Text

Issuance of Amendments Regarding Request to Relocate Specific Surveillance Frequencies to a Licensee Controlled Program
	ML17096A129
Person / Time
Site:	Brunswick
Issue date:	05/24/2017
From:	Andrew Hon; Plant Licensing Branch II
To:	William Gideon; Duke Energy Progress
	Hon A, NRR/DORL/LPL2-2, 415-8480
References
	CAC MF7206, CAC MF7207
	Download: ML17096A129 (40)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 24, 2017 Mr. William R. Gideon, Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd., SE, M/C BNP001 Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING REQUEST TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM (CAC NO. MF7206 AND MF7207)

Dear Mr. Gideon:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment Nos. 276 and 304 to Renewed Facility Operating License Nos. DPR-71 and DPR-62, respectively, for Brunswick Steam Electric Plant, Units 1 and 2. The amendments consist of changes to the technical specifications (TSs) in response to your application dated December 21, 2015, as supplemented by letters dated June 29, July 13, August 15, November 1, November 17, 2016, and February 27, 2017. The amendments revise the TSs by relocating specific surveillance frequencies to a licensee-controlled program consistent with the NRC-approved Technical Specifications Task Force (TSTF)-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative Sb."

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Sincerely, 44' z/-

Andrew Hon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 276 to DPR-71

2. Amendment No. 304 to DPR-62

3. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 276 Renewed License No. DPR-71

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Duke Energy Progress, LLC, dated December 21, 2015, as supplemented by letters dated June 29, July 13, August 15, November 1, November 17, 2016, and February 27, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-71 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 276, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Dateoflssuance: May 24, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 276 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace Page 6 of Renewed Facility Operating License No. DPR-71 with the attached Page 6.

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3.1-6 3.1-6 3.1-10 3.1-10 3.1-13 3.1-13 3.1-17 3.1-17 3.1-19 3.1-19 3.1-20 3.1-20 3.1-21 3.1-21 3.1-22 3.1-22 3.1-26 3.1-26 3.2-1 3.2-1 3.2-2 3.2-2 3.2-4 3.2-4 3.3-4 3.3-4 3.3-5 3.3-5 3.3-6 3.3-6 3.3-7 3.3-7 3.3-8 3.3-8 3.3-14 3.3-14 3.3-15 3.3-15 3.3-16 3.3-16

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(c) Transition License Conditions

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

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

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 1801h day falls within an outage window; then, in that case, compietion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

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

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

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 276, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 276

Reactivity Anomalies 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify core reactivity difference between the monitored Once within core kett and the predicted core kett is within +/- 1% Llk/k. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching equilibrium conditions following startup after fuel movement within the reactor pressure vessel or control rod replacement In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.1-6 Amendment No. 276

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program SR 3.1.3.2 -------------------------------N 0 TE---------------------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SR 3.1.3.3 Verify each control rod scram time from fully withdrawn In accordance with to notch position 06 is ::; 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)

Brunswick Unit 1 3.1-10 Amendment No. 276 I

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify, for a representative sample, each tested In accordance with control rod scram time is within the limits of the Surveillance Table 3.1.4-1 with reactor steam dome pressure Frequency Control

800 psig. Program SR 3.1.4.3 Verify each affected control rod scram time is within Prior to declaring the limits of Table 3 .1 .4-1 with any reactor steam control rod dome pressure. OPERABLE after work on control rod or CRD System that could affect scram time SR 3.1.4.4 Verify each affected control rod scram time is within Prior to exceeding the limits of Table 3.1.4-1 with reactor steam dome 40% RTP after pressure:::: 800 psig. fuel movement within the affected core cell Prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time Brunswick Unit 1 3.1-13 Amendment No. 276

Control Rod Scram Accumulators 3.1.5 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. One or more control rod C.1 Verify all control rods Immediately upon scram accumulators associated with inoperable discovery of inoperable with reactor accumulators are fully charging water steam dome pressure inserted. header pressure

< 950 psig. < 940 psig AND C.2 Declare the associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months control rod inoperable.

D. Required Action B.1 or C.1 D.1 --------------N 0 TE-------------

and associated Completion Not applicable if all Time not met. inoperable control rod scram accumulators are associated with fully inserted control rods.

Manually scram the reactor. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each control rod scram accumulator pressure is In accordance with

~ 940 psig. the Surveillance Frequency Control Program Brunswick Unit 1 3.1-17 Amendment No. 276 I

Rod Pattern Control 3.1.6 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Nine or more OPERABLE B.1 --------------N 0 TE-------------

control rods not in Co ntrol rod may be compliance with BPWS. bypassed in the RWM or RWM may be bypassed as allowed by LCO 3.3.2.1.

Suspend withdrawal of Immediately control rods.

B.2 Manually scram the reactor. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply with BPWS. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.1-19 Amendment No. 276 I

SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1. 7 Standby Liquid Control (SLC) System LCO 3.1. 7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1and2.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SLC subsystem A.1 Restore SLC subsystem to 7 days inoperable. OPERABLE status.

B. Two SLC subsystems B.1 Restore one SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable. 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 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify available volume of sodium pentaborate solution In accordance with is within the limits of Figure 3.1.7-1. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.1-20 Amendment No. 276 I

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.2 Verify temperature of sodium pentaborate solution is In accordance with within the limits of Figure 3.1.7-2. the Surveillance Frequency Control Program SR 3.1.7.3 Verify temperature of pump suction and discharge In accordance with piping up to the SLC injection valves is within the limits the Surveillance of Figure 3.1.7-2. Frequency Control Program SR 3.1.7.4 Verify continuity of explosive charge. In accordance with the Surveillance Frequency Control Program SR 3.1.7.5 Verify the concentration of boron in solution is within In accordance with the limits of Figure 3.1. 7-1. the Surveillance Frequency Control Program Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after water or boron is added to solution Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored within the limits of Figure 3.1.7-2 (continued)

Brunswick Unit 1 3.1-21 Amendment No. 276

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each pump develops a flow rate:::: 41.2 gpm at a In accordance with discharge pressure :::: 1190 psig. the lnservice Testing Program SR 3.1.7.7 Verify flow through one SLC subsystem from pump In accordance with into reactor pressure vessel. the Surveillance Frequency Control Program SR 3.1.7.8 Verify sodium pentaborate enrichment is:::: 47 atom Prior to addition to percent 8-10. SLC tank Brunswick Unit 1 3.1-22 Amendment No. 276 I

SDV Vent and Drain Valves 3.1.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1 ---------------------------------N 0 TE-------------------------------

Not required to be met on vent and drain valves closed during performance of SR 3.1.8.2.

Verify each SDV vent and drain valve is open. In accordance with the Surveillance Frequency Control Program SR 3.1.8.2 Cycle each SDV vent and drain valve to the fully In accordance with closed and fully open position. the Surveillance Frequency Control Program SR 3.1.8.3 Verify each SDV vent and drain valve: In accordance with the Surveillance

a. Closes in :-: ; 30 seconds after receipt of an actual Frequency Control or simulated scram signal; and Program

b. Opens when the actual or simulated scram signal is reset.

Brunswick Unit 1 3.1-26 Amendment No. 276 I

APLHGR 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER;::. 23% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any APLHGR not A.1 Restore APLHGR(s) to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months within limits. within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to < 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify all APLHGRs are less than or equal to the limits Once within specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

. 23% RTP In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.2-1 Amendment No. 276

MCPR 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

LCO 3.2.2 All MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR.

APPLICABILITY: THERMAL POWER:? 23% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any MCPR not within A.1 Restore MCPR(s) to within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits. limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify all MCPRs are greater than or equal to the Once within limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

? 23% RTP In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.2-2 Amendment No. 276

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER 2: 23% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within A.1 Restore LHGR(s) to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the limits Once within specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2: 23% RTP In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.2-4 Amendment No. 276

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS

N 0 TES ----------------------------------------------------------

1. Refer to Table 3.3.1.1-1 to determine which SRs apply for each RPS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into assotiated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains RPS trip capability.

SURVEILLANCE FREQUENCY SR 3.3.1.1.1 (Not used.)

SR 3.3.1.1.2 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.3 -----------------------------N 0 TE----------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER~ 23% RTP.

Adjust the average power range monitor (APRM) In accordance with channels to conform to the calculated power while the Surveillance operating at ~ 23% RTP. Frequency Control Program SR 3.3.1.1.4 ---------------------------------N 0 TE------------------------------

N ot required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-4 Amendment No. 276

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.5 Perform a functional test of each automatic scram In accordance with contactor. the Surveillance Frequency Control Program SR 3.3.1.1.6 Verify the source range monitor (SRM) and Prior to withdrawing intermediate range monitor (IRM) channels overlap. SRMs from the fully inserted position SR 3.3.1.1.7 -------------------------------N 0 TE--------------------------------

Only required to be met during entry into MODE 2 from MODE 1.

Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.8 Calibrate the local power range monitors. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.10 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-5 Amendment No. 276

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.11 --------------------------------N 0 TE S------------------------------

1. For Function 2.a, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

2. For Functions 2.b and 2.f, the CHANNEL FUNCTIONAL TEST includes the recirculation flow input processing, excluding the flow transmitters.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.12 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.13 -----------------------------------NOTES---------------------------

1. Neutron detectors are excluded.

2. For Function 1, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

3. For Functions 2.b and 2.f, the recirculation flow transmitters that feed the APRMs are included.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.14 (Not used.)

SR 3.3.1.1.15 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-6 Amendment No. 276

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop Valve-Closure and Turbine In accordance with Control Valve Fast Closure, Trip Oil Pressure-Low the Surveillance Functions are not bypassed when THERMAL POWER Frequency Control is ?: 26% RTP. Program SR 3.3.1.1.17 --------------------------------N 0 TES------------------------------

1. Neutron detectors are excluded.

2. For Functions 3 and 4, the sensor response time may be assumed to be the design sensor response time.

Verify the RPS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.18 Adjust recirculation drive flow to conform to reactor Once within 7 days core flow. after reaching equilibrium conditions following refueling outage (continued)

Brunswick Unit 1 3.3-7 Amendment No. 276

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1.1.19 Verify OPRM is not bypassed when APRM Simulated In accordance with Thermal Power is 2 25% and recirculation drive flow is the Surveillance

60%. Frequency Control Program Brunswick Unit 1 3.3-8 Amendment No. 276

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified condition.

SURVEILLANCE FREQUENCY SR 3.3.1.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.2 ------------------------------N 0 TE S--------------------------------

1. Only required to be met during CORE ALTERATIONS.

2. One SRM may be used to satisfy more than one of the following.

Verify an OPERABLE SRM detector is located in: In accordance with the Surveillance

a. The fueled region; Frequency Control Program

b. The core quadrant where CORE AL TERA TIONS are being performed, when the associated SRM is included in the fueled region; and

c. A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM is included in the fuel region.

SR 3.3.1.2.3 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-14 Amendment No. 276

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.2.4 -------------------------------N 0 TE S-------------------------------

1. Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant.

2. Not required to be met during a core spiral offload.

Verify count rate is:'.". 3.0 cps. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.6 ------------------------------N 0 TE----------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-15 Amendment No. 276

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1.2.7 -----------------------------N 0 TES---------------------------------

1. Neutron detectors are excluded.

2. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-16 Amendment No. 276 I

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. One or more Reactor Mode E.1 Suspend control rod Immediately Switch-Shutdown Position withdrawal.

channels inoperable.

E.2 Initiate action to fully insert Immediately all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function.

2. When an RBM channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains control rod block capability.

SURVEILLANCE FREQUENCY SR 3.3.2.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-20 Amendment No. 276

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.2 --------------------------------N0 TE--------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn at~ 8.75% RTP in MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.3 -------------------------------N 0 TE-------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is~ 8.75% RTP in MODE 1.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.4 Verify the RBM: In accordance with the Surveillance

a. Low Power Range-Upscale Function OR Frequency Control Intermediate Power Range-Upscale Function Program OR High Power Range-Upscale Function is enabled (not bypassed) when APRM Simulated Thermal Power is 2 29%.

b. Intermediate Power Range-Upscale Function OR High Power Range-Upscale Function is enabled (not bypassed) when APRM Simulated Thermal Power is 2 Intermediate Power Range Setpoint specified in the COLR.

c. High Power Range-Upscale Function is enabled (not bypassed) when APRM Simulated Thermal Power is 2 High Power Range Setpoint specified in the COLR.

(continued)

Brunswick Unit 1 3.3-21 Amendment No. 276 I

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.5 Verify the RWM is not bypassed when THERMAL In accordance with POWER is s: 8.75% RTP. the Surveillance Frequency Control Program SR 3.3.2.1.6 ------------------------------N 0 TE---------------------------------

N ot required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1. 7 ------------------------------N 0 TE--------------------------------

Ne utro n detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.8 Verify control rod sequences input to the RWM are in Prior to declaring conformance with BPWS. RWM OPERABLE following loading of sequence into RWM Brunswick Unit 1 3.3-22 Amendment No. 276

Feedwater and Main Turbine High Water Level Trip Instrumentation 3.3.2.2 SURVEILLANCE REQUIREMENTS

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided feedwater and main turbine high water level trip capability is maintained.

SURVEILLANCE FREQUENCY SR 3.3.2.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2.2 Perform CHANNEL CALIBRATION. The Allowable In accordance with Value shall be ~ 207 inches. the Surveillance Frequency Control Program SR 3.3.2.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST, In accordance with including valve actuation. the Surveillance Frequency Control Program Brunswick Unit 1 3.3-25 Amendment No. 276

PAM Instrumentation 3.3.3.1 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Enter the Condition Immediately associated Completion Time referenced in of Condition C not met. Table 3.3.3.1-1 for the channel.

E. As required by Required E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by Required F.1 Initiate action in accordance Immediately Action D.1 and referenced in with Specification 5.6.6.

Table 3.3.3.1-1.

SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

These SRs apply to each Function in Table 3.3.3.1-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.3.1.2 (Not Used.)

(continued)

Brunswick Unit 1 3.3-27 Amendment No. 276

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.3.1.3 Perform CHANNEL CALIBRATION for each required In accordance with PAM Instrumentation channel the Surveillance Frequency Control Program Brunswick Unit 1 3.3-28 Amendment No. 276

Remote Shutdown Monitoring Instrumentation 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown Monitoring Instrumentation LCO 3.3.3.2 The Remote Shutdown Monitoring Instrumentation Functions shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

N0 TE -----------------------------------------------------------

Se pa rate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more required A.1 Restore required Function 30 days Functions inoperable. to 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 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required In accordance with instrumentation channel that is normally energized. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-30 Amendment No. 276

Remote Shutdown Monitoring Instrumentation 3.3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.3.2.2 Perform CHANNEL CALIBRATION for each required In accordance with instrumentation channel. the Surveillance Frequency Control Program Brunswick Unit 1 3.3-31 Amendment No. 276

ATWS-RPT Instrumentation 3.3.4.1 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One Function with B.1 Restore A TWS-RPT trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ATWS-RPT trip capability capability.

not maintained.

C. Both Functions with C.1 Restore A TWS-RPT trip 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ATWS-RPT trip capability capability for one Function.

not maintained.

D. Required Action and D.1 Remove the associated 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time recirculation pump(s) from not met. service.

OR D.2 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains ATWS-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3.3.4.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-33 Amendment No. 276

ATWS-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.4 Perform CHANNEL CALIBRATION. The Allowable In accordance with Values shall be: the Surveillance Frequency Control

a. Reactor Vessel Water Level-Low Level 2: Program 2 101 inches; and

b. Reactor Vessel Pressure-High: s 1147 psig.

