------------

LCO 3.0.4.a is not applicable when Suspend CORE Immediately entering MODE 3. ALTERATIONS .

Initiate action to suspend Immediately OPDRVs.

E. Three control room AC E.1 Enter LCO a.a.a. Immediately subsystems inoperable in MODE 1, 2, or 3.

(continued)

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.7-16 Amendment No. 2-GJ

Main Condenser Offgas 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas LCO 3.7.5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be ~ 243,600 µCi/second after decay of 30 minutes.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation .

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit.

B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR

N 0 TE------------ B.2 Isolate SJAE . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.4 .a is not applicable when entering MODE 3.

~

-- ~7-'

B.34 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AN9

~ Be iR MG9E 4. de 1=191:1FS Brunswick Unit 1 3.7-18 Amendment No. ~

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite circuit inoperable ----------------------N 0 TE-------------------

for reasons other than Enter applicable Conditions and Condition B. Required Actions of LCO 3.8.7, "Distribution Systems-Operating ,"

AND when Condition F is entered with no AC power source to any 4.16 kV One DG inoperable for emergency bus.

reasons other than --------------------*-----------------------------

Condition B.

F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

N 0 TE------------

LCO 3.0.4.a is not applicable when -OR entering MODE 3.

'\F.2 Restore DG to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G. Two or more DGs inoperable. G \, Restore all but one DG to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months H. Required Action and H.1~ Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, D, E, F ANG or G not met.

M+/- Be iA MGl;H~i: 4. Je 1=1e1o1Fs I. One or more offsite circuits 1.1 Enter LCO 3.0.3. Immediately and two or more DGs inoperable.

OR Two or more offsite circuits and one DG inoperable for reasons other than Condition B.

Brunswick Unit 1 3.8-6 Amendment No. ~ I

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

LCO 3.0.4.a is not DC Sources- Operating applicable when 3.8.4 entering MODE 3.

ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. ANG Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Two or more DC electrical power subsystems

.......... inoperasle

/

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ~ 130 V on float 7 days charge.

SR 3.8.4.2 Verify no visible corrosion at battery terminals and 92 days connectors.

OR Verify battery connection resistance is ~ 23.0 µohms for inter-cell connections and ~ 82.8 µohms for inter-rack connections.

SR 3.8.4.3 Verify battery cells , cell plates, and racks show no 18 months visual indication of physical damage or abnormal deterioration that degrades performance.

(continued)

C. Two or more DC electrical C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months power subsystems inoperable.

AND C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.8-24 Amendment No. ~ I

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

LCO 3.0.4 .a is not Distribution Systems-Operating applicable when 3.8.7 entering MODE 3.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC electrical D.1 Restore DC electrical 7 days power distribution power distribution subsystems inoperable for subsystems to OPERABLE AND reasons other than status.

Condition C. 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO E. Required Action and E.1 'V Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, or D ANQ not met.

~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two or more electrical F.1 Enter LCO 3.0 .3. Immediately power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 1 3.8-36 Amendment No. ~ I

BSEP 16-0087 Enclosure 3 Marked-up Technical Specifications Pages - Unit 2 Enclosure 3 Contains the following Marked-up Unit 2 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36

NOTE------------ EC CS-Operating LCO 3.0.4.a is not 3.5.1 ACTIC applicable when entering MODE 3.

I\

vVl'OjUI I IVl'\I \ 7 EQUIRED ACTION COMPLETION TIME

~

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met. ANG

~ Be iA MGQe 4. a0 1=1e1:1Fs D. HPCI System inoperable. D.1 Verify by administrative Immediately means RCIC System is OPERABLE.

AND D.2 Restore HPCI System to 14 days OPERABLE status.

E. HPCI System inoperable. E.1 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND OR One low pressure ECCS injection/spray subsystem is E.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. ECCS injection/spray subsystem to OPERABLE status.

F. One required ADS valve F.1 Restore required ADS valve 14 days inoperable. to OPERABLE status.

(continued)

Brunswick Unit 2 3.5-2 Amendment No. ~

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. One required ADS valve G.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR One low pressure ECCS G.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status .

H. One required ADS valve H.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable . to OPERABLE status.

AND OR HPCI System inoperable. H .2 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

h ~eEll::liFeEI AstieA aAEI 4 ~MODE3 . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months assesiateEI GeFfl13letieA +iFfle

)~ ef GeAElitieA D, E, r , G , 9F H AND J.1 Aet met.

~ Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months GR ~e pressure to O psig .

Two or more required ADS valves inoperable. 2 (continued)

L[IJ I. Requ ired Action and 1.1 - - -NOTE- - -

associated Completion Time of LCO 3.0.4 .a is not Cond ition D, E. F. G, or Hnot applicable when met. entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3 .5-3 Amendment No. ~

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Two or more low pressure J,.+ Enter LCO 3.0.3. Immediately ECCS injection/spray subsystems inoperable for reasons other than Condition A or B.

~

HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1 .1 Verify, for each ECCS injection/spray subsystem , the 31 days piping is filled with water from the pump discharge valve to the injection valve.

(continued)

Brunswick Unit 2 3.5-4 Amendment No. ~

RCIC System 3.5 .3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

NOTE~--------------------------------------------------------

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A. 1 Verify by administrative Immediately means High Pressure Coolant Injection System is

N 0 TE------------ OPERABLE.

LCO 3.0.4.a is not

~

AND applicable when entering MODE 3.

K. \

Restore RCIC System to OPERABLE status .

14 days

~

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. ANG

~ Reel1::1ee FeaeteF steam 36 hel::IFS eleme pmss1::1m te

~ Hi9 psi§ .

Brunswick Unit 2 3.5-12 Amendment No. ~ I

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two reactor building-to- D.1 Restore one vacuum 7 days suppression chamber breaker to OPERABLE vacuum breakers inoperable status.

due to inoperable nitrogen backup subsystems.

E. One line with one or more E.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months reactor building-to- breaker(s) to OPERABLE suppression chamber status.

vacuum breakers inoperable for opening for reasons other than Condition C.

~ Two lines with one or more ~ Restore all vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reactor building-to- ~akers in one line to suppression chamber PERABLE status.

vacuum breakers inoperable for opening for reasons 1 other than Condition D.

~ Required Action and (;,.+ Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

~

associated Completion Time not met. ANQ I~ G+/- ~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

. H.2 Yot Condition A , B, C, D, F, or G I F. Required Action and F.1 - - -NOTE*- - -

associated Completion Time of LCO 3.0.4.a is not Condition E not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.6-16 Amendment No. ~

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1 .6 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for open ing .

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

APPLICABILITY: MODES 1, 2, and 3.

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

opening.

One suppression chamber- BA- Close the open vacuum 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to-drywell vacuum breaker breaker.

not closed .

Required Action and G:4- Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time ~ r:::--:-1 not met. AND. ' ~

of Cond ition C Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B. Required Action and B.1 ----------NOTE-----------

associated Completion Time of LCO 3.0.4 .a is not Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.6-18 Amendment No. ~ I

RHR Suppression Pool Cooling 3.6 .2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool A.1 Restore RHR suppression 7 days cooling subsystem pool cooling subsystem to inoperable. OPERABLE status.

8-:- Two RHR suppression pool 8:4 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months cooling subsystems suppression pool cooling inoperable. subsystem to OPERABLE C. status .

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 0 .2 of Condition C B. Required Action and 8 .1 ------NOTE- - - - -

associated Completion Time of LCO 3.0.4.a is not Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.6-24 Am endment No. ~ I

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3,

NOTE------------ During movement of recently irradiated fuel assemblies in the secondary LCO 3.0.4.a is not containment, applicable when \ Durinig operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs).

ACTIONS COMPLETION CONDITION \ REQUIRED ACTION TIME A. Secondary containment \ A.1 Restore secondary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in MODE 1, 2, \ containment to or3. ~I OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. ANG Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Secondary containment C.1 --------------NO TE--------------

inoperable during movement LCO 3.0.3 is not applicable.

of recently irradiated fuel assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

(continued)

Brunswick Unit 2 3.6-28 Amendment No. ~

SGT System 3 .6.4 .3 3.6 CONTAINMENT SYSTEMS 3.6.4 .3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3,

NO TE------------ During movement of recently irradiated fuel assemblies in the secondary LCO 3.0.4.a is not containment, applicable when During operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs) .