SR 3.3.4.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST In accordance with including breaker actuation. the Surveillance Frequency Control Program Brunswick Unit 1 3.3-34 Amendment No. 276

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 3.c; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.6 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-40 Amendment No. 276

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1 and 3 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-47 Amendment No. 276

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Functions 2.c, 2.d, 3.a, 3.b, 3.e, 3.f, 3.g, 3.h, 4.a, 4.b, 4.e, 4.f, 4.g, 4.h, 4.i, 4.k, 5.a, 5.b, 5.e, 5.f, and 6.a; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for all other Functions provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-52 Amendment No. 276

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.1.6 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.7 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.8 -------------------------------N 0 TES-------------------------------

1. Radiation detectors are excluded.

2. The sensor response time for Functions 1.a and 1.c may be assumed to be the design sensor response time.

Verify the ISOLATION INSTRUMENTATION In accordance with RESPONSE TIME is within limits. the Surveillance Frequency Control Program SR 3.3.6.1.9 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-53 Amendment No. 276

Secondary Containment Isolation Instrumentation 3.3.6.2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. (continued) C.1.2 Declare associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months secondary containment isolation dampers inoperable.

AND C.2.1 Place the associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months standby gas treatment (SGT) subsystem(s) in operation.

OR C.2.2 Declare associated SGT 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months subsystem(s) inoperable.

SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.6.2-1 to determine which SRs apply for each Secondary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Function 3 and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1 and 2 provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-60 Amendment No. 276

Secondary Containment Isolation Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-61 Amendment No. 276

GREV System Instrumentation 3.3.7.1 SURVEILLANCE REQUIREMENTS

*---------------------------------------------------- N0 TE -----------------------------------------------------------

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains GREV initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.7.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-64 Amendment No. 276

Condenser Vacuum Pump Isolation Instrumentation 3.3.7.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Required Action and B.1 Isolate condenser vacuum 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time pumps.

of Condition A not met.

OR OR B.2 Isolate main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Condenser vacuum pump isolation capability not OR maintained.

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

N0 TE -----------------------------------------------------------

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains condenser vacuum pump isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.7.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2.3 Perform CHANNEL CALIBRATION. The Allowable In accordance with Value shall be:::; 6 x background. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.3-67 Amendment No. 276 I

Condenser Vacuum Pump Isolation Instrumentation 3.3.7.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.7.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST In accordance with including condenser vacuum pump trip breaker and the Surveillance isolation valve actuation. Frequency Control Program Brunswick Unit 1 3.3-68 Amendment No. 276

LOP Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.8.1-1 to determine which SRs apply for each LOP Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided: (a) for Function 1, the associated Functions maintains initiation capability for three DGs; and (b) for Function 2, the associated Function maintains DG initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.8.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.2 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-70 Amendment No. 276

RPS Electric Power Monitoring 3.3.8.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Initiate action to fully insert Immediately associated Completion Time all insertable control rods in of Condition A or B not met core cells containing one or in MODE 3, 4, or 5 with any more fuel assemblies.

control rod withdrawn from a core cell containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.2.1 --------------------------------N 0 TE-------------------------------

0 nly required to be performed prior to entering MODE 2 from MODE 3 or 4, when in MODE 4 for

.2': 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.2 Perform CHANNEL CALIBRATION for each RPS In accordance with motor generator set electric power monitoring the Surveillance assembly. The Allowable Values shall be: Frequency Control Program

a. Overvoltage s 127 V.

b. Undervoltage .2': 107 V.

c. Underfrequency .2': 57.2 Hz.

(continued)

Brunswick Unit 1 3.3-73 Amendment No. 276

RPS Electric Power Monitoring 3.3.8.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.8.2.3 Perform CHANNEL CALIBRATION for each RPS In accordance with alternate power supply electric power monitoring the Surveillance assembly. The Allowable Values shall be: Frequency Control Program

a. Overvoltage :::; 127 V.

b. Undervoltage ~ 107 V.

c. Underfrequency ~ 57.2 Hz.

SR 3.3.8.2.4 Perform a system functional test. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.3-74 Amendment No. 276

Recirculation Loops Operating 3.4.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION 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.

No recirculation loops in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 --------------------------------- N0 TE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both recirculation loops are in operation.

Verify recirculation loop jet pump flow mismatch with In accordance with both recirculation loops in operation: the Surveillance Frequency Control

a. s 10% of rated core flow when operating at Program

< 75% of rated core flow; and

b. s 5% of rated core flow when operating at

2'. 75% of rated core flow.

Brunswick Unit 1 3.4-2 Amendment No. 276

Jet Pumps 3.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 -----------------------------N0 TES--------------------------------

1. Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after associated recirculation loop is in operation.

2. Not required to be performed until~ 25% RTP.

Verify at least one of the following criteria (a orb) is In accordance with satisfied for each operating recirculation loop: the Surveillance Frequency Control

a. Recirculation pump flow to speed ratio differs by Program s 5% from established patterns, and jet pump loop flow to recirculation pump speed ratio differs by s 5% from established patterns.

b. Each jet pump diffuser to lower plenum differential pressure differs by s 10% from that jet pump's established pattern.

Brunswick Unit 1 3.4-4 Amendment No. 276

SRVs 3.4.3 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.3.2 ------------------------------N 0 TE---------------------------------

N ot required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

Verify each required SRV opens when manually In accordance with actuated. the Surveillance Frequency Control Program Brunswick Unit 1 3.4-6 Amendment No. 276

RCS Operational LEAKAGE 3.4.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION 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. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Pressure boundary LEAKAGE exists.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify RCS unidentified and total LEAKAGE and In accordance with unidentified LEAKAGE increase are within limits. the Surveillance Frequency Control Program Brunswick Unit 1 3.4-8 Amendment No. 276

RCS Leakage Detection Instrumentation 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Perform a CHANNEL CHECK of required primary In accordance with containment atmosphere radioactivity monitoring the Surveillance system. Frequency Control Program SR 3.4.5.2 Perform a CHANNEL FUNCTIONAL TEST of required In accordance with leakage detection instrumentation. the Surveillance Frequency Control Program SR 3.4.5.3 Perform a CHANNEL CALIBRATION of required In accordance with leakage detection instrumentation. the Surveillance Frequency Control Program Brunswick Unit 1 3.4-11 Amendment No. 276

RCS Specific Activity 3.4.6 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. (continued) B.2.2.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2.2.2 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 3.4.6.1 --------------------------------N 0 TE------------------------------

0 nly required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 1-131 In accordance with specific activity is : : ; 0.2 µCi/gm. the Surveillance Frequency Control Program Brunswick Unit 1 3.4-13 Amendment No. 276

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 ------------------------------N 0 TE---------------------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR shutdown cooling isolation pressure.

Verify one required RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.7.2 --------------------------------N 0 TE-------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR shutdown cooling isolation pressure.

Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 1 3.4-16 Amendment No. 276

RHR Shutdown Cooling System-Cold Shutdown 3.4.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. No RHR shutdown cooling 8.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsystem in operation. circulating by an alternate discovery of no method. reactor coolant circulation No recirculation pump in operation.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 8.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one required RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 1 3.4-18 Amendment No. 276

RCS P/T Limits 3.4.9 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. ---------------NOTE--------------- C.1 Initiate action to restore Immediately Required Action C.2 shall be parameter(s) to within completed if this Condition is limits.

entered.

AND Requirements of the LCO C.2 Determine RCS is Prior to entering not met in other than acceptable for operation. MODE 2 or 3.

MODES 1, 2, and 3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 -------------------------------N 0 TE--------------------------------

0 n ly required to be performed during RCS heatup and cooldown operations.

Verify: In accordance with the Surveillance

a. RCS pressure and RCS temperature are within Frequency Control the applicable limits specified in Figures 3.4.9-1 Program and 3.4.9-2; and

b. RCS heatup and cooldown rates are :c:: 100°F in any 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

(continued)

Brunswick Unit 1 3.4-20 Amendment No. 276

RCS P/T Limits 3.4.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.9.2 ------------------------------N 0 TE---------------------------------

0 n ly required to be performed during RCS inservice leak and hydrostatic testing.

Verify: In accordance with the Surveillance

a. RCS pressure and RCS temperature are within Frequency Control the applicable limits specified in Figure 3.4.9-3; Program 3.4.9-4, or 3.4.9-5, as applicable.

b. RCS heatup and cooldown rates are :s; 30°F in any 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

SR 3.4.9.3 Verify RCS pressure and RCS temperature are within Once within the criticality limits specified in Figure 3.4.9-2. 15 minutes prior to control rod withdrawal for the purpose of achieving criticality SR 3.4.9.4 -------------------------------N 0 TE--------------------------------

0 n ly required to be met in MODES 1, 2, 3, and 4 during recirculation pump start.

Verify the difference between the bottom head coolant Once within temperature and the reactor pressure vessel (RPV) 30 minutes prior to coolant temperature is~ 145°F. each startup of a recirculation pump (continued)

Brunswick Unit 1 3.4-21 Amendment No. 276

RCS PIT Limits 3.4.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.9.5 ------------------------------N 0 TE---------------------------------

0 n ly required to be met in MODES 1, 2, 3, and 4 during recirculation pump start.

Verify the difference between the reactor coolant Once within temperature in the recirculation loop to be started and 30 minutes prior to the RPV coolant temperature is.,::; 50°F. each startup of a recirculation pump SR 3.4.9.6 ------------------------------N0 TE---------------------------------

0 n ly required to be performed when tensioning the reactor vessel head bolting studs.

Verify reactor vessel flange and head flange In accordance with temperatures are 2 70°F. the Surveillance Frequency Control Program SR 3.4.9.7 ------------------------------N 0 TE---------------------------------

N ot required to be performed until 30 minutes after RCS temperature .,::; 80°F in MODE 4.

Verify reactor vessel flange and head flange In accordance with temperatures are 2 70°F. the Surveillance Frequency Control Program SR 3.4.9.8 ------------------------------N0 TE---------------------------------

No t required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after RCS temperature.,::; 100°F in MODE 4.

Verify reactor vessel flange and head flange In accordance with temperatures are 2 70°F. the Surveillance Frequency Control Program Brunswick Unit 1 3.4-22 Amendment No. 276

Reactor Steam Dome Pressure 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Reactor Steam Dome Pressure LCO 3.4.10 The reactor steam dome pressure shall be :::; 1045 psig.

APPLICABILITY: MODES 1 and 2.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Reactor steam dome A.1 Restore reactor steam 15 minutes pressure not within limit. dome pressure to within limit.

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.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify reactor steam dome pressure is:::; 1045 psig. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.4-28 Amendment No. 276 I

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J. Two or more low pressure J.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, In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program (continued)

Brunswick Unit 1 3.5-4 Amendment No. 276 I

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.2 --------------------------------N0 TES-----------------------------

1. Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) shutdown cooling isolation pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem manual, In accordance with power operated, and automatic valve in the flow path, the Surveillance that is not locked, sealed, or otherwise secured in Frequency Control position, is in the correct position. Program SR 3.5.1.3 Verify ADS pneumatic supply header pressure is In accordance with

95 psig. the Surveillance Frequency Control Program SR 3.5.1.4 Verify the RHR System cross tie valve is locked In accordance with closed. the Surveillance Frequency Control Program SR 3.5.1.5 ---------------------------------N 0 TE-----------------------------

N ot required to be performed if performed within the previous 31 days.

Verify each recirculation pump discharge valve and Once each startup bypass valve cycles through one complete cycle of full prior to exceeding travel or is de-energized in the closed position. 25% RTP (continued)

Brunswick Unit 1 3.5-5 Amendment No. 276 I

EGGS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.6 Verify the following ECCS pumps develop the In accordance with specified flow rate against a system head the Surveillance corresponding to the specified reactor pressure. Frequency Control Program SYSTEM HEAD CORRESPONDING NO. OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF cs ~ 4100 gpm 1 ~ 113 psig LPCI ~ 14,000 gpm 2 ~ 20 psig SR 3.5.1.7 ---------------------------------N0 TE-----------------------------

Not required to be performed until 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after reactor steam pressure is adequate to perform the test.

Verify, with reactor pressure::; 1045 and~ 945 psig, In accordance with the HPCI pump unit can develop a flow rate the Surveillance

~ 4250 gpm against a system head corresponding to Frequency Control reactor pressure. Program SR 3.5.1.8 ---------------------------------N0 TE-----------------------------

Not required to be performed until 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after reactor steam pressure is adequate to perform the test.

Verify, with reactor pressure::; 180 psig, the HPCI In accordance with pump unit can develop a flow rate ~ 4250 gpm against the Surveillance a system head corresponding to reactor pressure. Frequency Control Program (continued)

Brunswick Unit 1 3.5-6 Amendment No. 276 I

EC CS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.9 ---------------------------------N 0 TE-----------------------------

Ves se I injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates In accordance with on an actual or simulated automatic initiation signal. the Surveillance Frequency Control Program SR 3.5.1.10 ---------------------------------N 0 TE-----------------------------

Va Ive actuation may be excluded.

Verify the ADS actuates on an actual or simulated In accordance with automatic initiation signal. the Surveillance Frequency Control Program SR 3.5.1.11 ---------------------------------N0 TE-----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

Verify each required ADS valve opens when manually In accordance with actuated. the Surveillance Frequency Control Program SR 3.5.1.12 ---------------------------------N 0 TE-----------------------------

1nst ru me ntat ion response time may be assumed to be the design instrumentation response time.

Verify the ECCS RESPONSE TIME for each ECCS In accordance with injection/spray subsystem is within the limit. the Surveillance Frequency Control Program Brunswick Unit 1 3.5-7 Amendment No. 276 I

ECCS-Shutdown 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action C.2 and D.1 Initiate action to restore Immediately associated Completion Time secondary containment to not met. OPERABLE status.

D.2 Initiate action to restore one Immediately standby gas treatment subsystem to OPERABLE status.

AND D.3 Initiate action to restore Immediately isolation capability in each required secondary containment penetration flow path not isolated.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water level is the Surveillance

~ -31 inches. Frequency Control Program (continued)

Brunswick Unit 1 3.5-9 Amendment No. 276 I

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required core spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is 2 -31 inches; or Program

b. ----------------------------N 0 TE----------------------------

0 nly one required CS subsystem may take credit for this option during OPDRVs.

Condensate storage tank water volume is 2 228,200 gallons.

SR 3.5.2.3 Verify, for each required ECCS injection/spray In accordance with subsystem, locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program SR 3.5.2.4 -------------------------------N 0 TES------------------------------

1. One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify each required ECCS injection/spray subsystem In accordance with manual, power operated, and automatic valve in the the Surveillance flow path, that is not locked, sealed, or otherwise Frequency Control secured in position, is in the correct position. Program (continued)

Brunswick Unit 1 3.5-10 Amendment No. 276 I

EGGS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the In accordance with specified flow rate against a system head the Surveillance corresponding to the specified reactor pressure. Frequency Control Program SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF cs ;::. 4100 gpm 1 ;::. 113 psig LPCI ;::. 9000 gpm 1 ;::. 20 psig SR 3.5.2.6 -------------------------------N 0 TE--------------------------------

Ves se I injection/spray may be excluded.

Verify each required ECCS injection/spray subsystem In accordance with actuates on an actual or simulated automatic initiation the Surveillance signal. Frequency Control Program SR 3.5.2.7 -------------------------------N 0 TE--------------------------------

1n st rumen tati on response time may be assumed to be the design instrumentation response time.

Verify the ECCS RESPONSE TIME for each required In accordance with ECCS injection/spray subsystem is within the limit. the Surveillance Frequency Control Program Brunswick Unit 1 3.5-11 Amendment No. 276 I

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program SR 3.5.3.2 --------------------------------N 0 TE-------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, In accordance with and automatic valve in the flow path, that is not the Surveillance locked, sealed, or otherwise secured in position, is in Frequency Control the correct position. Program SR 3.5.3.3 --------------------------------N 0 T E--------------------------------

1. Use of auxiliary steam for the performance of the SR is not allowed.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reactor steam pressure is adequate to perform the test.