ACTIONS COMPLETION COND ITION REQUIRED ACTION TIME A. One SGT subsystem Restore SGT subsystem 7 days inoperable in MODE 1, 2 or to OPERABLE status .

3.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. AND Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Two SGT subsystems inoperable in MODE 1, 2, or 3.

(continued)

Brun swick Unit 2 3.6-33 A mendment No. ~

RHRSW System 3.7.1 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME B. One RHRSW subsystem B.1 --------------N 0 TE--------------

inoperable for reasons other E nter applicable Conditions than Condition A. and Required Actions of LCO 3.4 .7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

Restore RHRSW 7 days subsystem to OPERABLE status.

&.- Both RHRSW subsystems G4 -------------N 0 TE--------------

~able E nt er applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status.

(continued)

C. Required Action and C.1 - - - -NOTE- -

associated Completion Time of LCO 3.0.4 .a is not Condition A or B not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.7-2 Amendment No. ~

RHRSW System 3.7.1 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME G-:- Required Action and G-:-4 ~ Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

'-' ....1( associated Completion Time

~ 1 not met. AND E.1 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months of Condition D SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1 .1 Verify each RHRSW manual, power operated , and 31 days automatic valve in the flow path , that is not locked ,

sealed , or otherwise secured in position , is in the correct position or can be aligned to the correct position .

Brunswick Unit 2 3.7-3 Amendment No. ~

N 0 TE------------ GREV System LCO 3.0.4 .a is not 3.7.3 applicable when ACTIONS {continued) I entering MODE 3.

C.

CONDITION Required Action and J

r C .1 REQUIRED ACTION Be in MODE 3.

COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met ANG in MODE 1, 2, or 3.

~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

D. Required Action and -------------------N 0 TE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met ------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE GREV Immediately the secondary containment, subsystem in during CORE radiation/smoke protection AL TERA TIONS, or during mode .

OPDRVs.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D .2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

(continued)

Brunswick Unit 2 3.7-12 Amendment No. ~ I

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary

NO TE------------ containment, LCO 3.0.4.a is not During CORE ALTERATIONS, applicable when During operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs) .

ACTIONS REQUIRED ACTION COMPLETION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable. subsystem to OPERABLE status .

B. Two control room AC Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystems inoperable. control room AC subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met ANG in MODE 1, 2, or 3.

Be in MODE 4. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (continued)

Brunswick Unit 2 3.7-15 Amendment No. ~

Control Room AC System 3.7.4 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and ---------------------NOTE--------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met -------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE control Immediately the secondary containment, room AC subsystem(s) in during CORE operation.

AL TERATIONS, or during OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

N 0 TE------------

D.2.2 Suspend CORE Immediately LCO 3.0.4.a is not AL TERATIONS.

applicable when entering MODE 3.

Initiate action to suspend Immediately OPDRVs.

E. Three control room AC E.1 Enter LCO 3.0.3. Immediately subsystems inoperable in MODE 1, 2, or 3.

(continued)

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.7-16 Amendment No. ~

Main Condenser Offgas 3.7.5 3.7 PLANT SYSTEMS 3.7 .5 Main Condenser Offgas LCO 3.7 .5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be ~ 243,600 µCi/second after decay of 30 minutes.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit.

B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR

N 0 TE------------ B.2 Isolate SJAE . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.4 .a is not applicable when OR entering MODE 3.

B.3A Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ANG

~ Be iR MGb>E 4. ;30 A91:ffS Brunswick Un it 2 3.7-18 Amendment No. ~

L_ ~

AC Sources- Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite circuit inoperable ----------------------N 0 TE------------------

for reasons other than Enter applicable Conditions and Condition B . Required Actions of LCO 3.8.7 ,

"Distribution Systems-Operating ,"

AND when Condition F is entered with no AC power source to any 4 .16 kV One DG inoperable for emergency bus .

reasons other than -------------------------------------------------

Condition B.

F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

N 0 TE------------ OPERABLE status .

LCO 3.0.4 .a is not applicable when OR entering MODE 3.

G. Two or more DGs i\\ F.2 G .1 Restore DG to OPERABLE status.

Restore all but one DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2 hours inoperable. OPERABLE status .

..\I,,

H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A , B, C , D, E, F AN9 or G not met.

~ Be iR MGQE 4. 30 R91:1FS I. One or more offsite circuits 1.1 Enter LCO 3.0 .3. Immediately and two or more DGs inoperable.

OR Two or more offsite circuits and o ne DG inoperable for reasons other than Cond iti on B.

Bru nsw ick Un it 2 3.8-6 A mendment No. ~ I

NO TE------------

LCO 3.0.4.a is not DC Sources-Operating applicable when 3.8.4 entering MODE 3.

ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. AN9 Be iA MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Two or more DC electrical power subsystems

......... iAoperable

/

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ~ 130 V on float 7 days charge .

SR 3.8.4.2 Verify no visible corrosion at battery terminals and 92 days connectors .

OR Verify battery connection resistance is :s; 23.0 µohms for inter-cell connections and :s; 82.8 µohms for inter-rack connections.

SR 3.8.4.3 Verify battery cells , cell plates, and racks show no 18 months visual indication of physical damage or abnormal deterioration that degrades performance.

(continued)

I I C. Two or more DC electrical C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months power subsystems inoperable.

AND C.2 Be in MODE4 . 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.8-24 Amendm ent No. ~ I

N 0 TE------------

LCO 3.0.4 .a is not Distribution Systems- Operating applicable when 3.8.7 entering MODE 3.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC electrical D.1 Restore DC electrical 7 days power distribution power distribution subsystems inoperable for subsystems to OPERABLE AND reasons other than status .

Condition C. 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO

\,/

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A , B, C, or D AND not met.

~ Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 2 3.8-36 Amendment No. ~ I

BSEP 16-0087 Enclosure 4 Revised Technical Specifications Pages - Unit 1 Enclosure 4 Contains the following Revised Unit 1 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36

ECCS-Operating 3.5.1 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 --------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. HPCI System inoperable. D.1 Verify by administrative Immediately means RCIC System is OPERABLE.

AND D.2 Restore HPCI System to 14 days OPERABLE status.

E. HPCI System inoperable. E.1 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND OR One low pressure ECCS injection/spray subsystem is E.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. ECCS injection/spray subsystem to OPERABLE status.

F. One required ADS valve F.1 Restore required ADS valve 14 days inoperable. to OPERABLE status.

(continued)

Brunswick Unit 1 3.5-2 Amendment No.

ECCS-Operating 3.5.1 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. One required ADS valve G.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR One low pressure ECCS G.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status.

H. One required ADS valve H.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR HPCI System inoperable. H.2 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

I. Required Action and 1.1 --------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition D, E, F, G, or H applicable when entering not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months J. Two or more required ADS J.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months valves inoperable.

AND J.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

.::; 150 psig.

(continued)

. Brunswick Unit 1 3.5-3 Amendment No .

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. Two or more low pressure K.1 Enter LCO 3.0.3. Immediately ECCS injection/spray subsystems inoperable for reasons other than Condition A or B.

HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, the 31 days piping is filled with water from the pump discharge valve to the injection valve.

(continued)

Brunswick Unit 1 3.5-4 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

N 0 TE-----------------------------------------------------------

L CO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A.1 Verify by administrative Immediately means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status.

B. Required Action and B.1 --------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.5-12 Amendment No.

Reactor Building-to-Suppression Chamber Vaccum Breakers 3.6.1.5 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Two reactor building- D.1 Restore one vacuum 7 days to-suppression chamber breaker to OPERABLE vacuum breakers inoperable status.

due to inoperable nitrogen backup subsystems.

E. One line with one or more E.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months reactor building-to- breaker(s) to OPERABLE suppression chamber status.

vacuum breakers inoperable for opening for reasons other than Condition C.

F. Required Action and F.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition E not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G. Two lines with one or more G.1 Restore all vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reactor building-to- breakers in one line to suppression chamber OPERABLE status.

vacuum breakers inoperable for opening for reasons other than Condition D.

H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, D, F, AND or G not met.

H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.6-16 Amendment No.

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

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

APPLICABILITY: MODES 1, 2, and 3.

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

opening.

B. Required Action and B.1 -------------NO TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. One suppression chamber- C. 1 Close the open vacuum 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to-drywell vacuum breaker breaker.

not closed.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.6-18 Amendment No.

RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

A PPLICABILITY: MODES 1, 2, and 3.

A CTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One RHR suppression pool A.1 Restore RHR suppression 7 days cooling subsystem pool cooling subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two RHR suppression pool C.1 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months I cooling subsystems suppression pool cooling inoperable. subsystem to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.6-24 Amendment No.

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in MODE 1, 2, containment to OPERABLE or 3. status.

B. Required Action and B.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Secondary containment C.1 --------------NOTE-------------

inoperable during movement LCO 3.0.3 is not applicable.

of recently irradiated fuel ------------------------------------

assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 1 3.6-28 Amendment No.

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SGT subsystem A.1 Restore SGT subsystem to 7 days inoperable in MODE 1, 2 or OPERABLE status.

3.

B. Required Action and B.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

OR -----------------------------------

Two SGT subsystems Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable in MODE 1, 2, or 3.

(continued)

Brunswick Unit 1 3.6-33 Amendment No.

RHRSW System 3.7.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One RHRSW subsystem B.1 -------------NOTE--------------

inoperable for reasons other Enter applicable Conditions than Condition A. and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

Restore RHRSW 7 days subsystem to OPERABLE status.

C. Required Action and C.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. Both RHRSW subsystems D.1 -------------N 0 TE--------------

inoperable. Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE

}

l status.

(continued)

Brunswick Unit 1 3.7-2 Amendment No.

l RHRSW System 3.7.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition D not met. AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and 31 days automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Brunswick Unit 1 3.7-3 Amendment No.

CREV System 3.7.3 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. Required Action and C.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met applicable when entering in MODE 1, 2, or 3. MODE 3.

OR Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

D. Required Action and -------------------N 0 TE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met ------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE GREV Immediately the secondary containment, subsystem in during CORE radiation/smoke protection ALTERATIONS, or during mode.

OPDRVs.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

(continued)

Brunswick Unit 1 3.7-12 Amendment No.

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable. subsystem to OPERABLE status.

B. Two control room AC B.1 Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystems inoperable. control room AC subsystem to OPERABLE status.

C. Required Action and C. 1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met applicable when entering in MODE 1, 2, or 3. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Brunswick Unit 1 3.7-15 Amendment No.

Control Room AC System 3.7.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and -------------------N 0 TE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met ------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE control Immediately the secondary containment, room AC subsystem(s) in during CORE operation.

ALTERATIONS, or during OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

E. Three control room AC E.1 -------------N 0 TE--------------

subsystems inoperable in LCO 3.0.4.a is not MODE 1, 2, or 3. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Brunswick Unit 1 3.7-16 Amendment No.

Main Condenser Offgas 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas LCO 3.7.5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be ::;; 243,600 µCi/second after decay of 30 minutes.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit.

B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR B.2 Isolate SJAE. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR B.3 -------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.7-18 Amendment No.

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite Gircuit inoperable ----------------------N 0 TE-------------------

for reasons other than Enter applicable Conditions and Condition B. Required Actions of LCO 3.8.7, "Distribution Systems-Operating,"

AND when Condition F is entered with no AC power source to any 4.16 kV One DG inoperable for emergency bus.

reasons other than -------------------------------------------------

Condition B.

F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

OR F.2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status.

G. Two or more DGs G.1 Restore all but one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable. OPERABLE status.

H. Required Action and H.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A, B, C, D, E, F applicable when entering or G not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I. One or more offsite circuits 1.1 Enter LCO 3.0.3. Immediately and two or more DGs inoperable.

OR Two or more offsite circuits and one DG inoperable for reasons other than Condition B.

Brunswick Unit 1 3.8-6 Amendment No.

DC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two or more DC electrical C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months power subsystems inoperable. AND C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ~ 130 V on float 7 days charge.

SR 3.8.4.2 Verify no visible corrosion at battery terminals and 92 days connectors.

Verify battery connection resistance is ~ 23.0 µohms for inter-cell connections and ~ 82.8 µohms for inter-rack connections.

SR 3.8.4.3 Verify battery cells, cell plates, and racks show no 18 months visual indication of physical damage or abnormal deterioration that degrades performance.

(continued)

Brunswick Unit 1 3.8-24 Amendment No.

Distribution Systems-Operating 3.8.7 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC electrical D.1 Restore DC electrical 7 days power distribution power distribution subsystems inoperable for subsystems to OPERABLE AND reasons other than status.

Condition C. 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO E. Required Action and E.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A, B, C, or D applicable when entering not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 1 3.8-36 Amendment No.

BSEP 16-0087 Enclosure 5 Revised Technical Specifications Pages - Unit 2 Enclosure 5 Contains the following Revised Unit 2 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36

EGGS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 --------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. HPCI System inoperable. D.1 Verify by administrative Immediately means RCIC System is OPERABLE.

AND D.2 Restore HPCI System to 14 days OPERABLE status.

E. HPCI System inoperable. E.1 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND OR One low pressure ECCS injection/spray subsystem is E.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. ECCS injection/spray subsystem to OPERABLE status.

F. One required ADS valve F.1 Restore required ADS valve 14 days inoperable. to OPERABLE status.

(continued)

Brunswick Unit 2 3.5-2 Amendment No.

EGGS-Operating 3.5.1 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. One required ADS valve G.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR One low pressure ECCS G.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status.

H. One required ADS valve H.1 Restore required ADS valve 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR HPCI System inoperable. H.2 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

I. Required Action and 1.1 --------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition D, E, F, G, or H applicable when entering not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months J. Two or more required ADS J.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months valves inoperable.

AND J.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

150 psig.

(continued)

Brunswick Unit 2 3.5-3 Amendment No.

EGGS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. Two or more low pressure K.1 Enter LCO 3.0.3. Immediately EGGS injection/spray subsystems inoperable for reasons other than Condition A or B.

HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each EGGS injection/spray subsystem, the 31 days piping is filled with water from the pump discharge valve to the injection valve.

(continued)

Brunswick Unit 2 3.5-4 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A.1 Verify by administrative Immediately means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status.

B. Required Action and B.1 --------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.5-12 Amendment No.

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Two reactor building-to- D.1 Restore one vacuum 7 days suppression chamber breaker to OPERABLE vacuum breakers inoperable status.

due to inoperable nitrogen backup subsystems.

E. One line with one or more E.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months reactor building-to- breaker(s) to OPERABLE suppression chamber status.

vacuum breakers inoperable for opening for reasons other than Condition C.

F. Required Action and F.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition E not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G. Two lines with one or more G.1 Restore all vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reactor building-to- breakers in one line to suppression chamber OPERABLE status.

vacuum breakers inoperable for opening for reasons other than Condition D.

H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, D, F, AND or G not met.

H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.6-16 Amendment No.

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

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

APPLICABILITY: MODES 1, 2, and 3.

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

opening.

B. Required Action and B.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. One suppression chamber- C.1 Close the open vacuum 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to-drywell vacuum breaker breaker.

not closed.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.6-18 Amendment No.

RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One RHR suppression pool A.1 Restore RHR suppression 7 days cooling subsystem pool cooling subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two RHR suppression pool C.1 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months cooling subsystems suppression pool cooling inoperable. subsystem to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.6-24 Amendment No.

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in MODE 1, 2, containment to or 3. OPERABLE status.

B. Required Action and B.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Secondary containment C.1 -------------NOTE-------------

inoperable during movement LCO 3.0.3 is not applicable.

of recently irradiated fuel ---------------------------------

assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 2 3.6-28 Amendment No.

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable in MODE 1, 2 or to OPERABLE status.

3.

B. Required Action and B.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

OR -----------------------------------

Two SGT subsystems Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable in MODE 1, 2, or 3.