Verify, with reactor pressure 2 945 psig and~ 1045 In accordance with psig, the RCIC pump can develop a flow rate the Surveillance 2 400 gpm against a system head corresponding to Frequency Control reactor pressure. Program (continued)

Brunswick Unit 1 3.5-13 Amendment No. 276 I

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.4 --------------------------------N 0 TES------------------------------

1. Use of auxiliary steam for the performance of the SR is not allowed with reactor pressure

150 psig.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reactor steam pressure is adequate to perform the test.

Verify, with turbine inlet pressure ;::: 135 psig and :<::: 165 In accordance with psig, the RCIC pump can develop a flow rate the Surveillance

400 gpm against a system head corresponding to an Frequency Control equivalent reactor pressure. Program SR 3.5.3.5 --------------------------------N 0 TE--------------------------------

Ves se I injection may be excluded.

Verify the RCIC System actuates on an actual or In accordance with simulated automatic initiation signal. the Surveillance Frequency Control Program Brunswick Unit 1 3.5-14 Amendment No. 276 I

Primary Containment 3.6.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1.1 Perform required visual examinations and leakage rate In accordance with testing, except for primary containment air lock testing, the Primary in accordance with the Primary Containment Leakage Containment Rate Testing Program. Leakage Rate Testing Program SR 3.6.1.1.2 Verify drywell to suppression chamber differential In accordance with pressure does not decrease at a rate> 0.25 inch water the Surveillance gauge per minute tested over a 1O minute period at an Frequency Control initial differential pressure of~ 1.00 psid and Program

1.25 psid.

Brunswick Unit 1 3.6-2 Amendment No. 276

Primary Containment Air Lock 3.6.1.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME 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 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.2.1 -------------------------------N 0 TE S-------------------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1.

Perform required primary containment air lock leakage In accordance with rate testing in accordance with the Primary the Primary Containment Leakage Rate Testing Program. Containment Leakage Rate Testing Program SR 3.6.1.2.2 Verify only one door in the primary containment air In accordance with lock can be opened at a time. the Surveillance Frequency Control Program Brunswick Unit 1 3.6-6 Amendment No. 276

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 ------------------------------N 0 TES-------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation manual In accordance with valve and blind flange that is located outside primary the Surveillance containment and not locked, sealed, or otherwise Frequency Control secured and is required to be closed during accident Program conditions is closed.

(continued)

Brunswick Unit 1 3.6-11 Amendment No. 276

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.2 ------------------------------N 0 TES-------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual isolation Prior to entering valve and blind flange that is located inside primary MODE 2 or 3 from containment and not locked, sealed, or otherwise MODE 4 if primary secured and is required to be closed during accident containment was conditions, is closed. de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.3 Verify continuity of the traversing incore probe (TIP) In accordance with shear isolation valve explosive charge. the Surveillance Frequency Control Program SR 3.6.1.3.4 Verify the isolation time of each power operated and In accordance each automatic PCIV, except for MSIVs, is within with the lnservice limits. Testing Program SR 3.6.1.3.5 Verify the isolation time of each MSIV is 2 3 seconds In accordance with and ::; 5 seconds. the lnservice Testing Program (continued)

Brunswick Unit 1 3.6-12 Amendment No. 276

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify each automatic PCIV actuates to the isolation In accordance with position on an actual or simulated isolation signal. the Surveillance Frequency Control Program SR 3.6.1.3. 7 Verify a representative sample of reactor In accordance with instrumentation line EFCVs actuate to the isolation the Surveillance position on an actual or simulated instrument line Frequency Control break signal. Program SR 3.6.1.3.8 Remove and test the explosive squib from each shear In accordance with isolation valve of the TIP System. the lnservice Testing Program SR 3.6.1.3.9 Verify leakage rate through each main steam line is In accordance with

c; 100 scfh and the combined leakage rate of all four the Primary main steam lines is :c; 150 scfh when tested at Containment

~ 25 psig. Leakage Rate Testing Program Brunswick Unit 1 3.6-13 Amendment No. 276

Drywell Air Temperature 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Drywell Air Temperature LCO 3.6.1.4 Drywell average air temperature shall be s; 150°F.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Drywell average air A.1 Restore drywell average air 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within limit. temperature to within limit.

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. AND B.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 3.6.1.4.1 Verify drywell average air temperature is within limit. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.6-14 Amendment No. 276

Reactor Building-to-Suppression Chamber Vaccum Breakers 3.6.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.5.1 Verify nitrogen bottle supply pressure of each nitrogen In accordance with backup subsystem is 2 1130 psig. the Surveillance Frequency Control Program SR 3.6.1.5.2 ------------------------------N0 TES-------------------------------

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

2. Not required to be met for vacuum breakers open when performing their intended function.

Verify each vacuum breaker is closed. In accordance with the Surveillance Frequency Control Program SR 3.6.1.5.3 Perform a functional test of each vacuum breaker. In accordance with the Surveillance Frequency Control Program SR 3.6.1.5.4 Verify the full open setpoint of each vacuum breaker is In accordance with

S 0.5 psid. the Surveillance Frequency Control Program SR 3.6.1.5.5 Verify leakage rate of each nitrogen backup In accordance with subsystem is :S 0.65 scfm when tested at an initial the Surveillance nitrogen bottle supply pressure of 2 1130 psig. Frequency Control Program SR 3.6.1.5.6 Verify the Nitrogen Backup System supplies nitrogen In accordance with to the vacuum breakers on an actual or simulated the Surveillance actuation signal. Frequency Control Program Brunswick Unit 1 3.6-17 Amendment No. 276

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 --------------------------------N 0 TE-------------------------------

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

Verify each vacuum breaker is closed. In accordance with the Surveillance Frequency Control Program 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 Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following an operation that causes any of the vacuum breakers to open (continued)

Brunswick Unit 1 3.6-19 Amendment No. 276

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.6.2 Perform a functional test of each required vacuum In accordance with breaker. the Surveillance Frequency Control Program Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after any discharge of steam to the suppression chamber from the SRVs SR 3.6.1.6.3 Verify the full open setpoint of each required vacuum In accordance with breaker is~ 0.5 psid. the Surveillance Frequency Control Program Brunswick Unit 1 3.6-19a Amendment No. 276

Suppression Pool Average Temperature 3.6.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1.1 Verify suppression pool average temperature is within In accordance with the applicable limits. the Surveillance Frequency Control Program 5 minutes when performing testing that adds heat to the suppression pool Brunswick Unit 1 3.6-22 Amendment No. 276

Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT SYSTEMS 3.6.2.2 Suppression Pool Water Level LCO 3.6.2.2 Suppression pool water level shall be 2 -31 inches and:.::; -27 inches.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Suppression pool water A.1 Restore suppression pool 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months level not within limits. water level to within limits.

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. AND B.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 3.6.2.2.1 Verify suppression pool water level is within limits. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.6-23 Amendment No. 276

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling subsystem In accordance with manual, power operated, and automatic valve in the the Surveillance flow path that is not locked, sealed, or otherwise Frequency Control secured in position is in the correct position or can be Program aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance with 2 7700 gpm through the associated heat exchanger the Surveillance while operating in the suppression pool cooling mode. Frequency Control Program SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program Brunswick Unit 1 3.6-25 Amendment No. 276

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Oxygen Concentration LCO 3.6.3.1 The primary containment oxygen concentration shall be< 4.0 volume percent.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to

< 15% RTP.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Primary containment oxygen A.1 Restore oxygen 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months concentration not within concentration to within limit.

limit.

B. Required Action and B.1 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months associated Completion Time POWER to::; 15% RTP.

not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1.1 Verify primary containment oxygen concentration is In accordance with within limits. the Surveillance Frequency Control Program Brunswick Unit 1 3.6-26 Amendment No. 276

Secondary Containment 3.6.4.1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. (continued) C.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment equipment hatches In accordance with are closed and sealed. the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify one secondary containment access door is In accordance with closed in each access opening. the Surveillance Frequency Control Program SR 3.6.4.1.3 Verify each SGT subsystem can maintain ~ 0.25 inch In accordance with of vacuum water gauge in the secondary containment the Surveillance for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a flow rate :<:: 3000 cfm. Frequency Control Program Brunswick Unit 1 3.6-29 Amendment No. 276

SC IDs 3.6.4.2 ACTIONS (continued)

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

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met during movement of recently irradiated fuel assemblies in Suspend movement of Immediately the secondary containment recently irradiated fuel or during OPDRVs. assemblies in the secondary containment.

AND D.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each automatic SCIO is In accordance with within limits. the Surveillance Frequency Control Program SR 3.6.4.2.2 Verify each automatic SCIO actuates to the isolation In accordance with position on an actual or simulated actuation signal. the Surveillance Frequency Control Program Brunswick Unit 1 3.6-32 Amendment No. 276

SGT System 3.6.4.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. Two SGT subsystems E.1 --------------N 0 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 secondary containment.

AND E.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for ~ 15 continuous In accordance with minutes with heaters operating. the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or In accordance with simulated initiation signal. the Surveillance Frequency Control Program Brunswick Unit 1 3.6-35 Amendment No. 276

RHRSW System 3.7.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME 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 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and In accordance with automatic valve in the flow path, that is not locked, the Surveillance sealed, or otherwise secured in position, is in the Frequency Control correct position or can be aligned to the correct Program position.

Brunswick Unit 1 3.7-3 Amendment No. 276

SW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the water level in the SW pump suction bay of In accordance with the intake structure is ~ -6 ft mean sea level. the Surveillance Frequency Control Program SR 3.7.2.2 Verify the water temperature of UHS is s 90.5°F. In accordance with the Surveillance Frequency Control Program SR 3.7.2.3 -------------------------------N 0 TE---------------------------------

1so lati on of flow to individual components does not render SW System inoperable.

Verify each SW System manual, power operated, and In accordance with automatic valve in the flow paths servicing safety the Surveillance related systems or components, that is not locked, Frequency Control sealed, or otherwise secured in position, is in the Program correct position.

SR 3.7.2.4 ------------------------------N0 TES--------------------------------

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

2. Isolation of flow to individual components does not render SW System inoperable.

Verify automatic transfer of each DG cooling water In accordance with supply from the normal SW supply to the alternate SW the Surveillance supply on low DG jacket cooling water supply Frequency Control pressure. Program (continued)

Brunswick Unit 1 3.7-9 Amendment No. 276

SW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.7.2.5 -------------------------------N 0 TE---------------------------------

1so Iati on of flow to individual components does not render SW System inoperable.

Verify each required SW System automatic component In accordance with actuates on an actual or simulated initiation signal. the Surveillance Frequency Control Program Brunswick Unit 1 3.7-10 Amendment No. 276

GREV System 3.7.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. Two GREV subsystems -------------------N 0 TE---------------------

inoperable during movement LCO 3.0.3 is not applicable.

of irradiated fuel assemblies ------------------------------------------------

in the secondary containment, during CORE E.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies OPDRVs. in the secondary containment.

OR AND One or more CREV subsystems inoperable due E.2 Suspend CORE Immediately to an inoperable CRE ALTERATIONS.

boundary during movement of irradiated fuel assemblies AND in the secondary containment, during CORE E.3 Initiate action to suspend Immediately ALTERATIONS, or during OPDRVs.

OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for~ 15 continuous In accordance with minutes. the Surveillance Frequency Control Program SR 3.7.3.2 Perform required CREV filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP (continued)

Brunswick Unit 1 3.7-13 Amendment No. 276

GREV System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Perform required CRE unfiltered air inleakage testing In accordance with in accordance with the Control Room Envelope the Control Room Habitability Program. Envelope Habitability Program SR 3.7.3.4 Verify each GREV subsystem actuates on an actual or In accordance with simulated initiation signal. the Surveillance Frequency Control Program Brunswick Unit 1 3.7-14 Amendment No. 276

Control Room AC System 3.7.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME F. Three control room AC -------------------NOTE---------------------

subsystems inoperable LCO 3.0.3 is not applicable.

during movement of ------------------------------------------------

irradiated fuel assemblies in the secondary containment, F .1 Suspend movement of Immediately during CORE irradiated fuel assemblies in ALTERATIONS, or during the secondary containment.

OPDRVs.

AND F.2 Suspend CORE Immediately ALTERATIONS.

F.3 Initiate actions to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 7.4.1 Verify each control room AC subsystem has the In accordance with capability to remove the assumed heat load. the Surveillance Frequency Control Program Brunswick Unit 1 3.7-17 Amendment No. 276

Main Condenser Offgas 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -------------------------------N 0 TE---------------------------------

Not required to be performed until 31 days after any main steam line not isolated and SJAE in operation.

Verify the gross gamma activity rate of the noble In accordance with gases is s 243,600 µCi/second after decay of the Surveillance 30 minutes. Frequency Control Program Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a 2 50%

increase in the nominal steady state fission gas release after factoring out increases due to changes in THERMAL POWER level Brunswick Unit 1 3.7-19 Amendment No. 276

Main Turbine Bypass System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify one complete cycle of each main turbine bypass In accordance with valve. the Surveillance Frequency Control Program SR 3.7.6.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM RESPONSE In accordance with TIME is within limits. the Surveillance Frequency Control Program Brunswick Unit 1 3.7-21 Amendment No. 276

Spent Fuel Storage Pool Water Level 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Spent Fuel Storage Pool Water Level LCO 3.7.7 The spent fuel storage pool water level shall be::::.: 19 feet 11 inches over the top of irradiated fuel assemblies seated in the spent fuel storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the spent fuel storage pool.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Spent fuel storage pool A.1 -------------N 0 TE--------------

water level not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in the spent fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 7. 7 .1 Verify the spent fuel storage pool water level is In accordance with

.

19 feet 11 inches over the top of irradiated fuel the Surveillance assemblies seated in the spent fuel storage racks. Frequency Control Program Brunswick Unit 1 3.7-22 Amendment No. 276

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 -------------------------------N0 TES-------------------------------

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

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

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

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

Brunswick Unit 1 3.8-7 Amendment No. 276

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------------------N 0 TES-------------------------------

1. DG loadings may include gradual loading.

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

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

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

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

Verify each DG is synchronized and loaded and In accordance with operates for 2 60 minutes at a load 2 2800 kW and the Surveillance

3500 kW. Frequency Control Program SR 3.8.1.4 Verify each engine mounted tank contains 2 150 gal of In accordance with fuel oil. the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance with engine mounted tank. the Surveillance Frequency Control Program SR 3.8.1.6 Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from the day fuel oil storage tank to the engine the Surveillance mounted tank. Frequency Control Program (continued)

Brunswick Unit 1 3.8-8 Amendment No. 276 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.7 -------------------------------N 0 TES-------------------------------

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

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

Verify each DG starts from standby condition and In accordance with achieves, in ::::; 10 seconds, voltage 2 3750 V and the Surveillance frequency 2 58.8 Hz, and after steady state conditions Frequency Control are reached, maintains voltage 2 3750 V and : : ; 4300 V Program and frequency 2 58.8 Hz and ::::; 61.2 Hz.

(continued)

Brunswick Unit 1 3.8-9 Amendment No. 276 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.8 -------------------------------N0 TES-------------------------------

1. SR 3.8.1.8.a shall not be performed in MODE 1 or 2 for the Unit 1 offsite circuits. However, credit may be taken for unplanned events that satisfy this SR.

2. SR 3.8.1.8.a is not required to be met if the unit power supply is from the preferred offsite circuit.

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

Verify: In accordance with the Surveillance

a. Automatic transfer capability of the unit power Frequency Control supply from the normal circuit to the preferred Program offsite circuit; and

b. Manual transfer of the unit power supply from the preferred offsite circuit to the alternate offsite circuit.

(continued)

Brunswick Unit 1 3.8-10 Amendment No. 276 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.9 -------------------------------N 0 TES-------------------------------

1. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 1 and DG 2. However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with the DG synchronized with offsite power, it shall be performed at a power factor::; 0.9.

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

Verify each DG rejects a load greater than or equal to In accordance with its associated core spray pump without tripping. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.8-11 Amendment No. 276 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.10 -------------------------------N0 TE---------------------------------

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

Verify each DG's automatic trips are bypassed on an In accordance with actual or simulated ECCS initiation signal except: the Surveillance Frequency Control

a. Engine overspeed; Program

b. Generator differential overcurrent;

c. Low lube oil pressure;

d. Reverse power;

e. Loss of field; and

f. Phase overcurrent (voltage restrained).

(continued)

Brunswick Unit 1 3.8-12 Amendment No. 276 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 -------------------------------N 0 TES-------------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

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

Verify each DG operating at a power factor :c; 0.9 In accordance with operates for ~ 60 minutes loaded to ~ 3500 kW and the Surveillance

c; 3850 kW. Frequency Control Program SR 3.8.1.12 -------------------------------N 0 TE---------------------------------

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

Verify an actual or simulated ECCS initiation signal is In accordance with capable of overriding the test mode feature to return the Surveillance each DG to ready-to-load operation. Frequency Control Program (continued)

Brunswick Unit 1 3.8-13 Amendment No. 276 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 -------------------------------N 0 TE---------------------------------

T his Surveillance shall not be performed in MODE 1, 2, or 3 for the load sequence relays associated with DG 1 and DG 2. However, credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load block is In accordance with within +/- 10% of design interval for each load sequence the Surveillance relay. Frequency Control Program (continued)

Brunswick Unit 1 3.8-14 Amendment No. 276

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.14 -------------------------------N 0 TES-------------------------------

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

2. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 1 and DG 2. However, credit may be taken for unplanned events that satisfy this SR.

Verify, on actual or simulated loss of offsite power In accordance with signal in conjunction with an actual or simulated ECCS the Surveillance initiation signal: Frequency Control Program

a. De-energization of emergency buses;

b. Load shedding from emergency buses; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in

10.5 seconds,

2. energizes auto-connected emergency loads through load sequence relays,

3. maintains steady state voltage::'.'. 3750 V and:::: 4300 V,

4. maintains steady state frequency::'.'. 58.8 Hz and :::: 61.2 Hz, and

5. supplies permanently connected and auto-connected emergency loads for

'.'. 5 minutes.

Brunswick Unit 1 3.8-15 Amendment No. 276

Diesel Fuel Oil 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 For each required DG, verify: In accordance with the Surveillance

a. The associated day fuel oil storage tank Frequency Control contains ~ 22,650 gal; and Program

b. The main fuel oil storage tank contains ~ 20,850 gal per required DG.

SR 3.8.3.2 Verify fuel oil properties of stored fuel oil are tested in In accordance with accordance with, and maintained within the limits of, the Diesel Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.3 Check for and remove accumulated water from each In accordance with day fuel oil tank and the main fuel oil storage tank. the Surveillance Frequency Control Program Brunswick Unit 1 3.8-22 Amendment No. 276 I

DC Sources-Operating 3.8.4 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. AND B.2 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 inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ?: 130 V on float In accordance with charge. the Surveillance Frequency Control Program SR 3.8.4.2 Verify no visible corrosion at battery terminals and In accordance with connectors. the Surveillance Frequency Control Program 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 In accordance with visual indication of physical damage or abnormal the Surveillance deterioration that degrades performance. Frequency Control Program (continued)

Brunswick Unit 1 3.8-24 Amendment No. 276 I

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery cell to cell In accordance with and terminal connections are coated with the Surveillance anti-corrosion material. Frequency Control Program SR 3.8.4.5 Verify each required battery charger supplies In accordance with 2 250 amps at 2 135 V for 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . the Surveillance Frequency Control Program SR 3.8.4.6 -------------------------------N 0 TES-------------------------------

1. The modified performance discharge test in SR 3.8.4.7 may be performed in lieu of the service test in SR 3.8.4.6 once per 60 months.

2. This Surveillance shall not be performed in MODE 1 or 2 for the Unit 1 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR.

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

Verify battery capacity is adequate to supply, and In accordance with maintain in OPERABLE status, the required the Surveillance emergency loads for the design duty cycle when Frequency Control subjected to a battery service test. Program (continued)

Brunswick Unit 1 3.8-25 Amendment No. 276 I

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.7 -------------------------------N 0 TES-------------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 for the Unit 1 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR.

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

Verify battery capacity is ~ 80% of the manufacturer's In accordance with rating when subjected to a performance discharge test the Surveillance or a modified performance discharge test. Frequency Control Program 12 months when battery shows degradation or has reached 85% of the expected life with capacity < 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity ~ 100% of manufacturer's rating Brunswick Unit 1 3.8-26 Amendment No. 276

Battery Cell Parameters 3.8.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B limits of Table 3.8.6-1.

B. Required Action and B.1 Declare associated battery Immediately associated Completion Time inoperable.

of Condition A not met.

OR One or more batteries with average electrolyte temperature of the representative cells not within limits.

OR One or more batteries with one or more battery cell parameters not within Category C limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 In accordance with Category A limits. the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.8-31 Amendment No. 276 I

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 In accordance with Category B limits. the Surveillance Frequency Control Program SR 3.8.6.3 Verify average electrolyte temperature of In accordance with representative cells is 2 60°F. the Surveillance Frequency Control Program Brunswick Unit 1 3.8-32 Amendment No. 276 I

Distribution Systems-Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and indicated power In accordance with availability to required AC and DC electrical power the Surveillance distribution subsystems. Frequency Control Program SR 3.8.7.2 Verify no combination of more than two power In accordance with conversion modules (consisting of either two lighting the Surveillance inverters or one lighting inverter and one plant Frequency Control uninterruptible power supply unit) are aligned to Program Division II bus B.

Brunswick Unit 1 3.8-37 Amendment No. 276 I

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to suspend Immediately operations with a potential for draining the reactor vessel.

AND A.2.4 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status.

AND A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and indicated power In accordance with availability to required AC and DC electrical power the Surveillance distribution subsystems. Frequency Control Program Brunswick Unit 1 3.8-39 Amendment No. 276 I

Refueling Equipment Interlocks 3.9.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Perform CHANNEL FUNCTIONAL TEST on each of In accordance with the following required refueling equipment interlock the Surveillance inputs: Frequency Control Program

a. All-rods-in,

b. Refuel platform position,

c. Refuel platform fuel grapple, fuel loaded,

d. Fuel grapple position,

e. Refuel platform frame-mounted hoist, fuel loaded, and

f. Refuel platform monorail hoist, fuel loaded.

Brunswick Unit 1 3.9-2 Amendment No. 276 I

Refuel Position One-Rod-Out Interlock 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Refuel Position One-Rod-Out Interlock LCO 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE.

APPLICABILITY: MODE 5 with the reactor mode switch in the refuel position and any control rod withdrawn.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refuel position one-rod-out A.1 Suspend control rod Immediately interlock inoperable. withdrawal.

A.2 Initiate action to fully insert Immediately all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Verify reactor mode switch locked in Refuel position. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.9-3 Amendment No. 276 I

Refuel Position One-Rod-Out Interlock 3.9.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.9.2.2 ---------------------------------N 0 TE-------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.9-4 Amendment No. 276 I

Control Rod Position 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Control Rod Position LCO 3.9.3 All control rods shall be fully inserted.

APPLICABILITY: When loading fuel assemblies into the core.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more control rods A.1 Suspend loading fuel Immediately not fully inserted. assemblies into the core.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify all control rods are fully inserted. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.9-5 Amendment No. 276 I

Control Rod OPERABILITY-Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY-Refueling LCO 3.9.5 Each withdrawn control rod shall be OPERABLE.

APPLICABILITY: MODE 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more withdrawn A.1 Initiate action to fully insert Immediately control rods inoperable. inoperable withdrawn control rods.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 ---------------------------------N 0 TE-------------------------------

Not required to be performed until 7 days after the control rod is withdrawn.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SR 3.9.5.2 Verify each withdrawn control rod scram accumulator In accordance with pressure is ;:: 940 psig. the Surveillance Frequency Control Program Brunswick Unit 1 3.9-8 Amendment No. 276 I

RPV Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level LCO 3.9.6 RPV water level shall be~ 23 ft above the top of irradiated fuel assemblies seated within the RPV.

APPLICABILITY: During movement of irradiated fuel assemblies within the RPV, During movement of new fuel assemblies or handling of control rods within the RPV, when irradiated fuel assemblies are seated within the RPV.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not within A.1 Suspend movement of fuel Immediately limit. assemblies and handling of control rods within the RPV.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify RPV water level is~ 23 ft above the top of In accordance with irradiated fuel assemblies seated within the RPV. the Surveillance Frequency Control Program Brunswick Unit 1 3.9-9 Amendment No. 276 I

RHR-High Water Level 3.9.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is In accordance with operating. the Surveillance Frequency Control Program SR 3.9.7.2 Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program Brunswick Unit 1 3.9-12 Amendment No. 276 I

RHR-Low Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is In accordance with operating. the Surveillance Frequency Control Program SR 3.9.8.2 Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 1 3.9-15 Amendment No. 276 I

Reactor Mode Switch Interlock Testing 3.10.2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.3.1 Place the reactor mode 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months switch in the shutdown position.

OR A. 3. 2 -------------N 0 TE--------------

On ly applicable in MODE 5.

Place the reactor mode 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months switch in the refuel position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.2.1 Verify all control rods are fully inserted in core cells In accordance with containing one or more fuel assemblies. the Surveillance Frequency Control Program SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.10-5 Amendment No. 276 I

Single Control Rod Withdrawal-Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.3.1 Perform the applicable SRs for the required LCOs. According to the applicable SRs SR 3.10.3.2 -----------------------------N 0 TE-----------------------------------

Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.10.3.d.1 requirements.

Verify all control rods, other than the control rod being In accordance with withdrawn, in a five by five array centered on the the Surveillance control rod being withdrawn, are disarmed. Frequency Control Program SR 3.10.3.3 Verify all control rods, other than the control rod being In accordance with withdrawn, are fully inserted. the Surveillance Frequency Control Program Brunswick Unit 1 3.10-8 Amendment No. 276 I

Single Control Rod Withdrawal-Cold Shutdown 3.10.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One or more of the above 8.1 Suspend withdrawal of the Immediately requirements not met with control rod and removal of the affected control rod not associated CRD.

insertable.

8.2.1 Initiate action to fully insert Immediately all control rods.

8.2.2 Initiate action to satisfy the Immediately requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.4.1 Perform the applicable SRs for the required LCOs. According to the applicable SRs SR 3.10.4.2 -----------------------------N 0 TE-----------------------------------

Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.c.1 requirements.

Verify all control rods, other than the control rod being In accordance with withdrawn, in a five by five array centered on the the Surveillance control rod being withdrawn, are disarmed. Frequency Control Program (continued)

Brunswick Unit 1 3.10-11 Amendment No. 276

Single Control Rod Withdrawal-Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.4.3 Verify all control rods, other than the control rod being In accordance with withdrawn, are fully inserted. the Surveillance Frequency Control Program SR 3.10.4.4 -----------------------------N 0 TE-----------------------------------

Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.b.1 requirements.

Verify a control rod withdrawal block is inserted. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.10-12 Amendment No. 276 I

Single CRD Removal-Refueling 3.10.5 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2.1 Initiate action to fully insert Immediately all control rods.

A.2.2 Initiate action to satisfy the Immediately requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.5.1 Verify all control rods, other than the control rod In accordance with withdrawn for the removal of the associated CRD, are the Surveillance fully inserted. Frequency Control Program SR 3.10.5.2 Verify all control rods, other than the control rod In accordance with withdrawn for the removal of the associated CRD, in a the Surveillance five by five array centered on the control rod withdrawn Frequency Control for the removal of the associated CRD, are disarmed. Program SR 3.10.5.3 Verify a control rod withdrawal block is inserted. In accordance with the Surveillance Frequency Control Program SR 3.10.5.4 Perform SR 3.1.1.1. According to SR 3.1.1.1 (continued)

Brunswick Unit 1 3.10-14 Amendment No. 276 I

Single CRD Removal-Refueling 3.10.5 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.10.5.5 Verify no other CORE AL TE RATIONS are in progress. In accordance with the Surveillance Frequency Control Program Brunswick Unit 1 3.10-15 Amendment No. 276 I

Multiple Control Rod Withdrawal-Refueling 3.10.6 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.3.1 Initiate action to fully insert Immediately all control rods in core cells containing one or more fuel assemblies.

A.3.2 Initiate action to satisfy the Immediately requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.6.1 Verify the four fuel assemblies are removed from core In accordance with cells associated with each control rod or CRD the Surveillance removed. Frequency Control Program SR 3.10.6.2 Verify all other control rods in core cells containing one In accordance with or more fuel assemblies are fully inserted. the Surveillance Frequency Control Program SR 3.10.6.3 -----------------------------N0 TE-----------------------------------

0 nly required to be met during fuel loading.

Verify fuel assemblies being loaded are in compliance In accordance with with an approved spiral reload sequence. the Surveillance Frequency Control Program Brunswick Unit 1 3.10-17 Amendment No. 276 I

SOM Test-Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.2 -----------------------------N 0 TE-----------------------------------

N ot required to be met if SR 3.10.8.3 satisfied.

Perform the MODE 2 applicable SRs for LCO 3.3.2.1, According to the Function 2 of Table 3.3.2.1-1. applicable SRs SR 3.10.8.3 -----------------------------N 0 T E-----------------------------------

N ot required to be met if SR 3.10.8.2 satisfied.

Verify movement of control rods is in compliance with During control rod the approved control rod sequence for the SOM test by movement a second licensed operator or other qualified member of the technical staff.

SR 3.10.8.4 Verify no other CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 1 3.10-22 Amendment No. 276 I

SOM Test-Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.5 Verify each withdrawn control rod does not go to the Each time the withdrawn overtravel position. control rod is withdrawn to "full out" position Prior to satisfying LCO 3.10.8.c requirement after work on control rod or CRD System that could affect coupling SR 3.10.8.6 Verify CRD charging water header pressure :;::: 940 In accordance with psig. the Surveillance Frequency Control Program Brunswick Unit 1 3.10-23 Amendment No. 276 I

Programs and Manuals 5.5 5.5 Programs and Manuals Control Room Envelope Habitability Program (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

Brunswick Unit 1 5.0-17a Amendment No. 276 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 304 Renewed License No. DPR-62

1. The Nuclear Regulatory Commission (the Commission) has found that:

A The application for amendment filed by Duke Energy Progress, LLC, dated December 21, 2015, as supplemented by letters dated June 29, July 13, August 15, November 1, November 17, 2016, and February 27, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-62 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 304, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: May 2 4 , 2o1 7

ATTACHMENT TO LICENSE AMENDMENT NO. 304 BRUNSWICK STEAM ELECTRIC PLANT. UNIT 2 FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace Page 6 of Renewed Facility Operating License No. DPR-62 with the attached Page 6.