(continued)

Brunswick Unit 2 3.6-33 Amendment No. 280

RHRSW System

. 3.7.1 A CT IONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One RHRSW subsystem B.1 -------------NOTE--------------

inoperable for reasons other Enter applicable Conditions than Condition A. and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

Restore RHRSW 7 days subsystem to OPERABLE status.

C. Required Action and C. 1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. Both RHRSW subsystems D.1 -------------NOTE--------------

inoperable. Enter applicable Conditions and Required Actions of LCO 3.4. 7 for RHR shutdown cooling made inoperable by RHRSW System.

Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status.

(continued)

Brunswick Unit 2 3.7-2 Amendment No.

RHRSW System 3.7.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition D not met. AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and 31 days automatic. valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Brunswick Unit 2 3. 7-3 Amendment No.

CREV System 3.7.3 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. Required Action and C.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met applicable when entering in MODE 1, 2, or 3. MODE 3.

OR Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

D. Required Action and -------------------NOTE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met ------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE CREV Immediately the secondary containment, subsystem in during CORE radiation/smoke protection ALTERATIONS, or during mode.

OPDRVs.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

(continued)

Brunswick Unit 2 3.7-12 Amendment No.

Control Room AC System 3.7.4

3. 7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A One control room AC A.1 Restore control room AC 30 days subsystem inoperable. subsystem to OPERABLE status.

B. Two control room AC B.1 Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystems inoperable. control room AC subsystem to OPERABLE status.

C. Required Action and C.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met applicable when entering in MODE 1, 2, or 3. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Brunswick Unit 2 3.7-15 Amendment No.

Control Room AC System 3.7.4 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and --------------------N 0 TE--------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met ------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE control Immediately the secondary containment, room AC subsystem(s) in during CORE operation.

ALTERATIONS, or during OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs.

E. Three control room AC E.1 -------------NOTE--------------

subsystems inoperable in LCO 3.0.4.a is not MODE 1, 2, or 3. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Brunswick Unit 2 3.7-16 Amendment No.

Main Condenser Offgas 3.7.5

3. 7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas LCO 3.7.5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be ~ 243,600 µCi/second after decay of 30 minutes.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit.

B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR B.2 Isolate SJAE. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR B.3 -------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.7-18 Amendment No.

AC Sources-Operating 3.8.1 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite circuit inoperable ----------------------NOTE------------------

for reasons other than Enter applicable Conditions and Condition B. Required Actions of LCO 3.8.7, "Distribution Systems-Operating,"

AND when Condition F is entered with no AC power source to any 4.16 kV One DG inoperable for emergency bus.

reasons other than -------------------------------------------------

Condition B.

F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

OR F.2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status.

G. Two or more DGs G.1 Restore all but one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable. OPERABLE status.

H. Required Action and H.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A, B, C, D, E, F applicable when entering or G not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I. One or more offsite circuits 1.1 Enter LCO 3.0.3. Immediately and two or more DGs inoperable.

OR Two or more offsite circuits and one DG inoperable for reasons other than Condition B.

Brunswick Unit 2 3.8-6 Amendment No.

DC Sources-Operating 3.8.4 A CTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

8. Required Action and 8.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two or more DC electrical C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months power subsystems inoperable. AND C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ~ 130 V on float 7 days charge.

SR 3.8.4.2 Verify no visible corrosion at battery terminals and 92 days connectors.

Verify battery connection resistance is :-: :; 23.0 µohms for inter-cell connections and :-: :; 82.8 µohms for inter-rack connections.

SR 3.8.4.3 Verify battery cells, cell plates, and racks show no 18 months visual indication of physical damage or abnormal deterioration that degrades performance.

(continued)

Brunswick Unit 2 3.8-24 Amendment No.

Distribution Systems-Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC electrical D.1 Restore DC electrical 7 days power distribution power distribution subsystems inoperable for subsystems to OPERABLE AND reasons other than status.

Condition C. 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO E. Required Action and E.1 -------------N 0 TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A, B, C, or D applicable when entering not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 2 3.8-36 Amendment No.

BSEP 16-0087 Enclosure 6 Marked-up Technical Specifications Bases Pages - Unit 1 (For Information Only)

ECCS- Operating B 3.5.1 BASES ACTIONS C.1 and C.2 (continued)

If any Required Action and associated Completion Time of Condition A or B are not met, the plant must be brought to a MODE in which the LCO does not apply overall plant risk is minimized. 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 15) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short However.

voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C, 1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3.0.4.b. if applicable.

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components . consideration of the results determination of the acceptability of entering MODE 3 and establishment of risk management actions. if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times--afe is._reasonable, based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D.1 and D.2 If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days. In this condition , adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS . Also , the RCIC System will automatically provide makeup water at most reactor operating pressures . Immediate verificati on of RCIC OPERABI LITY is th erefore required when HPCI is inoperable. This may be performed as an administrative check by examining logs or other information to determine if RCIC is out of service for maintenance or other reason s. It does not mean to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System. However, if the OPERABILITY of the RCI C System cannot be immediately verified , Condition I must be immediately entered. If a sing le active component fails concu rrent with a design basis LOCA , there is a potential , depending on the specific fa ilu re, that th e minimum requ ired ECCS eq uipment wi ll not be availa ble.

A 14 day Completion Time is based on a reliability study cited in Brunswick Unit 1 B 3.5.1-7 Revision No. 31

ECCS-Operating B 3.5.1 BASES ACTIONS G.1 and G.2 (continued)

Since both a high pressure system (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the low pressure ECCS subsystem or the required ADS valve to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.

H.1 and H.2 If the HPCI System is inoperable in addition to one required ADS valve inoperable, adequate core cooling is ensured by the OPERABILITY of the remaining ADS valves and the low pressure ECCS subsystems.

However, overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA may result in the minimum required ECCS equipment not being available. Since a high pressure system is inoperable (HPCI) and the ADS cannot withstand a single active component failure , a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the HPCI System or the required ADS valve to OPERABLE status. The Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.

1.1 and1.2 If any Required Action and associated Completion Time of Condition D, E, F, G, or H is not met, or if two or more required ADS *1alves are inoperable, the plant must be brought to a condition MODE in which--tRe LCO does not apply overall plant risk is minimized . 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 ...aM reactor steam dome pressure reduced to < 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 15) and because the time spent in MODE 3 to perform the necessarv repa irs to restore the system to OPERABLE status will be short. However.

voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state.

Requ ired Action 1. 1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4 .a to enter MODE 3 during startup with the LCO not met.

However. _there is no rest[iction on the use of LCO .0 . .b i *c because LCO 3.0.4.b requ ires performance of a risk assessment addressing inoperable systems and components , considerati on of th e results, determination of the acceptability of entering MODE 3, and establishment of risk management actions . if appropriate. LCO 3.0.4 is not applicable to and the Note does not precl ude changes in MODES or other specified conditions in the Applicability that are requ ired to comply with ACTIONS or that are part of a sh utdown of the unit.

Brunswick Unit 1 B 3.5.1-9 Revision No. 31 I

ECCS-Operating B 3.5.1 The allowed Completion Time&-afe~ 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 3.5.1-10 Revision No. 31 I

ECCS-Operating B 3.5.1 BASES ACTIONS J.1 and J.2 (continued)

If two or more required ADS valves are inoperable. there is a reduction in the depressurization capability. The plant must be brought to a condition 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 reactor steam dome pressure reduced to ::> 150 psig 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.

K1 When multiple ECCS subsystems are inoperable , as stated in Condition J!S, the plant is in a condition outside of the accident analyses.

Therefore , LCO 3.0 .3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The flow path piping of each ECCS has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System , CS subsystems , and LPCI subsystems full of water ensures that the ECCS w ill perform properly, injecting its full capacity into the RCS upon demand . This SR also prevents water hammer in the piping following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The 31 day Frequency is based on the gradual nature of void buildup in the ECCS piping , the procedural controls governing system operation , and operating experience .