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3.1-6 3.1-6 3.1-10 3.1-10 3.1-13 3.1-13 3.1-17 3.1-17 3.1-19 3.1-19 3.1-20 3.1-20 3.1-21 3.1-21 3.1-22 3.1-22 3.1-26 3.1-26 3.2-1 3.2-1 3.2-2 3.2-2 3.2-4 3.2-4 3.3-4 3.3-4 3.3-5 3.3-5 3.3-6 3.3-6 3.3-7 3.3-7 3.3-8 3.3-8 3.3-14 3.3-14 3.3-15 3.3-15 3.3-16 3.3-16

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(c) Transition License Conditions

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

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

3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 1801h day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

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

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

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 304, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 304

Reactivity Anomalies 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify core reactivity difference between the monitored Once within core ke11 and the predicted core ke11 is within +/- 1% Llk/k. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching equilibrium conditions following startup after fuel movement within the reactor pressure vessel or control rod replacement In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.1-6 Amendment No. 304 I

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program SR 3.1.3.2 ----------------------------N 0 TE-----------------------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SR 3.1.3.3 Verify each control rod scram time from fully withdrawn In accordance with to notch position 06 is :::: 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 (continued)

Brunswick Unit 2 3.1-10 Amendment No. 304 I

Control Rod Scram Times 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify, for a representative sample, each tested control In accordance with rod scram time is within the limits of Table 3.1.4-1 with the Surveillance reactor steam dome pressure 2 800 psig. Frequency Control Program SR 3.1.4.3 Verify each affected control rod scram time is within Prior to declaring the limits of Table 3.1.4-1 with any reactor steam dome control rod pressure. OPERABLE after work on control rod or CRD System that could affect scram time SR 3.1.4.4 Verify each affected control rod scram time is within Prior to exceeding the limits of Table 3.1.4-1 with reactor steam dome 40% RTP after fuel pressure 2 800 psig. movement within the affected core cell Prior to exceeding 40% RTP after work on control rod or CRD System that could affect scram time Brunswick Unit 2 3.1-13 Amendment No. 304 I

Control Rod Scram Accumulators 3.1.5 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. One or more control rod C.1 Verify all control rods Immediately upon scram accumulators associated with inoperable discovery of inoperable with reactor accumulators are fully charging water steam dome pressure inserted. header pressure

< 950 psig. < 940 psig AND C.2 Declare the associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months control rod inoperable.

D. Required Action B.1 or C.1 D.1 -------------N 0 TE--------------

and associated Completion Not applicable if all Time not met. inoperable control rod scram accumulators are associated with fully inserted control rods.

Manually scram the reactor. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each control rod scram accumulator pressure is In accordance with

2'. 940 psig. the Surveillance Frequency Control Program Brunswick Unit 2 3.1-17 Amendment No. 304 I

Rod Pattern Control 3.1.6 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Nine or more OPERABLE B.1 -------------N 0 TE--------------

control rods not in Co ntro I rod may be compliance with BPWS. bypassed in the RWM or RWM may be bypassed as allowed by LCO 3.3.2.1.

Suspend withdrawal of Immediately control rods.

B.2 Manually scram the reactor. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply with BPWS. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.1-19 Amendment No. 304 I

SLC System 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SLC subsystem A.1 Restore SLC subsystem to 7 days inoperable. OPERABLE status.

B. Two SLC subsystems B.1 Restore one SLC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable. 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 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify available volume of sodium pentaborate solution In accordance with is within the limits of Figure 3.1. 7-1. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.1-20 Amendment No. 304 I

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.2 Verify temperature of sodium pentaborate solution is In accordance with within the limits of Figure 3.1.7-2. the Surveillance Frequency Control Program SR 3.1.7.3 Verify temperature of pump suction and discharge In accordance with piping up to the SLC injection valves is within the limits the Surveillance of Figure 3.1.7-2. Frequency Control Program SR 3.1.7.4 Verify continuity of explosive charge. In accordance with the Surveillance Frequency Control Program SR 3.1.7.5 Verify the concentration of boron in solution is within In accordance with the limits of Figure 3.1. 7-1. the Surveillance Frequency Control Program Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after water or boron is added to solution Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored within the limits of Figure 3.1.7-2 (continued)

Brunswick Unit 2 3.1-21 Amendment No. 304 I

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each pump develops a flow rate z 41.2 gpm at a In accordance with discharge pressure z 1190 psig. the lnservice Testing Program SR 3.1. 7 .7 Verify flow through one SLC subsystem from pump In accordance with into reactor pressure vessel. the Surveillance Frequency Control Program SR 3.1.7.8 Verify sodium pentaborate enrichment is;:: 47 atom Prior to addition to percent B-10. SLC tank Brunswick Unit 2 3.1-22 Amendment No. 304 I

SDV Vent and Drain Valves 3.1.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1 --------------------------------N 0 TE--------------------------------

Not required to be met on vent and drain valves closed during performance of SR 3.1.8.2.

Verify each SDV vent and drain valve is open. In accordance with the Surveillance Frequency Control Program SR 3.1.8.2 Cycle each SDV vent and drain valve to the fully In accordance with closed and fully open position. the Surveillance Frequency Control Program SR 3.1.8.3 Verify each SDV vent and drain valve: In accordance with the Surveillance

a. Closes in '.': : 30 seconds after receipt of an actual Frequency Control or simulated scram signal; and Program

b. Opens when the actual or simulated scram signal is reset.

Brunswick Unit 2 3.1-26 Amendment No. 304 I

APLHGR 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER z 23% RTP.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Any APLHGR not within A.1 Restore APLHGR(s) to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion Time POWER to < 23% RTP.

not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify all APLHGRs are less than or equal to the limits Once within specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after z 23% RTP In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.2-1 Amendment No. 304 I

MCPR 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

LCO 3.2.2 All MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR.

APPLICABILITY: THERMAL POWER:::". 23% RTP.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Any MCPR not within A.1 Restore MCPR(s) to within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits. limits.

B. Required Action and B.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify all MCPRs are greater than or equal to the limits Once within specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

:". 23% RTP In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.2-2 Amendment No. 304 I

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER 2 23% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within A.1 Restore LHGR(s) to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits. within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 23% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the limits Once within specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 23% RTP In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.2-4 Amendment No. 304 I

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.1.1-1 to determine which SRs apply for each RPS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains RPS trip capability.

SURVEILLANCE FREQUENCY SR 3.3.1.1.1 (Not used.)

SR 3.3.1.1.2 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.3 --------------------------------N 0 TE--------------------------------

No t required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER 2 23% RTP.

Adjust the average power range monitor (APRM) In accordance with channels to conform to the calculated power while the Surveillance operating at ::> 23% RTP. Frequency Control Program SR 3.3.1 .1.4 --------------------------------N 0 TE--------------------------------

Not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-4 Amendment No. 304 I

RPS Instrumentation 3.3.1.1 s URVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.5 Perform a functional test of each automatic scram In accordance with contactor. the Surveillance Frequency Control Program SR 3.3.1.1.6 Verify the source range monitor (SRM) and Prior to withdrawing intermediate range monitor (IRM) channels overlap. SRMs from the fully inserted position SR 3.3.1.1.7 --------------------------------N 0 TE--------------------------------

Only required to be met during entry into MODE 2 from MODE 1.

Verify the IRM and APRM channels overlap. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.8 Calibrate the local power range monitors. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.10 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-5 Amendment No. 304 I

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.11 --------------------------------N 0 TES------------------------------

1. For Function 2.a, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

2. For Functions 2.b and 2.f, the CHANNEL FUNCTIONAL TEST includes the recirculation flow input processing, excluding the flow transmitters.

In accordance with Perform CHANNEL FUNCTIONAL TEST.

the Surveillance Frequency Control Program In accordance with SR 3.3.1.1.12 Perform CHANNEL FUNCTIONAL TEST.

the Surveillance Frequency Control Program SR 3.3.1.1.13 --------------------------------NOTES------------------------------

1. Neutron detectors are excluded.

2. For Function 1, not required to be performed when entering MODE 2 from MODE 1 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2.

3. For Functions 2.b and 2.f, the recirculation flow transmitters that feed the APRMs are included.

In accordance with Perform CHANNEL CALIBRATION.

the Surveillance Frequency Control Program SR 3.3.1.1.14 (Not used.)

In accordance with SR 3.3.1.1.15 Perform LOGIC SYSTEM FUNCTIONAL TEST.

the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-6 Amendment No. 304

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop Valve-Closure and Turbine In accordance with Control Valve Fast Closure, Trip Oil Pressure-Low the Surveillance Functions are not bypassed when THERMAL Frequency Control POWER is ::;. 26% RTP. Program SR 3.3.1.1.17 --------------------------------N 0 TES----------------------------

1. Neutron detectors are excluded.

2. For Functions 3 and 4, the sensor response time may be assumed to be the design sensor response time.

Verify the RPS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.18 Adjust the flow control trip reference card to conform Once within 7 days to reactor flow. after reaching equilibrium conditions following refueling outage (continued)

Brunswick Unit 2 3.3-7 Amendment No. 304 I

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1.1.19 Verify OPRM is not bypassed when APRM Simulated In accordance with Thermal Power is : '.'. 25% and recirculation drive flow is the Surveillance

S60%. Frequency Control Program Brunswick Unit 2 3.3-8 Amendment No. 304 I

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

Refer to Table 3.3.1.2-1 to determine which SRs apply for each applicable MODE or other specified condition.

SURVEILLANCE FREQUENCY SR 3.3.1.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.2 --------------------------------N0 TES-----------------------------

1. Only required to be met during CORE ALTERATIONS.

2. One SRM may be used to satisfy more than one of the following.

Verify an OPERABLE SRM detector is located in: In accordance with the Surveillance

a. The fueled region; Frequency Control Program

b. The core quadrant where CORE AL TERA TIONS are being performed, when the associated SRM is included in the fueled region; and

c. A core quadrant adjacent to where CORE ALTERATIONS are being performed, when the associated SRM is included in the fueled region.

SR 3.3.1.2.3 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-14 Amendment No. 304 I

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.2.4 --------------------------------N 0 TES-----------------------------

1. Not required to be met with less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies in the associated core quadrant.

2. Not required to be met during a core spiral offload.

Verify count rate is?: 3.0 cps. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2.6 --------------------------------N 0 TE-------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-15 Amendment No. 304 I

SRM Instrumentation 3.3.1.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.1.2.7 --------------------------------N 0 TES-----------------------------

1. Neutron detectors are excluded.

2. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs on Range 2 or below.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-16 Amendment No. 304 I

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. One or more Reactor Mode E.1 Suspend control rod Immediately Switch-Shutdown Position withdrawal.

channels inoperable.

E.2 Initiate action to fully insert Immediately all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function.

2. When an RBM channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains control rod block capability.

SURVEILLANCE FREQUENCY SR 3.3.2.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-20 Amendment No. 304 I

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.2 --------------------------------N 0 TE-------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn at::; 8.75% RTP in MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.3 -------------------------------N0 TE--------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is::; 8.75% RTP in MODE 1.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.4 Verify the RBM: In accordance with the Surveillance

a. Low Power Range-Upscale Function OR Frequency Control Intermediate Power Range-Upscale Function Program OR High Power Range-Upscale Function is enabled (not bypassed) when APRM Simulated Thermal Power is~ 29%.

b. Intermediate Power Range-Upscale Function OR High Power Range-Upscale Function is enabled (not bypassed) when APRM Simulated Thermal Power is~ Intermediate Power Range Setpoint specified in the COLR.

c. High Power Range-Upscale Function is enabled (not bypassed) when APRM Simulated Thermal Power is ~ High Power Range Setpoint specified in the COLR.

(continued)

Brunswick Unit 2 3.3-21 Amendment No. 304 I

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.5 Verify the RWM is not bypassed when THERMAL In accordance with POWER is~ 8.75% RTP. the Surveillance Frequency Control Program SR 3.3.2.1.6 --------------------------------N 0 TE-------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.7 --------------------------------N 0 TE-------------------------------

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.8 Verify control rod sequences input to the RWM are in Prior to declaring conformance with BPWS. RWM OPERABLE following loading of sequence into RWM Brunswick Unit 2 3.3-22 Amendment No. 304 I

Feedwater and Main Turbine High Water Level Trip Instrumentation 3.3.2.2 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided feedwater and main turbine high water level trip capability is maintained.

SURVEILLANCE FREQUENCY SR 3.3.2.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2.2 Perform CHANNEL CALIBRATION. The Allowable In accordance with Value shall be .::: 207 inches. the Surveillance Frequency Control Program SR 3.3.2.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST, In accordance with including valve actuation. the Surveillance Frequency Control Program Brunswick Unit 2 3.3-25 Amendment No. 304 I

PAM Instrumentation 3.3.3.1 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Enter the Condition Immediately associated Completion Time referenced in of Condition C not met. Table 3.3.3.1-1 for the channel.

E. As required by Required E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by Required F.1 Initiate action in accordance Immediately Action D.1 and referenced in with Specification 5.6.6.

Table 3.3.3.1-1.

SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.3.1-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.3.1.2 (Not Used.)

(continued)

Brunswick Unit 2 3.3-27 Amendment No. 304 I

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.3.1.3 Perform CHANNEL CALIBRATION for each required In accordance with PAM Instrumentation channel. the Surveillance Frequency Control Program Brunswick Unit 2 3.3-28 Amendment No. 304 I

Remote Shutdown Monitoring Instrumentation 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown Monitoring Instrumentation LCO 3.3.3.2 The Remote Shutdown Monitoring Instrumentation Functions shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

N0 TE -----------------------------------------------------------

Se pa rate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more required A.1 Restore required Function 30 days Functions inoperable. to 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 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required In accordance with instrumentation channel that is normally energized. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-30 Amendment No. 304 I

Remote Shutdown Monitoring Instrumentation 3.3.3.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.3.2.2 Perform CHANNEL CALIBRATION for each required In accordance with instrumentation channel. the Surveillance Frequency Control Program Brunswick Unit 2 3.3-31 Amendment No. 304 I

A TWS-RPT Instrumentation 3.3.4.1 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One Function with B.1 Restore ATWS-RPT trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months A TWS-RPT trip capability capability.

not maintained.

C. Both Functions with C.1 Restore ATWS-RPT trip 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ATWS-RPT trip capability capability for one Function.

not maintained.

D. Required Action and D.1 Remove the associated 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time recirculation pump(s) from not met. service.

OR D.2 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains ATWS-RPT trip capability.

SURVEILLANCE FREQUENCY SR 3.3.4.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-33 Amendment No. 304 I

A TWS-RPT Instrumentation 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.4.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.4.1.4 Perform CHANNEL CALIBRATION. The Allowable In accordance with Values shall be: the Surveillance Frequency Control

a. Reactor Vessel Water Level-Low Level 2: Program 2 101 inches; and

b. Reactor Vessel Pressure-High:~ 1147 psig.

SR 3.3.4.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST In accordance with including breaker actuation. the Surveillance Frequency Control Program Brunswick Unit 2 3.3-34 Amendment No. 304 I

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 3.c; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.6 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-40 Amendment No. 304 I

RCIC System Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.5.2-1 to determine which SRs apply for each RCIC Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1 and 3 provided the associated Function maintains RCIC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Calibrate the trip units. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-47 Amendment No. 304 I

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

N0 TES -----------------------------------------------*----------

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Functions 2.c, 2.d, 3.a, 3.b, 3.e, 3.f, 3.g, 3.h, 4.a, 4.b, 4.e, 4.f, 4.g, 4.h, 4.i, 4.k, 5.a, 5.b, 5.e, 5.f, and 6.a; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for all other Functions provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.5 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-52 Amendment No. 304 I

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.1.6 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.7 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.8 ----------------------------------N 0 TE S----------------------------

1. Radiation detectors are excluded.

2. The sensor response time for Functions 1.a, 1.c, and 1.f may be assumed to be the design sensor response time.

Verify the ISOLATION INSTRUMENTATION In accordance with RESPONSE TIME is within limits. the Surveillance Frequency Control Program SR 3.3.6.1.9 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-53 Amendment No. 304 I

Secondary Containment Isolation Instrumentation 3.3.6.2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. (continued) C.1.2 Declare associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months secondary containment isolation dampers inoperable.

AND C.2.1 Place the associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months standby gas treatment (SGT) subsystem(s) in operation.

OR C.2.2 Declare associated SGT 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months subsystem(s) inoperable.

SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.6.2-1 to determine which SRs apply for each Secondary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Function 3 and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1 and 2 provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-60 Amendment No. 304 I

Secondary Containment Isolation Instrumentation 3.3.6.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-61 Amendment No. 304 I

GREV System Instrumentation 3.3.7.1 SURVEILLANCE REQUIREMENTS

N0 TE -----------------------------------------------------------

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains GREV initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.7.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program

SR 3.3.7.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.7.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-64 Amendment No. 304 I

Condenser Vacuum Pump Isolation Instrumentation 3.3.7.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Required Action and B.1 Isolate condenser vacuum 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time pumps.

of Condition A not met.

OR OR B.2 Isolate main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Condenser vacuum pump isolation capability not OR maintained.

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

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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains condenser vacuum pump isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.7.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2.3 Perform CHANNEL CALIBRATION. The Allowable In accordance with Value shall be '.".'. 6 x background. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.3-67 Amendment No. 304 I

Condenser Vacuum Pump Isolation Instrumentation 3.3.7.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.3.7.2.4 Perform LOGIC SYSTEM FUNCTIONAL TEST In accordance with including condenser vacuum pump trip breaker and the Surveillance isolation valve actuation. Frequency Control Program Brunswick Unit 2 3.3-68 Amendment No. 304 I

LOP Instrumentation 3.3.8.1 SURVEILLANCE REQUIREMENTS

N0 TES ----------------------------------------------------------

1. Refer to Table 3.3.8.1-1 to determine which SRs apply for each LOP Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided: (a) for Function 1, the associated Functions maintains initiation capability for three DGs; and (b) for Function 2, the associated Function maintains DG initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.8.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.2 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.3 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.8.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-70 Amendment No. 304 I

RPS Electric Power Monitoring 3.3.8.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Initiate action to fully insert Immediately associated Completion Time all insertable control rods of Condition A or B not met in core cells containing in MODE 3, 4, or 5 with any one or more fuel control rod withdrawn from a assemblies.

core cell containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.2.1 -------------------------------N 0 TE--------------------------------

0 n ly required to be performed prior to entering MODE 2 from MODE 3 or 4, when in MODE 4 for 2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.8.2.2 Perform CHANNEL CALIBRATION for each RPS In accordance with motor generator set electric power monitoring the Surveillance assembly. The Allowable Values shall be: Frequency Control Program

a. Overvoltage ::::: 127 V.

b. Undervoltage 2 107 V.

c. Underfrequency 2 57 .2 Hz.

(continued)

Brunswick Unit 2 3.3-73 Amendment No. 304 I

RPS Electric Power Monitoring 3.3.8.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.8.2.3 Perform CHANNEL CALIBRATION for each RPS In accordance with alternate power supply electric power monitoring the Surveillance assembly. The Allowable Values shall be: Frequency Control Program

a. Overvoltage :o: 127 V.

b. Undervoltage 2 107 V.

c. Underfrequency 2 57.2 Hz.

SR 3.3.8.2.4 Perform a system functional test. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.3-74 Amendment No. 304 I

Recirculation Loops Operating 3.4.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION 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.

No recirculation loops in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 -------------------------------N 0 TE--------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both recirculation loops are in operation Verify recirculation loop jet pump flow mismatch with In accordance with both recirculation loops in operation: . the Surveillance Frequency Control

a. :c: 10% of rated core flow when operating at Program

< 75% of rated core flow; and

b. :c: 5% of rated core flow when operating at

~ 75% of rated core flow.

Brunswick Unit 2 3.4-2 Amendment No. 304 I

Jet Pumps 3.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 -----------------------------N 0 TES---------------------------------

1. Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after associated recirculation loop is in operation.

2. Not required to be performed until 2 25% RTP.

Verify at least one of the following criteria (a orb) is In accordance with satisfied for each operating recirculation loop: the Surveillance Frequency Control

a. Recirculation pump flow to speed ratio differs by Program s:: 5% from established patterns, and jet pump loop flow to recirculation pump speed ratio differs by s:: 5% from established patterns.

b. Each jet pump diffuser to lower plenum differential pressure differs by s 10% from that jet pump's established pattern.

Brunswick Unit 2 3.4-4 Amendment No. 304 I

SRVs 3.4.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.3.2 -------------------------------N0 TE---------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

Verify each required SRV opens when manually In accordance with actuated. the Surveillance Frequency Control Program Brunswick Unit 2 3.4-6 Amendment No. 304 I

RCS Operational LEAKAGE 3.4.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION 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. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Pressure boundary LEAKAGE exists.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify RCS unidentified and total LEAKAGE and In accordance with unidentified LEAKAGE increase are within limits. the Surveillance Frequency Control Program Brunswick Unit 2 3.4-8 Amendment No. 304 I

RCS Leakage Detection Instrumentation 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Perform a CHANNEL CHECK of required primary In accordance with containment atmosphere radioactivity monitoring the Surveillance system. Frequency Control Program SR 3.4.5.2 Perform a CHANNEL FUNCTIONAL TEST of required In accordance with leakage detection instrumentation. the Surveillance Frequency Control Program SR 3.4.5.3 Perform a CHANNEL CALIBRATION of required In accordance with leakage detection instrumentation. the Surveillance Frequency Control Program Brunswick Unit 2 3.4-11 Amendment No. 304 I

RCS Specific Activity 3.4.6 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. (continued) B.2.2.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2.2.2 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 3.4.6.1 ---------------------------------N 0 TE-------------------------------

0 n ly required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 1-131 In accordance with specific activity is s 0.2 µCi/gm. the Surveillance Frequency Control Program Brunswick Unit 2 3.4-13 Amendment No. 304 I

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 --------------------------------N 0 TE-------------------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR shutdown cooling isolation pressure.

Verify one required RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.7.2 --------------------------------N0 TE-------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR shutdown cooling isolation pressure.

Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 2 3.4-16 Amendment No. 304 I

RHR Shutdown Cooling System-Cold Shutdown 3.4.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. No RHR shutdown cooling 8.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsystem in operation. circulating by an alternate discovery of no method. reactor coolant circulation No recirculation pump in operation.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND 8.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one required RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 2 3.4-18 Amendment No. 304 I

RCS P/T Limits 3.4.9 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. --------------NOTE--------------- C.1 Initiate action to restore Immediately Required Action C.2 shall be parameter(s) to within completed if this Condition is limits.

entered.

AND Requirements of the LCO C.2 Determine RCS is Prior to entering not met in other than acceptable for operation. MODE 2 or 3.

MODES 1, 2, and 3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 --------------------------------N 0 TE-------------------------------

0 n ly required to be performed during RCS heatup and cooldown operations.

Verify: In accordance with the Surveillance

a. RCS pressure and RCS temperature are within Frequency Control the applicable limits specified in Figures 3.4.9-1 Program and 3.4.9-2; and

b. RCS heatup and cooldown rates are ~ 100°F in any 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

(continued)

Brunswick Unit 2 3.4-20 Amendment No. 304 I

RCS PIT Limits 3.4.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.9.2 -------------------------------N 0 TE--------------------------------

0 nly required to be performed during RCS inservice leak and hydrostatic testing.

Verify: In accordance with the Surveillance

a. RCS pressure and RCS temperature are within Frequency Control the applicable limits specified in Figure 3.4.9-3; Program 3.4.9-4, or 3.4.9-5, as applicable;

b. RCS heatup and cooldown rates are :::: 30°F in any 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

SR 3.4.9.3 Verify RCS pressure and RCS temperature are within Once within the criticality limits specified in Figure 3.4.9-2. 15 minutes prior to control rod withdrawal for the purpose of achieving criticality SR 3.4.9.4 -------------------------------N 0 TE--------------------------------

0 nly required to be met in MODES 1, 2, 3, and 4 during recirculation pump start.

Verify the difference between the bottom head coolant Once within temperature and the reactor pressure vessel (RPV) 30 minutes prior to coolant temperature is:::: 145°F. each startup of a recirculation pump (continued)

Brunswick Unit 2 3.4-21 Amendment No. 304 I

RCS PIT Limits 3.4.9 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.9.5 -------------------------------N 0 TE--------------------------------

0 n ly required to be met in MODES 1, 2, 3, and 4 during recirculation pump start.

Verify the difference between the reactor coolant Once within temperature in the recirculation loop to be started and 30 minutes prior to the RPV coolant temperature is:'.'.'. 50°F. each startup of a recirculation pump SR 3.4.9.6 -------------------------------N 0 TE--------------------------------

0 n ly required to be performed when tensioning the reactor vessel head bolting studs.

Verify reactor vessel flange and head flange In accordance with temperatures are ? 70°F. the Surveillance Frequency Control Program SR 3.4.9.7 ------------------------------- N 0 TE--------------------------------

Not required to be performed until 30 minutes after RCS temperature:'.'.'. 80°F in MODE 4.

Verify reactor vessel flange and head flange In accordance with temperatures are :::: 70°F. the Surveillance Frequency Control Program SR 3.4.9.8 -------------------------------N 0 TE--------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after RCS

'temperature :'.'.'. 100°F in MODE 4.

Verify reactor vessel flange and head flange In accordance with temperatures are:::: 70°F. the Surveillance Frequency Control Program Brunswick Unit 2 3.4-22 Amendment No. 304 I

Reactor Steam Dome Pressure 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Reactor Steam Dome Pressure LCO 3.4.10 The reactor steam dome pressure shall be ~ 1045 psig.

APPLICABILITY: MODES 1 and 2.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Reactor steam dome A.1 Restore reactor steam 15 minutes pressure not within limit. dome pressure to within limit.

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.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify reactor steam dome pressure is~ 1045 psig. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.4-28 Amendment No. 304 I

ECCS-Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J. Two or more low pressure J.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, In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program (continued)

Brunswick Unit 2 3.5-4 Amendment No. 304 I

EGGS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.2 -------------------------------N 0 TES-------------------------------

1. Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) shutdown cooling isolation pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem manual, In accordance with power operated, and automatic valve in the flow path, the Surveillance that is not locked, sealed, or otherwise secured in Frequency Control position, is in the correct position. Program SR 3.5.1.3 Verify ADS pneumatic supply header pressure is In accordance with

?: 95 psig. the Surveillance Frequency Control Program SR 3.5.1.4 Verify the RHR System cross tie valve is locked In accordance with closed. the Surveillance Frequency Control Program SR 3.5.1.5 -------------------------------N 0 TE--------------------------------

N ot required to be performed if performed within the previous 31 days.

Verify each recirculation pump discharge valve and Once each startup bypass valve cycles through one complete cycle of full prior to exceeding travel or is de-energized in the closed position. 25% RTP (continued)

Brunswick Unit 2 3.5-5 Amendment No. 304 I

EGGS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.6 Verify the following ECCS pumps develop the In accordance with specified flow rate against a system head the Surveillance corresponding to the specified reactor pressure. Frequency Control Program SYSTEM HEAD CORRESPONDING NO. OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF cs ?: 4100 gpm ?: 113 psig LPCI ?: 14,000 gpm 2 ?: 20 psig SR 3.5.1.7 -------------------------------N0 TE--------------------------------

Not required to be performed until 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after reactor steam pressure is adequate to perform the test.

Verify, with reactor pressures: 1045 and ?: 945 psig, In accordance with the HPCI pump unit can develop a flow rate the Surveillance

?: 4250 gpm against a system head corresponding to Frequency Control reactor pressure. Program SR 3.5.1.8 -------------------------------N 0 TE--------------------------------

Not required to be performed until 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after reactor steam pressure is adequate to perform the test.

Verify, with reactor pressures: 180 psig, the HPCI In accordance with pump unit can develop a flow rate ?: 4250 gpm against the Surveillance a system head corresponding to reactor pressure. Frequency Control Program (continued)

Brunswick Unit 2 3.5-6 Amendment No. 304 I

ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.9 -------------------------------N 0 TE--------------------------------

Vessel injection/spray may be excluded.

Verify each ECCS injection/spray subsystem actuates In accordance with on an actual or simulated automatic initiation signal. the Surveillance Frequency Control Program SR 3.5.1.10 -------------------------------N 0 TE--------------------------------

Va Ive actuation may be excluded.

Verify the ADS actuates on an actual or simulated In accordance with automatic initiation signal. the Surveillance Frequency Control Program SR 3.5.1.11 -------------------------------N 0 TE--------------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

Verify each required ADS valve opens when manually In accordance with actuated. the Surveillance Frequency Control Program SR 3.5.1.12 -------------------------------N0 TE--------------------------------

1nstru men tat ion response time may be assumed to be the design instrumentation response time.

Verify the ECCS RESPONSE TIME for each ECCS In accordance with injection/spray subsystem is within the limit. the Surveillance Frequency Control Program Brunswick Unit 2 3.5-7 Amendment No. 304 I

ECCS-Shutdown 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action C.2 and D.1 Initiate action to restore Immediately associated Completion Time secondary containment to not met. OPERABLE status.

D.2 Initiate action to restore one Immediately standby gas treatment subsystem to OPERABLE status.

D.3 Initiate action to restore Immediately isolation capability in each required secondary containment penetration flow path not isolated.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water level is the Surveillance

> -31 inches. Frequency Control Program (continued)

Brunswick Unit 2 3.5-9 Amendment No. 304 I

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required core spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is:? -31 inches; or Program

b. --------------------------N 0 TE-----------------------------

On ly one required CS subsystem may take credit for this option during OPDRVs.

Condensate storage tank water volume is

? 228,200 gallons.

SR 3.5.2.3 Verify, for each required ECCS injection/spray In accordance with subsystem, locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program SR 3.5.2.4 -------------------------------N 0 TES------------------------------

1. One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

2. Not required to be met for system vent flow paths opened under administrative control.

Verify each required ECCS injection/spray subsystem In accordance with manual, power operated, and automatic valve in the the Surveillance flow path, that is not locked, sealed, or otherwise Frequency Control secured in position, is in the correct position. Program (continued)

Brunswick Unit 2 3.5-10 Amendment No. 304

EGGS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each required ECCS pump develops the In accordance with specified flow rate against a system head the Surveillance corresponding to the specified reactor pressure. Frequency Control Program SYSTEM HEAD NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF cs 2 4100 gpm 2 113 psig LPCI 2 9000 gpm 1 2 20 psig SR 3.5.2.6 ----------------------------------N 0 TE-----------------------------

Ves se I injection/spray may be excluded.

Verify each required ECCS injection/spray subsystem In accordance with actuates on an actual or simulated automatic initiation the Surveillance signal. Frequency Control Program SR 3.5.2.7 ----------------------------------N 0 TE-----------------------------

1nstrum en tat ion response time may be assumed to be the design instrumentation response time.

Verify the ECCS RESPONSE TIME for each required In accordance with ECCS injection/spray subsystem is within the limit. the Surveillance Frequency Control Program Brunswick Unit 2 3.5-11 Amendment No. 304

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program SR 3.5.3.2 ----------------------------------N 0 TE-----------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, In accordance with and automatic valve in the flow path, that is not the Surveillance locked, sealed, or otherwise secured in position, is in Frequency Control the correct position. Program SR 3.5.3.3 ----------------------------------N 0 TES----------------------------

1. Use of auxiliary steam for the performance of the SR is not allowed.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reactor steam pressure is adequate to perform the test.