SR 3.5.1.2 Verifying the correct alignment for manual , power operated , and automatic valves in the ECCS flow paths provides assurance that the proper flow paths exist for ECCS operation . This SR does not apply to valves that are locked , sealed , or otherwise secu red in position since these are verified to be in the correct position prior to locking , sealing , or securing . A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition to the accident position in the proper stroke time. This SR does not require any testing or valve manipulation ; rather, it involves verification th at those valves capable of potentially bein g mispositioned are in the correct position . This SR does not apply to valves that cannot be inadvertently misaligned , such as check valves. For the HPCI System, this SR al so includes the steam flow path for the tu rbine and the flow contro ller position.

(continued)

Brunswick Unit 1 B 3.5. 1-11 Revision No. 31 I

ECCS-Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.12 (continued)

REQUIREMENTS TIME testing. This exception is allowed since the ECCS instrumentation response time is a small part of the ECCS RESPONSE TIME (e .g.,

sufficient margin exists in the emergency diesel generator start time when compared to the instrumentation response time) (Ref. 14).

ECCS RESPONSE TIME tests are conducted every 24 months. The 24 month Frequency is consistent with the Brunswick refueling cycle.

REFERENCES 1. UFSAR, Section 6.3.2.2.3.

2. UFSAR, Section 6.3.2.2.4.

3. UFSAR, Section 6.3.2.2.1.

4. UFSAR, Section 6.3.2.2.2.

5. UFSAR, Section 15.2.

6. UFSAR, Section 15.6.

7. 10 CFR 50 , Appendix K.

8. UFSAR, Section 6.3.3.

9. 10 CFR 50.46.

10. (Deleted.)

11. 10 CFR 50.36(c)(2)(ii).

12. Memorandum from R.L . Baer (NRC) to V. Stello, Jr. (NRC) ,

Recommended Interim Revisions to LCOs for ECCS Components ,

December 1, 1975.

13. UFSAR, Section 6.3.3.7.

14. NED0-32291-A, System Analyses for the Elimination of Selected Response Time Testing Requirements , October 1995.

15. NEDC-32988-A. Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States fo r BWR Plants, December 2002.

Brunswick Unit 1 B3 .5.1 -17 Revision No. 58 I

RCIC System B 3.5.3 BASES ACTIONS A.1 and A.2 (continued)

OPERABLE status within 14 days. In this condition , loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is available to function during a loss of coolant accident (LOCA) . OPERABILITY of the HPCI System is therefore verified immediately when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if the HPCI System is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be immediately verified , however, Condition B must be immediately entered . For transients and certain abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status .

The 14 day Completion Time is based on the availability of the HPCI System and the low probability of the occurrence of an event that would require the RCIC System.

B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time , or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply overall plant risk is minimized. 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 reactor steam dome pressure reduced to < 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 4) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However, voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on th e use of LCO 3.0.4.b, if applicable ,

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, cons ideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions , if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Brunswick Unit 1 B 3.5.3-3 Revision No. 31 I

RCIC System B 3.5.3 The allowed Completion Time&-afe~ 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 3.5.3-4 Revision No. 31 I

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.5 (continued)

REQUIREMENTS This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1. UFSAR, Section 3.1.2.4.4.

2. UFSAR, Section 5.4.6.

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

4. NEDC-32988-A. Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002.

Brunswick Unit 1 B 3.5.3-8 Revision No. 31 I

Reactor Bu ilding-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 BASES ACTIONS E.1 (continued) threaten the ability to mitigate an event that causes a containment depressurization . Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Completion Time for Condition A and the fact that the leak tight primary containment boundary is being maintained .

E.1 If one line has one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition E. the remaining breakers in the remaining lines can provide the opening function . The plant must be brought to a condition in which overall plant risk is minimized. 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However.

voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action E.1 is modified by a Note that states that LCO 3.0.4 a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4 .a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3.0.4.b. if applicable.

because LCO 3,0.4 .b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptability of entering MODE 3. and establishment of risk management actions . if appropriate. LCO 3.0.4 is not applicable to . and the Note does not preclude. changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable. based on operating experience. to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F-4G .1 With two lines with one or more vacuum breakers inoperable for openi ng ,

the primary containment boundary is intact. However, in the event of a containment depressurization , the function of the vacuum breakers is lost if the vacuum breakers are inoperable for reasons other than th e Nitrogen Backup System being inoperable (Condition D). Therefo re , all vacuum breakers in one line must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This Completion Time is consistent with th e ACTION S of LCO 3.6.1.1, which requires that prim ary containment be restored to OPERABLE status with in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

G.1 and G.2H.1 and H.2 Brunswick Un it 1 B 3.6.1.5-6 Revision No. 31 I

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6 .1.5 If any Required Action and associated Completion Time of Condition A.

B. C. D. F or G 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 3.6.1 .5.1 REQUIREMENTS The bank of nitrogen bottles supplying each nitrogen backup subsystem header is required to be verified to be pressurized to ~ 1130 psig to ensure sufficient motive force is available to the pneumatic butterfly valve actuators following a LOCA and subsequent primary containment isolation . A nitrogen bottle pressure of ~ 1130 psig assures sufficient capacity to actuate and cycle the pneumatic butterfly valve for 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months including design system leakage. This Surveillance may be satisfied by (continued)

Brunswick Unit 1 B 3.6.1.5-7 Revision No. 31 I

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1 .5 BASES SURVEILLANCE SR 3.6.1.5.6 (continued)

REQUIREMENTS 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is concluded to be acceptable from a reliability standpoint.

REFERENCES 1. NRG Generic Letter GL 84-09 , Recombiner Capability Requirements of 10 CFR 50.44(c)(3)(ii) .

2. UFSAR, Section 6.2.

3. 10 CFR 50 .36(c)(2)(ii).

4. NEDC-32988-A. Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants , December 2002.

Brunswick Unit 1 B 3.6.1.5-9

Revision No. 31 I

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BASES ACTIONS A.1 (continued) with those assumed for the design basis analysis. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered acceptable due to the low probability of an event in which the remaining vacuum breaker capability would not be adequate .

.B...1 If a required suppression chamber-to-drvwell vacuum breaker is inoperable for opening and is not restored to OPERABLE status within the required Completion Time. the plant must be brought to a condition in which overall plant risk is minimized . 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 .

Remaining in the Applicabilitv of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However.

voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3 This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However there is no restriction on the use of LCO 3.0.4.b. if applicable because LCO 3 O 4 b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptabilitv of entering MODE 3. and establishment of risk management actions if appropriate. LCO 3.0.4 is not applicable to. and the Note does not preclude. changes in MODES or other specified conditions in the Applicabilitv that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable. based on operating experience. to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

g,+C.1 With one vacuum breaker not closed , communication between the drywell and suppression chamber airspace could occur, and , as a result, there is the potential for primary containment overpressurization due to this bypass leakage if a LOCA were to occur. Therefore, the open vacuum breaker must be closed . A short time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment. If vacuum breaker position indication is not available , an alternate method of verifying that the vacuum breakers are closed is to verify that the differential pressure between the suppression chamber and drywell is maintained > 0.5 times the initial differential pressure for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without nitrogen makeup. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is considered adequate to perform this test.

Brunswick Unit 1 B 3.6.1.6-4 Revision No. 31 I

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 C.1 and C.2D.1 and D.2 If any Required Action and associated the open suppression chamber-to-drywell vacuum breaker cannot be closed within the required Completion Time can not 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 3.6.1.6.1 REQUIREMENTS Each vacuum breaker is verified closed (except when the vacuum breaker is performing its intended design function) to ensure that this potential large bypass leakage path is not present. This Surveillance is performed by observing the vacuum breaker position indication or by verifying that the differential pressure between the suppression chamber (continued)

Brunswick Unit 1 B 3.6.1.6-5 Revision No. 31 I

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BASES SURVEILLANCE SR 3.6.1.6.1 (continued)

REQUIREMENTS and drywell is maintained > 0.5 times the initial differential pressure for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without nitrogen makeup. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel and procedural controls to ensure the drywell is normally maintained at a higher pressure than the suppression chamber, and has been shown to be acceptable through operating experience . This verification is also required within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after any discharge of steam to the suppression chamber from any source, and within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after an operation that causes any of the vacuum breakers to open.

A Note is added to this SR which allows suppression chamber-to-drywell vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers.

SR 3.6 .1.6.2 Each required vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position. This is accomplished by verifying each required vacuum breaker operates through at least one complete cycle of full travel. This SR ensures that the safety analysis assumptions are valid. The 92 day Frequency of this SR was developed , based on lnservice Testing Program requirements to perform valve testing at least once every 92 days. In addition , this functional test is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after a discharge of steam to the suppression chamber fro m the SRVs.

SR 3.6.1.6.3 Verification of the vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 24 month Frequency has been demonstrated to be acceptable, based on operating experience , and is further justified because of other surveillances performed more frequ ently that convey the proper functioning status of each va cuum brea ker.

RE FERENCES 1. UFSAR , Section 6.2.

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

3. NEDC-32988-A. Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants December 2002 .

Brunswick Unit 1 B 3.6.1.6-5 Revision No. 65

RHR Suppression Pool Cooling B 3.6 .2.3 BASES ACTIONS (continued)

If one RHR suppression pool cooling subsystem is inoperable and is not restored to OPERABLE status within the required Completion Time. the plant must be brought to a condition in which overall plant risk is minimized. 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 5) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However.

voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state .

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3 0.4.a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3.0.4.b. if applicable .

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptability of entering MODE 3. and establishment of risk management actions. if appropriate . LCO 3.0.4 is not applicable to. and the Note does not preclude. changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable. based on operating experience. to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems .

.G...1 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 OBA and because alternative methods to remove heat from primary containment are available.

C.1 and C.20.1 and D.2 If aAy-the Required Action and associated Completion Time of Condition C 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 reasonabl e, based on operating experience, to rea ch the required plant conditions from fu ll power conditions in an orderly manner and without challen ging plant systems.

Brunswick Un it 1 B 3.6.2.3-3 Revision No. 41

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 OBA (Ref. 2). The normal test of centrifugal pump performance required by ASME OM Code (Ref. 4) is covered by the requirements of LCO 3.5.1, "ECCS-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 Code for Operation and Maintenance of Nuclear Power Plants .

5. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002 Brunswick Unit 1 B 3.6.2.3-4 Revision No. 59

Secondary Containment B 3.6.4 .1 BASES ACTIONS A.1 (continued) and 3. This time period also ensures that the probabil ity of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

B.1 and B.2 If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply overall plant risk is minimized . 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 7),

because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However there is no restriction on the use of LCO 3.0.4.b, if applicable .

because LCO 3.0 4,b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptability of entering MODE 3, and establishment of risk management actions . if appropriate. LCO 3.0.4 is not applicable to , and the Note does not preclude , changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times afe--is_reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 and C.2 Movement of recently irradiated fuel assemblies in the secondary containment and OPDRVs can be postulated to cause significant fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the environ ment. Therefore, movement of recently irradiated fu el assemblies must be immediately suspended if the secondary containment is inoperable. Suspension of this activity shall not preclude completing an action that involves moving a component to a safe position. Also, acti on must be immediately in itiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission produ ct release. Action s must continue until OPDRVs are suspended .

LCO 3.0.3 is not applicable wh ile in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action C.1 has been mod ified by a Note stating that Brunswick Unit 1 B 3.6.4.1 -3 Revision No. 31

Secondary Containment B 3.6.4.1 BASES (continued)

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

2. UFSAR, Section 15.6.4.

3. Not used.

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

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

6. Regulatory Guide 1.52 , Revision 1.

7. NEDC-32988-A. Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002 .

Brunswick Unit 1 B 3.6.4.1-6 Revision No. 31 I

SGT System B 3.6.4 .3 BASES APPLICABILITY (OPDRVs) or during movement of recently irradiated fuel assemblies in (continued) the secondary containment. Due to radioactive decay, the SGT System is only required to be OPERABLE during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ).

ACTIONS A.1 With one SGT subsystem inoperable in MODE 1, 2, or 3, the inoperable subsystem must be restored to OPERABLE status in 7 days. In this condition , the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a OBA occurring during this period.

B.1 and B.2 In MODE 1, 2, or 3, if one SGT subsystem cannot be restored to OPERABLE status within the required Completion Time or both SGT subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply overall plant risk is minimized . 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However.

voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state, Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4 .a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable.

because LCO 3.0.4.b requ ires performance of a risk assessment addressing inoperable systems and components , considerati on of the results. determination of the acceptability of entering MODE 3. and establishment of risk man agement actions if appropriate . LCO 3.0.4 is not applicable to . and the Note does not preclude changes in MODES or other specified con ditions in the Applicabil ity that are requ ired to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are-is_reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Brunswick Unit 1 B 3.6.4 .3-3 Revision No. 31

SGT System B 3.6.4.3 BASES SURVEILLANCE SR 3.6.4.3.2 REQUIREMENTS (continued) This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6) ,

except as specified in Specification 5.5.7, "Ventilation Filter Testing Program (VFTP)". The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). It is noted that, per the basis provided by ESR 99-00055 (Ref. 7) , system flow rate is determined using installed calibrated flow orifice plates. Specific test frequencies and additional information are discussed in detail in the VFTP .

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. While this Surveillance can be performed with the reactor at power, operating experience has demonstrated that these components will usually pass the Surveillance when performed at the 24 month Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation ,"

overlaps this SR to provide complete testing of the safety function .

Therefore, the Frequency was found to be acceptable from a reliability standpoint.

REFERENCES 1. UFSAR, Section 6.5.1.

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

3. UFSAR Section 15.6.4.

4. Not used.

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

6. Regulatory Guide 1.52 , Revision 1.

7. ESR 99-00055 , SBGT and CBEAF Technical Specification Surveillance Flow Measurement.

8. NEDC-32988-A Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States fo r BWR Plants. December 2002 .

Brunswick Unit 1 B 3.6.4.3-7 Revision No. 31 I

RHRSW System B 3.7.1 BASES ACTIONS (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 If one RHRSW subsystem is inoperable or one RHRSW pump in one or one subsystem is inoperable and not restored within the provided Completion Times. the plant must be brought to a condition in which overall plant risk is minimized . 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 .

Remaining in the Applicabilitv of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 7) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However.

voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C.1 is modified by a Note that states that LCO 3.0.4 .a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3.0.4 .b. if applicable.

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components. consideration of th e results. determination of the acceptability of entering MODE 3. and establishment of risk management actions, if appropriate . LCO 3.0.4 is not applicable to. and the Note does not preclude. changes in MODES or other specified conditions in the Applicability th at are required to comply with ACTIONS or th at are part of a shutdown of the unit G,..+D .1 With both RHRSW subsystems inoperable (e.g. , one or two RHRSW pumps inoperable in each subsystem) , the RHRSW System is not Brunswick Unit 1 B 3.7.1-4 Revision No. 41

RHRSW System B 3.7 .1 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.2E .1 and E.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 -5 Revision No. 41

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.

7. NEDC-32988-A. Revision 2. Technical Justification to Support Risk-Informed Mod ification to Selected Required End States for BWR Plants. December 2002.

Brunswick Unit 1 B 3.7.1-6 Revision No. 41

CREV System B 3.7.3 BASES ACTIONS C.1 and C.2 (continued)

In MODE 1, 2, or 3, if any Required Action and requ ired Completion Time of Condition A or B cannot be met or two CREV subsystems are inoperable for reasons other than Cond ition B, the unit must be placed in a MODE that minimizes accident overall plant risk. 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 9) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However.

voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state ,

Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b if applicable.

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptabilitv of entering MODE 3. and establishment of risk management actions. if appropriate. LCO 3.0.4 is not applicable to. and the Note does not preclude. changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times afe-is_reasonable, based on operating experience , to rea ch the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1. D.2.1 . D.2 .2. and D.2.3 The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inabil ity to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown .

During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS , or during OPDRVs, if the inoperable CREV subsystem cannot be restored to OPERABLE status within the required Completion Time , the OPE RABLE CREV subsystem may be placed in the radiation/smoke protection mode. This action ensures that the remaining subsystem is OPERABLE , that no fail ures that would prevent automatic actuation will occur, and th at any active fai lu re will be readily detected.