Verify, with reactor pressure ::::o: 945 psig and s 1045 In accordance with psig, the RCIC pump can develop a flow rate the Surveillance

o: 400 gpm against a system head corresponding to Frequency Control reactor pressure. Program (continued)

Brunswick Unit 2 3.5-13 Amendment No. 304 I

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.4 ----------------------------------N 0 TES----------------------------

1. Use of auxiliary steam for the performance of the SR is not allowed with reactor pressure

150 psig.

2. Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reactor steam pressure is adequate to perform the test.

Verify, with turbine inlet pressure :::: 135 psig and :::: 165 In accordance with psig, the RCIC pump can develop a flow rate the Surveillance

400 gpm against a system head corresponding to an Frequency Control equivalent reactor pressure. Program SR 3.5.3.5 ----------------------------------N 0 T E-----------------------------

Ves se I injection may be excluded.

Verify the RCIC System actuates on an actual or In accordance with simulated automatic initiation signal. the Surveillance Frequency Control Program Brunswick Unit 2 3.5-14 Amendment No. 304 I

Primary Containment 3.6.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1.1 Perform required visual examinations and leakage rate In accordance with testing, except for primary containment air lock testing, the Primary in accordance with the Primary Containment Leakage Containment Rate Testing Program. Leakage Rate Testing Program SR 3.6.1.1.2 Verify drywell to suppression chamber differential In accordance with pressure does not decrease at a rate> 0.25 inch water the Surveillance gauge per minute tested over a 10 minute period at an Frequency Control initial differential pressure of 2'. 1.00 psid and Program

1.25 psid.

Brunswick Unit 2 3.6-2 Amendment No. 304 I

Primary Containment Air Lock 3.6.1.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME 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 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.2.1 -------------------------------N 0 TES-------------------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1.

Perform required primary containment air lock leakage In accordance with rate testing in accordance with the Primary the Primary Containment Leakage Rate Testing Program. Containment Leakage Rate Testing Program SR 3.6.1.2.2 Verify only one door in the primary containment air In accordance with lock can be opened at a time. the Surveillance Frequency Control Program Brunswick Unit 2 3.6-6 Amendment No. 304 I

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 -------------------------------N 0 TES------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation manual In accordance with valve and blind flange that is located outside primary the Surveillance containment and not locked, sealed, or otherwise Frequency Control secured and is required to be closed during accident Program conditions is closed.

(continued)

Brunswick Unit 2 3.6-11 Amendment No. 304 I

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.2 -------------------------------N 0 TES------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual isolation Prior to entering valve and blind flange that is located inside primary MODE 2 or 3 from containment and not locked, sealed, or otherwise MODE 4 if primary secured and is required to be closed during accident containment was conditions, is closed. de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.3 Verify continuity of the traversing incore probe (TIP) In accordance with shear isolation valve explosive charge. the Surveillance Frequency Control Program SR 3.6.1.3.4 Verify the isolation time of each power operated and In accordance each automatic PCIV, except for MSIVs, is within with the lnservice limits. Testing Program SR 3.6.1.3.5 Verify the isolation time of each MSIV is?: 3 seconds In accordance with and s 5 seconds. the lnservice Testing Program (continued)

Brunswick Unit 2 3.6-12 Amendment No. 304 I

PC IVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Verify each automatic PCIV actuates to the isolation In accordance with position on an actual or simulated isolation signal. the Surveillance Frequency Control Program SR 3.6.1.3.7 Verify a representative sample of reactor In accordance with instrumentation line EFCVs actuate to the isolation the Surveillance position on an actual or simulated instrument line Frequency Control break signal. Program SR 3.6.1.3.8 Remove and test the explosive squib from each shear In accordance with isolation valve of the TIP System. the lnservice Testing Program SR 3.6.1.3.9 Verify leakage rate through each main steam line is In accordance with

100 scfh and the combined leakage rate of all four the Primary main steam lines is: ::; 150 scfh when tested at Containment z 25 psig. Leakage Rate Testing Program Brunswick Unit 2 3.6-13 Amendment No. 304 I

Drywell Air Temperature 3.6.1.4 3.6 CONTAINMENT SYSTEMS 3.6.1.4 Drywell Air Temperature LCO 3.6.1.4 Drywell average air temperature shall be .: : 150°F.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Drywell average air A.1 Restore drywell average air 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months temperature not within limit. temperature to within limit.

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. AND B.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 3.6.1.4.1 Verify drywell average air temperature is within limit. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.6-14 Amendment No. 304 I

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.5.1 Verify nitrogen bottle supply pressure of each nitrogen In accordance with backup subsystem is;::: 1130 psig. the Surveillance Frequency Control Program SR 3.6.1.5.2 -------------------------------N 0 TES------------------------------

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

2. Not required to be met for vacuum breakers open when performing their intended function.

Verify each vacuum breaker is closed. In accordance with the Surveillance Frequency Control Program SR 3.6.1.5.3 Perform a functional test of each vacuum breaker. In accordance with the Surveillance Frequency Control Program SR 3.6.1.5.4 Verify the full open setpoint of each vacuum breaker is In accordance with s 0.5 psid. the Surveillance Frequency Control Program SR 3.6.1.5.5 Verify leakage rate of each nitrogen backup In accordance with subsystem is s 0.65 scfm when tested at an initial the Surveillance nitrogen bottle supply pressure of;::: 1130 psig. Frequency Control Program SR 3.6.1.5.6 Verify the Nitrogen Backup System supplies nitrogen In accordance with to the vacuum breakers on an actual or simulated the Surveillance actuation signal. Frequency Control Program Brunswick Unit 2 3.6-17 Amendment No. 304 I

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.6.1 --------------------------------N 0 TE-------------------------------

N ot required to be met for vacuum breakers that are open during Surveillances.

Verify each vacuum breaker is closed. In accordance with the Surveillance Frequency Control Program 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 Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following an operation that causes any of the vacuum breakers to open (continued)

Brunswick Unit 2 3.6-19 Amendment No. 304

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.6.2 Perform a functional test of each required vacuum In accordance with breaker. the Surveillance Frequency Control Program Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after any discharge of steam to the suppression chamber from the SR Vs SR 3.6.1.6.3 Verify the full open setpoint of each required vacuum In accordance with breaker is~ 0.5 psid. the Surveillance Frequency Control Program Brunswick Unit 2 3.6-19a Amendment No. 304

Suppression Pool Average Temperature 3.6.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1.1 Verify suppression pool average temperature is within In accordance with the applicable limits. the Surveillance Frequency Control Program 5 minutes when performing testing that adds heat to the suppression pool Brunswick Unit 2 3.6-22 Amendment No. 304 I

Suppression Pool Water Level 3.6.2.2 3.6 CONTAINMENT SYSTEMS 3.6.2.2 Suppression Pool Water Level LCO 3.6.2.2 Suppression pool water level shall be~ -31 inches and~ -27 inches.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Suppression pool water A.1 Restore suppression pool 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months level not within limits. water level to within limits.

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. AND B.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 3.6.2.2.1 Verify suppression pool water level is within limits. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.6-23 Amendment No. 304 I

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling subsystem In accordance with manual, power operated, and automatic valve in the the Surveillance flow path that is not locked, sealed, or otherwise Frequency Control secured in position is in the correct position or can be Program aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance with 2 7700 gpm through the associated heat exchanger the Surveillance while operating in the suppression pool cooling mode. Frequency Control Program SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program Brunswick Unit 2 3.6-25 Amendment No. 304 I

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Oxygen Concentration LCO 3.6.3.1 The primary containment oxygen concentration shall be< 4.0 volume percent.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to

< 15% RTP.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Primary containment oxygen A.1 Restore oxygen 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months concentration not within concentration to within limit.

limit.

B. Required Action and B.1 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months associated Completion Time POWER to::; 15% RTP.

not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1.1 Verify primary containment oxygen concentration is In accordance with within limits. the Surveillance Frequency Control Program Brunswick Unit 2 3.6-26 Amendment No. 304 I

Secondary Containment 3.6.4.1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. (continued) C.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment equipment hatches In accordance with are closed and sealed. the Surveillance Frequency Control Program SR 3.6.4.1.2 Verify one secondary containment access door is In accordance with closed in each access opening. the Surveillance Frequency Control Program SR 3.6.4.1.3 Verify each SGT subsystem can maintain ::::>: 0.25 inch In accordance with of vacuum water gauge in the secondary containment the Surveillance for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a flow rate::: 3000 cfm. Frequency Control Program Brunswick Unit 2 3.6-29 Amendment No. 304

SCIDs 3.6.4.2 ACTIONS (continued)

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

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met during movement of recently irradiated fuel assemblies in Suspend movement of Immediately the secondary containment recently irradiated fuel or during OPDRVs. assemblies in the secondary containment.

AND D.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each automatic SCIO is In accordance with within limits. the Surveillance Frequency Control Program SR 3.6.4.2.2 Verify each automatic SCIO actuates to the isolation In accordance with position on an actual or simulated actuation signal. the Surveillance Frequency Control Program Brunswick Unit 2 3.6-32 Amendment No. 304 I

SGT System 3.6.4.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. Two SGT subsystems E.1 ---------------N0 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 secondary containment.

AND E.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for~ 15 continuous In accordance with minutes with heaters operating. the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual or In accordance with simulated initiation signal. the Surveillance Frequency Control Program Brunswick Unit 2 3.6-35 Amendment No. 304 I

RHRSW System 3.7.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME 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 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 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and In accordance with automatic valve in the flow path, that is not locked, the Surveillance sealed, or otherwise secured in position, is in the Frequency Control correct position or can be aligned to the correct Program position.

Brunswick Unit 2 3.7-3 Amendment No. 304 I

SW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the water level in the SW pump suction bay of In accordance with the intake structure is 2 -6 ft mean sea level. the Surveillance Frequency Control Program SR 3.7.2.2 Verify the water temperature of UHS is .'.S'. 90.5°F. In accordance with the Surveillance Frequency Control Program SR 3.7.2.3 -------------------------------N 0 TE-------------------------------

1so Iat ion of flow to individual components does not render SW System inoperable.

Verify each SW System manual, power operated, and In accordance with automatic valve in the flow paths servicing safety the Surveillance related systems or components, that is not locked, Frequency Control sealed, or otherwise secured in position, is in the Program correct position.

SR 3.7.2.4 ------------------------------N 0 TES--------------------------------

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

2. Isolation of flow to individual components does not render SW System inoperable.

Verify automatic transfer of each DG cooling water In accordance with supply from the normal SW supply to the alternate SW the Surveillance supply on low DG jacket cooling water supply Frequency Control pressure. Program (continued)

Brunswick Unit 2 3.7-9 Amendment No. 304

SW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS continued)

SURVEILLANCE FREQUENCY SR 3.7.2.5 -------------------------------N0 TE---------------------------------

1so Iati on of flow to individual components does not render SW System inoperable.

Verify each required SW System automatic component In accordance with actuates on an actual or simulated initiation signal. the Surveillance Frequency Control Program Brunswick Unit 2 3.7-10 Amendment No. 304 I

CREV System 3.7.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME E. Two CREV subsystems -------------------N 0 TE---------------------

inoperable during movement LCO 3.0.3 is not applicable.

of irradiated fuel assemblies in the secondary containment, during CORE E.1 Suspend movement of Immediately ALTERATIONS, or during irradiated fuel assemblies OPDRVs. in the secondary containment.

One or more CREV subsystems inoperable due E.2 Suspend CORE Immediately to an inoperable CRE ALTERATIONS.

boundary during movement of irradiated fuel assemblies AND in the secondary containment, during CORE E.3 Initiate action to suspend Immediately ALTERATIONS, or during OPDRVs.

OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate each CREV subsystem for :::: 15 continuous In accordance with minutes. the Surveillance Frequency Control Program SR 3.7.3.2 Perform required CREV filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP (continued)

Brunswick Unit 2 3.7-13 Amendment No. 304

CREV System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.3 Perform required CRE unfiltered air inleakage testing In accordance with in accordance with the Control Room Envelope the Control Room Habitability Program. Envelope Habitability Program SR 3.7.3.4 Verify each CREV subsystem actuates on an actual or In accordance with simulated initiation signal. the Surveillance Frequency Control Program Brunswick Unit 2 3.7-14 Amendment No. 304 I

Control Room AC System 3.7.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME F. Three control room AC -------------------N 0 T E---------------------

subsystems inoperable LCO 3.0.3 is not applicable during movement of irradiated fuel assemblies in the secondary containment, F.1 Suspend movement of Immediately during CORE irradiated fuel assemblies in ALTERATIONS, or during the secondary containment.

OPDRVs.

AND F.2 Suspend CORE Immediately ALTERATIONS.

F.3 Initiate actions to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the In accordance with capability to remove the assumed heat load. the Surveillance Frequency Control Program Brunswick Unit 2 3.7-17 Amendment No. 304

Main Condenser Offgas 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -------------------------------N 0 TE---------------------------------

N ot required to be performed until 31 days after any main steam line not isolated and SJAE in operation.

Verify the gross gamma activity rate of the noble gases In accordance with is .:o: 243,600 µCi/second after decay of 30 minutes. the Surveillance Frequency Control Program Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after a~ 50%

increase in the nominal steady state fission gas release after factoring out increases due to changes in THERMAL POWER level Brunswick Unit 2 3.7-19 Amendment No. 304 I

Main Turbine Bypass System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify one complete cycle of each main turbine bypass In accordance with valve. the Surveillance Frequency Control Program SR 3.7.6.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM RESPONSE In accordance with TIME is within limits. the Surveillance Frequency Control Program Brunswick Unit 2 3.7-21 Amendment No. 304 I

Spent Fuel Storage Pool Water Level 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Spent Fuel Storage Pool Water Level LCO 3. 7. 7 The spent fuel storage pool water level shall be 2 19 feet 11 inches over the top of irradiated fuel assemblies seated in the spent fuel storage pool racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the spent fuel storage pool.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Spent fuel storage pool A.1 --------------N 0 TE-------------

water level not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in the spent fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify the spent fuel storage pool water level is In accordance with 2 19 feet 11 inches over the top of irradiated fuel the Surveillance assemblies seated in the spent fuel storage pool Frequency Control racks. Program Brunswick Unit 2 3.7-22 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power In accordance with availability for each offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 ----------------------------N0 TES----------------------------------

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

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

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

Verify each DG starts from standby conditions and In accordance with achieves steady state voltage 2'. 3750 V and ::: 4300 V the Surveillance and frequency 2'. 58.8 Hz and ::: 61.2 Hz. Frequency Control Program (continued)

Brunswick Unit 2 3.8-7 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 ---------------------------- N0 TES----------------------------------

1. DG loadings may include gradual loading.

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

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

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

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

Verify each DG is synchronized and loaded and In accordance with operates for ~ 60 minutes at a load ~ 2800 kW and the Surveillance s 3500 kW. Frequency Control Program SR 3.8.1.4 Verify each engine mounted tank contains ~ 150 gal of In accordance with fuel oil. the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each In accordance with engine mounted tank. the Surveillance Frequency Control Program SR 3.8.1.6 Verify the fuel oil transfer system operates to transfer In accordance with fuel oil from the day fuel oil storage tank to the engine the Surveillance mounted tank. Frequency Control Program (continued)

Brunswick Unit 2 3.8-8 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.7 ----------------------------N 0 TES----------------------------------

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

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

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

(continued)

Brunswick Unit 2 3.8-9 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.8 ----------------------------N0 TES---------------------------------

1. SR 3.8.1.8.a shall not be performed in MODE 1 or 2 for the Unit 2 offsite circuits. However, credit may be taken for unplanned events that satisfy this SR.