An altern ative to Req ui red Action D.1 is to immediately suspend activities that present a potential for releasing rad ioactivity that might requ ire Brunswick Unit 1 B 3.7.3-5 Revision No. 64

CREV System B 3.7 .3 BASES SURVEILLANCE SR 3.7.3.4 REQUIREMENTS (continued) This SR verifies that on an actual or simulated initiation signal , each CREV subsystem starts and operates. This SR includes ensuring outside air flow is diverted to the HEPA filter and charcoal adsorber bank of each CREV subsystem. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.7 .1 overlaps this SR to provide complete testing of the safety function. Operating experience has demonstrated that the components will usually pass the SR when performed at the 24 month Frequency.

Therefore , the Frequency was found to be acceptable from a reliability standpoint.

REFERENCES 1. UFSAR, Section 6.4 .

2. UFSAR, Section 9.4 .

3. UFSAR, Section 6.4.4 .1.

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

5. ESR 99-00055 , SBGT and CBEAF Technical Specification Surveillance Flow Measurement.

6. Regulatory Guide 1.196

7. NEI 99-03 , "Control Room Habitability Assessment," June 2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30 , 2004 , "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

9. NEDC-32988-A. Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002 Brunswick Unit 1 B 3.7.3-8 Revision No. 64 I

Control Room AC System B 3.7.4 BASES (continued)

ACTIONS A.1 With one control room AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition , the remaining OPERABLE control room AC subsystems are adequate to perform the control room air conditioning function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystems could result in loss of the control room air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation , the consideration that the remaining subsystems can provide the required protection , and the availability of alternate safety and nonsafety cooling methods.

B.1 With two control room AC subsystems inoperable, the Control Room AC System may not be capable of performing the intended function .

However, since the BNP control room is common to both Units 1 and 2, the risk associated with continued operation for a relatively short time could be less than that associated with an immediate controlled shutdown of both units. Therefore, additional time is allowed to restore one of the inoperable control room AC subsystems to OPERABLE status. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining the Control Room AC System OPERABLE . This time period also ensures that the probability of an accident (requiring Control Room AC System OPERABILITY) occurring during periods when two control room AC subsystems are inoperable is minimal.

C.1 and C.2 In MODE 1, 2, or 3, if Required Action A.1 or B.1 cannot be completed within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk. 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 .

Remaining in the Applicability ofthe LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However.

voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action C .1 is modified by a Note that states that LCO 3.0.4 .a is not applicable when e ntering MODE 3. This Note prohibits the use of LCO 3.0.4 .a to enter MODE 3 during startup w ith the LCO not met.

However, there is no restriction on the use of LCO 3.0.4 .b if applicable .

because LCO 3.0.4 .b requires performance of a risk assessment addressing inoperable systems an d components . consideration of the results . determination of the acceptability of entering MODE 3. and Brunswick Unit 1 B 3.7.4-3 Revision No. 31

Control Room AC System B 3.7.4 establ ishment of risk management actions if appropriate . LCO 3.0.4 is not applicable to . and the Note does not preclude . changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit The allowed Completion Times ai:e-is_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 3.7.4-4 Revision No. 31 I

Control Room AC System B 3.7.4 BASES ACTIONS D.1, D.2.1, D.2.2, and D.2.3 (continued)

LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS , or during OPDRVs, if Required Action A.1 or B.1 cannot be completed within the associated Completion Time , the OPERABLE control room AC subsystem or subsystems may be placed immediately in operation . This action ensures that the remaining subsystem(s) is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected .

An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room . This places the unit in a condition that minimizes risk.

If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also , if applicable , action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release . Action must continue until the OPDRVs are suspended .

E.1 If three control room AC subsystems are inoperable in MODE 1, 2, or 3, the Control Room AC System may not be capable of performing the intended function . Theref.ore , LCO 3.0 .3 must be entered immediately.

Therefore. the plant must be brought to a MODE in which overall plant risk is minimized . 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 .

Remaini ng in the Applicability of the LCO is acceptable because the pla nt risk in MODE 3 is similar to or lower than th e risk in MODE 4 (Ref. 3) and

~ause the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However.

volu ntarv entry into MODE 4 may be made as it is also an acceptable low-risk state Req uired Action E.1 is mod ified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4 .a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3,0.4,b. if applicable .

Brunswick Unit 1 B 3.7.4-5 Revision No. 31

Control Room AC System 8 3.7.4 because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results determination of the acceptability of entering MODE 3. and establishment of risk management actions if appropriate LCO 3 0 4 is not applicable to and the Note does not preclude changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is 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 8 3.7.4-6 Revision No. 31 I

Control Room AC System B 3.7.4 BASES ACTIONS F.1, F.2, and F.3 (continued)

LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations .

Therefore, inability to suspend movement of irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown .

During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS , or during OPDRVs , with three control room AC subsystems inoperable, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might requ ire isolation of the control room . This places the unit in a condition that minimizes risk.

If applicable, CORE AL TERA TIONS and handling of irradiated fuel in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position . Also , if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended .

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analyses .

The SR consists of a combination of testing and calculation . The 24 month Frequency is appropriate since significant degradation of the Control Room AC System is not expected over this time period .

REFERENCES 1. UFSAR, Section 6.4.2.

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

3, NEDC-32988-A. Revision 2 Technical Justification to Support Risk-Informed Modification to Selected Requ ired End States for BWR Plants, December 2002 ,

Brunswi ck Unit 1 B 3.7.4-7 Revision No. 31 I

Main Condenser Offgas B 3.7.5 BASES (continued)

LCO To ensure compliance with the assumptions of the Main Condenser Offgas System failure event (Ref. 1), the fission product release rate should be consistent with a noble gas release to the reactor coolant of 100 µCi/MWt-second after decay of 30 minutes. The LCO is established consistent with this requirement (2436 MWt x 100 µCi/MWt-second =

243 ,600 µCi/second) and is based on the original licensed RATED THERMAL POWER.

APPLICABILITY The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System. This occurs during MODE 1, and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation. In MODES 4 and 5, main steam is not being exhausted to the main condenser and the requirements are not applicable.

ACTIONS A.1 If the offgas radioactivity rate limit is exceeded , 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the gross gamma activity rate to within the limit. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on engineering judgment, the time required to complete the Required Action , the large margins associated with permissible dose and exposure limits, and the low probability of a Main Condenser Offgas System failure.

B.1. B.2. and B.3.1. and B.3.2 If the gross gamma activity rate is not restored to within the limits in the associated Completion Time , all main steam lines or the SJAE must be isolated . This isolates the Main Condenser Offgas System from significant sources of radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed , and at least one main steam line drain valve in each drain line is closed. 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 perform the actions from full power conditions in an orderly manner and without challenging unit systems .

(continued)

Brunswick Unit 1 B 3.7.5-2 Revision No. 31 I

Main Condenser Offgas B 3.7.5 BASES ACTIONS B.1. B.2. B.3.1. and B.3 .2 (continued)

An alternative to Required Actions B.1 and B.2 is to place the unit in a MODE in which the LCO does not apply overall plant risk is minimized .

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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MOPE 3 is similar to or lower than the risk in MODE 4 <Ref. 4) and because the time spent in MODE 3 to pertorm the necessary repairs to restore the system to OPERABLE status will be short. However.

voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state .

Required Action B.3 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4 .b. if applicable ,

because LCO 3.0.4 .b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results. determination of the acceptability of entering MODE 3, and establishment of risk management actions , if appropriate . LCO 3.0.4 is not applicable to, and the Note does not preclude. changes in MODES or other specified conditions in the Appl icability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times af&-i.s_reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7 .5.1 REQUIREMENTS This SR, on a 31 day Frequency, requires an isotopic analysis of an offgas sample (taken at the discharge of the main condenser air ejector prior to dilution or discharge) to ensure that the required limits are satisfied . The noble gases to be sampled are Xe-133, Xe-135 , Xe-138 ,

Kr-85m , Kr-87 , and Kr-88. If the measured rate of radioactivity increases significantly (by~ 50% after correcting for expected increases due to changes in THERMAL POWER) , an isotopic analysis is also performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the increase is indicated (by the condenser air ejector noble gas activity monitor) , to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas , and is acceptable , based on operating experience .

This SR is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation. Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates.

Brunswick Unit 1 B 3.7.5-3 Revision No. 31

Main Condenser Offgas B 3.

7.5 REFERENCES

1. UFSAR, Section 11 .3.

2. 10 CFR 50.67 .

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

4. NEDC-32988-A. Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002 ,

Brunswick Un it 1 B 3.7.5-4 Revision No. 31 I

AC Sources-Operating B 3.8.1 BASES ACTIONS G.1 (continued)

According to Regulatory Guide 1.93 (Ref. 9) , with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . While this Action allows more than two DGs to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two DGs are required by the LCO , and a loss of those two DGs results in a total loss of on site power to the Class 1E Electrical Power Distribution System. Thus, with the BNP electrical design , a loss of the four DGs results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9).

H.1 and H.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply overall plant risk is minimized. To achieve this status, the unit 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 14) and because the time spent in MODE 3 to perform the necessarv repai rs to restore the system to OPERABLE status will be short. However.

voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state .

Required Action H 1 is modified by a Note that states that LCO 3,0.4 ,a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4 ,a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3.0.4.b, if applicable ,

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptability of entering MODE 3, and establishment of risk management actions . if appropriate. LCO 3.0.4 is not applicable to. and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times afe-is_reasonable , based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems .

L1 Condition I corresponds to a level of degradation in which all redundan cy in the AC electrical power supplies has been lost. At thi s severely deg raded level, any further losses in the AC electrical power system may cau se a loss of function. Therefore, no additional time is justified for continued operation . The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all Brunswick Unit 1 B 3.8.1-19 Revision No. 31

AC Sources-Operating B 3.8.1 BASES REFERENCES 11 . Regulatory Guide 1.9, July 1993, Revision 3.

(continued)

12. Regulatory Guide 1.137, January 1978.

13. IEEE Standard 308.

14. NEDC-32988-A Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002, Brunswick Unit 1 B 3.8.1-34 Revision No. 31 I

DC Sources-Operating B 3.8.4 BASES ACTIONS A.1 (continued)

Therefore.the Required Actions of Condition A are modified by a Note to indicate that when Condition A results in de-energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem , Actions of LCO 3.8 .7 must be immediately entered . This allows Condition A to provide requirements for the loss of a DC electrical power subsystem without regard to whether a distribution subsystem is de-energized. LCO 3.8.7 provides the appropriate restriction for a de-energized distribution subsystem.

Condition A represents one division with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division .

If one of the required DC electrical power subsystems is inoperable (e.g .,

inoperable battery, inoperable battery charger(s), or inoperable battery charger and associated inoperable battery) , the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could , however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 7 days. The Completion time is based on the capacity and capability of the remaining DC Sources, including the enhanced reliability afforded by the capability to manually transfer DC loads to the opposite unit's DC electrical power distribution subsystems .

B.1 and B.2 If the DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time or if two or more DC electrical power subsystems are inoperable , the unit must be brought to a MODE in which the LCO does not apply overall plant risk is minimized . To achieve this status, the unit 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 .

Remaining in the Appl icability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 12) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However, voluntarv entry into MODE 4 may be made as it is also an accepta ble low-risk state, Required Action B.1 is mod ified by a Note that states that LCO 3.0.4.a is not appl icable when entering MODE 3. This Note prohibits th e use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, th ere is no restriction on the use of LCO 3.0.4.b, if applicable because LCO 3.0.4 .b req uires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and Brunswick Un it 1 B 3.8.4-4 Revision No. 31

DC Sources-Operating 8 3.8.4 establishment of risk management actions. if appropriate. LCO 3.0.4 is not applicable to. and the Note does not preclude. changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

(continued)

Brunswick Unit 1 8 3.8.4-5 Revision No. 31 I

DC Sources-Operating B 3.8.4 BASES ACTIONS B.1 and B.2 (continued)

The allowed Completion Times are-is_reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7) .

C 1andC2 If two or more DC electrical power subsystem are inoperable, the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status , the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit 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 .

The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatorv Guide 1.93 <Ref. 7) .

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function . Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fu lly charged state. The voltage requirements are based on the nominal design voltage of the battery. The 7 day Frequency is conservative when compared with manufacturer recommendations and IEEE-450 (Ref. 8).

SR 3.8.4.2 Visual inspection to detect corrosion of the battery cells and connections ,

or measurement of the resistance of each inter-cell and inter-rack connection , provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.

The connection resistance limits are ::; 1.2 times the established benchmark resistance values for the connections or ::; 5µohms above the established benchmark resistance values for the connections, which ever is higher. These connection resistance acceptance criteri a were derived from IEEE-450 (Ref. 8) and IEEE-484 (Ref. 9) , respectively.

The Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days. This Frequency is consistent with man ufacturers recommendations.

(contin ued)

Brunswick Unit 1 B 3.8.4-6 Revi sion No . 31

DC Sources-Operating B 3.8.4 BASES REFERENCES 6. 10 CFR 50.36(c)(2)(ii).

(continued)

7. Regulatory Guide 1.93 , December 1974.

8. IEEE Standard 450, 1987.

9. IEEE Standard 484 , 1996.

10. UFSAR, Section 8.3.2.

11 . IEEE Standard 485, 1983.

12. NEDC-32988-A. Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002.

Brunswick Unit 1 B 3.8.4-12 Revision No. 31 I I_

Distribution Systems-Operating B 3.8.7 BASES ACTIONS D.1 (continued) distribution system . At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be restored OPERABLE . This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition D was entered . The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

E.1 and E.2 If the inoperable electrical power distribution subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply overall plant risk is minimized . 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 .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 4) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However.

voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action E.1 is modified by a Note that states that LCO 3.0.4 .a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4 .a to enter MODE 3 during startup with the LCO not met.

However. there is no restriction on the use of LCO 3.0.4.b. if applicable.

because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptability of entering MODE 3. and establishment of risk management actions. if appropriate. LCO 3.0.4 is not applicable to . and the Note does not preclude . changes in MODES or other specified cond itions in the Appl icabil ity that are required to com ply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completi on Times afe-i.s_reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant system s.

F.1 Condition F corresponds to a level of degradation in th e el ectrical pow er distri bution system that causes a required safety function to be lost.

When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required functio n, the plant is in a con dition outside th e accident analysis. Therefore, no add itiona l time is Brun swick Un it 1 B 3.8.7- 13 Revision No. 3 1

Distribution Systems-Operating B 3.8.7 BASES (continued)

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS Th is Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly , with the correct circuit breaker alignment. This includes verifying that distribution bus tie breakers are open and control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels are aligned to their normal DC sources . The correct breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained , and power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses . This may be performed by verification of absence of low voltage alarms or by verifying a load powered from the bus is operating. The 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions .

SR 3.8.7.2 This Surveillance verifies that no combination of more than two power conversion modules (consisting of either two lighting inverters or one lighting inverter and one plant uninterruptible power supply unit) are aligned to Division II (bus B). Two power conversion modules aligned to Division II (bus B) was an initial assumption in the DC battery load study.

Limiting two power conversion modules to be aligned to Division II ensures the associated batteries will supply DC power to safety related equipment during a design basis event. The 7 day Frequency takes into account the redundant capability of the DC electrical power distribution subsystems and indications available in the control room to alert the operator of power conversion module misalignment.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

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

4. NEDC-32988-A. Revision 2, Tech nical Justifi cati on to Su pport Risk-Informed Modification to Selected Required End States fo r BWR Plants December 2002 .

Brunswick Unit 1 B 3. 8.7-15 Revision No. 31 I

BSEP 16-0087 Enclosure 7 Page 1 of 1 Regulatory Commitments The following table identifies those actions committed to by Duke Energy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr.

Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Regulatory Commitments Due Date I Event Duke Energy will follow the guidance Ongoing established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council , Revision 3, July 2000.

Duke Energy will follow the guidance Upon implementation of amendment.

established in TSTF-IG-05-02, Revision 2, "Implementation Guidance for TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A."'

v t e Letter Sequence Request
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BSEP 16-0087, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A.

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