2. SR 3.8.1.8.a is not required to be met if the unit power supply is from the preferred offsite circuit.

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

Verify: In accordance with the Surveillance

a. Automatic transfer capability of the unit power Frequency Control supply from the normal circuit to the preferred Program offsite circuit; and

b. Manual transfer of the unit power supply from the preferred offsite circuit to the alternate offsite circuit.

(continued)

Brunswick Unit 2 3.8-10 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.9 ----------------------------N 0 TES---------------------------------

1. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 3 and DG 4. However, credit may be taken for unplanned events that satisfy this SR.

2. If performed with the DG synchronized with offsite power, it shall be performed at a power factor :c:: 0.9.

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

Verify each DG rejects a load greater than or equal to In accordance with its associated core spray pump without tripping. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.8-11 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.10 ----------------------------N 0 TES---------------------------------

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

Verify each DG's automatic trips are bypassed on an In accordance with actual or simulated ECCS initiation signal except: the Surveillance Frequency Control

a. Engine overspeed; Program

b. Generator differential overcurrent;

c. Low lube oil pressure;

d. Reverse power;

e. Loss of field; and

f. Phase overcurrent (voltage restrained).

(continued)

Brunswick Unit 2 3.8-12 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 ----------------------------N0 TES---------------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

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

Verify each DG operating at a power factor::;; 0.9 In accordance with operates for ~ 60 minutes loaded to ~ 3500 kW and the Surveillance

3850 kW. Frequency Control Program SR 3.8.1.12 ----------------------------N 0 T ES---------------------------------

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

Verify an actual or simulated ECCS initiation signal is In accordance with capable of overriding the test mode feature to return the Surveillance each DG to ready-to-load operation. Frequency Control Program (continued)

Brunswick Unit 2 3.8-13 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.13 ----------------------------N0 TES---------------------------------

T his Surveillance shall not be performed in MODE 1, 2, or 3 for the load sequence relays associated with DG 3 and DG 4. However, credit maybe taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load block is In accordance with within +/- 10% of design interval for each load sequence the Surveillance relay. Frequency Control Program (continued)

Brunswick Unit 2 3.8-14 Amendment No. 304 I

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.14 ----------------------------N 0 TES---------------------------------

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

2. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 3 and DG 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify, on actual or simulated loss of offsite power In accordance with signal in conjunction with an actual or simulated ECCS the Surveillance initiation signal: Frequency Control Program

a. De-energization of emergency buses;

b. Load shedding from emergency buses; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in

10.5 seconds,

2. energizes auto-connected emergency loads through load sequence relays,

3. maintains steady state voltage ~ 3750 V and:::: 4300 V,

4. maintains steady state frequency~ 58.8 Hz and :::: 61.2 Hz, and

5. supplies permanently connected and auto-connected emergency loads for

~ 5 minutes.

Brunswick Unit 2 3.8-15 Amendment No. 304 I

Diesel Fuel Oil 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 For each required DG, verify: In accordance with the Surveillance

a. The associated day fuel oil storage tank Frequency Control contains~ 22,650 gal; and Program

b. The main fuel oil storage tank contains ~ 20,850 gal per required DG.

SR 3.8.3.2 Verify fuel oil properties of stored fuel oil are tested in In accordance with accordance with, and maintained within the limits of, the Diesel Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.3 Check for and remove accumulated water from each In accordance with day fuel oil tank and the main fuel oil storage tank. the Surveillance Frequency Control Program Brunswick Unit 2 3.8-22 Amendment No. 304 I

DC Sources-Operating 3.8.4 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. AND B.2 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 inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is ::o: 130 V on float In accordance with charge. the Surveillance Frequency Control Program SR 3.8.4.2 Verify no visible corrosion at battery terminals and In accordance with connectors. the Surveillance Frequency Control Program 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 In accordance with visual indication of physical damage or abnormal the Surveillance deterioration that degrades performance. Frequency Control Program (continued)

Brunswick Unit 2 3.8-24 Amendment No. 304 I

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery cell to cell In accordance with and terminal connections are coated with the Surveillance anti-corrosion material. Frequency Control Program SR 3.8.4.5 Verify each required battery charger supplies In accordance with 2 250 amps at 2 135 V for 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . the Surveillance Frequency Control Program SR 3.8.4.6 -------------------------------N 0 TES------------------------------

1. The modified performance discharge test in SR 3.8.4.7 may be performed in lieu of the service test in SR 3.8.4.6 once per 60 months.

2. This Surveillance shall not be performed in MODE 1 or 2 for the Unit 2 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR.

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

Verify battery capacity is adequate to supply, and In accordance with maintain in OPERABLE status, the required the Surveillance emergency loads for the design duty cycle when Frequency Control subjected to a battery service test. Program (continued)

Brunswick Unit 2 3.8-25 Amendment No. 304 I

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.7 -------------------------------N 0 TES-------------------------------

1. This Surveillance shall not be performed in MODE 1 or 2 for the Unit 2 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR.

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

Verify battery capacity is ~ 80% of the manufacturer's In accordance with rating when subjected to a performance discharge test the Surveillance or a modified performance discharge test. Frequency Control Program 12 months when battery shows degradation or has reached 85% of the expected life with capacity < 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity ~ 100% of manufacturer's rating Brunswick Unit 2 3.8-26 Amendment No. 304 I

Battery Cell Parameters 3.8.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B limits of Table 3.8.6-1.

B. Required Action and B.1 Declare associated battery Immediately associated Completion Time inoperable.

of Condition A not met.

OR One or more batteries with average electrolyte temperature of the representative cells not within limits.

OR One or more batteries with one or more battery cell parameters not within Category C limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 In accordance with Category A limits. the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.8-31 Amendment No. 304 I

Battery Cell Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 In accordance with Category B limits. the Surveillance Frequency Control Program SR 3.8.6.3 Verify average electrolyte temperature of In accordance with representative cells is 2 60°F. the Surveillance Frequency Control Program Brunswick Unit 2 3.8-32 Amendment No. 304 I

Distribution Systems-Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and indicated power In accordance with availability to required AC and DC electrical power the Surveillance distribution subsystems. Frequency Control Program SR 3.8.7.2 Verify no combination of more than two power In accordance with conversion modules (consisting of either two lighting the Surveillance inverters or one lighting inverter and one plant Frequency Control uninterruptible power supply unit) are aligned to Program Division II bus B.

Brunswick Unit 2 3.8-37 Amendment No. 304 I

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to suspend Immediately operations with a potential for draining the reactor vessel.

AND A.2.4 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status.

AND A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and indicated power In accordance with availability to required AC and DC electrical power the Surveillance distribution subsystems. Frequency Control Program Brunswick Unit 2 3.8-39 Amendment No. 304 I

Refueling Equipment Interlocks 3.9.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Perform CHANNEL FUNCTIONAL TEST on each of In accordance with the following required refueling equipment interlock the Surveillance inputs: Frequency Control Program

a. All-rods-in,

b. Refuel platform position,

c. Refuel platform fuel grapple, fuel loaded,

d. Fuel grapple position,

e. Refuel platform frame-mounted hoist, fuel loaded, and

f. Refuel platform monorail hoist, fuel loaded.

Brunswick Unit 2 3.9-2 Amendment No. 304 I

Refuel Position One-Rod-Out Interlock 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Refuel Position One-Rod-Out Interlock LCO 3.9.2 The refuel position one-rod-out interlock shall be OPERABLE.

APPLICABILITY: MODE 5 with the reactor mode switch in the refuel position and any control rod withdrawn.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refuel position one-rod-out A.1 Suspend control rod Immediately interlock inoperable. withdrawal.

A.2 Initiate action to fully insert Immediately all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Verify reactor mode switch locked in Refuel position. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.9-3 Amendment No. 304 I

Refuel Position One-Rod-Out Interlock 3.9.2 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.9.2.2 ---------------------------------N 0 TE-------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.9-4 Amendment No. 304 I

Control Rod Position 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Control Rod Position LCO 3.9.3 All control rods shall be fully inserted.

APPLICABILITY: When loading fuel assemblies into the core.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more control rods A.1 Suspend loading fuel Immediately not fully inserted. assemblies into the core.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify all control rods are fully inserted. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.9-5 Amendment No. 304 I

Control Rod OPERABILITY-Refueling 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Control Rod OPERABILITY-Refueling LCO 3.9.5 Each withdrawn control rod shall be OPERABLE.

APPLICABILITY: MODE 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more withdrawn A.1 Initiate action to fully insert Immediately control rods inoperable. inoperable withdrawn control rods.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 --------------------------------N0 TE--------------------------------

Not required to be performed until 7 days after the control rod is withdrawn.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SR 3.9.5.2 Verify each withdrawn control rod scram accumulator In accordance with pressure is ~ 940 psig. the Surveillance Frequency Control Program Brunswick Unit 2 3.9-8 Amendment No. 304 I

RPV Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Reactor Pressure Vessel (RPV) Water Level LCO 3.9.6 RPV water level shall be :::: 23 ft above the top of irradiated fuel assemblies seated within the RPV.

APPLICABILITY: During movement of irradiated fuel assemblies within the RPV, During movement of new fuel assemblies or handling of control rods within the RPV, when irradiated fuel assemblies are seated within the RPV.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RPV water level not within A.1 Suspend movement of fuel Immediately limit. assemblies and handling of control rods within the RPV.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify RPV water level is:::: 23 ft above the top of In accordance with irradiated fuel assemblies seated within the RPV. the Surveillance Frequency Control Program Brunswick Unit 2 3.9-9 Amendment No. 304 I

RHR-High Water Level 3.9.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is In accordance with operating. the Surveillance Frequency Control Program SR 3.9.7.2 Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance .

sufficiently filled with water. Frequency Control Program Brunswick Unit 2 3.9-12 Amendment No. 304 I

RHR-Low Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is In accordance with operating. the Surveillance Frequency Control Program SR 3.9.8.1 Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 2 3.9-15 Amendment No. 304 I

Reactor Mode Switch Interlock Testing 3.10.2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.3.1 Place the reactor mode 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months switch in the shutdown position.

OR A. 3. 2 -------------N 0 TE--------------

0 nly applicable in MODE 5.

Place the reactor mode 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months switch in the refuel position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.2.1 Verify all control rods are fully inserted in core cells In accordance with containing one or more fuel assemblies. the Surveillance Frequency Control Program SR 3.10.2.2 Verify no CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.10-5 Amendment No. 304 I

Single Control Rod Withdrawal-Hot Shutdown 3.10.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.3.1 Perform the applicable SRs for the required LCOs. According to the applicable SRs SR 3.10.3.2 --------------------------------N 0 TE--------------------------------

Not required to be met if SR 3.10.3.1 is satisfied for LCO 3.10.3.d.1 requirements.

Verify all control rods, other than the control rod being In accordance with withdrawn, in a five by five array centered on the the Surveillance control rod being withdrawn, are disarmed. Frequency Control Program SR 3.10.3.3 Verify all control rods, other than the control rod being In accordance with withdrawn, are fully inserted. the Surveillance Frequency Control Program Brunswick Unit 2 3.10-8 Amendment No. 304 I

Single Control Rod Withdrawal-Cold Shutdown 3.10.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One or more of the above B.1 Suspend withdrawal of the Immediately requirements not met with control rod and removal of the affected control rod not associated CRD.

insertable.

B.2.1 Initiate action to fully insert Immediately all control rods.

B.2.2 Initiate action to satisfy the Immediately requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.4.1 Perform the applicable SRs for the required LCOs. According to the applicable SRs SR 3.10.4.2 --------------------------------N 0 T E--------------------------------

Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.c.1 requirements.

Verify all control rods, other than the control rod being In accordance with withdrawn, in a five by five array centered on the the Surveillance control rod being withdrawn, are disarmed. Frequency Control Program (continued)

Brunswick Unit 2 3.10-11 Amendment No. 304 I

Single Control Rod Withdrawal-Cold Shutdown 3.10.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.4.3 Verify all control rods, other than the control rod being In accordance with withdrawn, are fully inserted. the Surveillance Frequency Control Program SR 3.10.4.4 --------------------------------N0 TE--------------------------------

Not required to be met if SR 3.10.4.1 is satisfied for LCO 3.10.4.b.1 requirements.

Verify a control rod withdrawal block is inserted. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.10-12 Amendment No. 304 I

Single CRD Removal-Refueling 3.10.5 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2.1 Initiate action to fully insert Immediately all control rods.

A.2.2 Initiate action to satisfy the Immediately requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.5.1 Verify all control rods, other than the control rod In accordance with withdrawn for the removal of the associated CRD, are the Surveillance fully inserted. Frequency Control Program SR 3.10.5.2 Verify all control rods, other than the control rod In accordance with withdrawn for the removal of the associated CRD, in a the Surveillance five by five array centered on the control rod withdrawn Frequency Control for the removal of the associated CRD, are disarmed. Program SR 3.10.5.3 Verify a control rod withdrawal block is inserted. In accordance with the Surveillance Frequency Control Program SR 3.10.5.4 Perform SR 3.1.1.1. According to SR 3.1.1.1 (continued)

Brunswick Unit 2 3.10-14 Amendment No. 304 I

Single CRD Removal-Refueling 3.10.5 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.10.5.5 Verify no other CORE AL TE RATIONS are in progress. In accordance with the Surveillance Frequency Control Program Brunswick Unit 2 3.10-15 Amendment No. 304 I

Multiple Control Rod Withdrawal-Refueling 3.10.6 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.3.1 Initiate action to fully insert Immediately all control rods in core cells containing one or more fuel assemblies.

A.3.2 Initiate action to satisfy the Immediately requirements of this LCO.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.10.6.1 Verify the four fuel assemblies are removed from core In accordance with cells associated with each control rod or CRD the Surveillance removed. Frequency Control Program SR 3.10.6.2 Verify all other control rods in core cells containing one In accordance with or more fuel assemblies are fully inserted. the Surveillance Frequency Control Program SR 3.10.6.3 --------------------------------N0 TE--------------------------------

0 n ly required to be met during fuel loading.

Verify fuel assemblies being loaded are in compliance In accordance with with an approved spiral reload sequence. the Surveillance Frequency Control Program Brunswick Unit 2 3.10-17 Amendment No. 304 I

SDM Test-Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.2 --------------------------------N 0 TE--------------------------------

Not required to be met if SR 3.10.8.3 satisfied.

Perform the MODE 2 applicable SRs for LCO 3.3.2.1, According to the Function 2 of Table 3.3.2.1-1. applicable SRs SR 3.10.8.3 --------------------------------N 0 TE--------------------------------

Not required to be met if SR 3.10.8.2 satisfied.

Verify movement of control rods is in compliance with During control rod the approved control rod sequence for the SDM test by movement a second licensed operator or other qualified member of the technical staff.

SR 3.10.8.4 Verify no other CORE ALTERATIONS are in progress. In accordance with the Surveillance Frequency Control Program (continued)

Brunswick Unit 2 3.10-22 Amendment No. 304 I

SOM Test-Refueling 3.10.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.10.8.5 Verify each withdrawn control rod does not go to the Each time the withdrawn overtravel position. control rod is withdrawn to "full out" position Prior to satisfying LCO 3.10.8.c requirement after work on control rod or CRD System that could affect coupling SR 3.10.8.6 Verify CRD charging water header pressure ;:::: 940 In accordance with psig. the Surveillance Frequency Control Program Brunswick Unit 2 3.10-23 Amendment No. 304 I

Programs and Manuals 5.5 5.5 Programs and Manuals Control Room Envelope Habitability Program (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

Brunswick Unit 2 5.0-17a Amendment No. 304 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 276 AND 304 TO RENEWED FACILITY OPERATING LICENSES NOS. DPR-71 AND DPR-62 DUKE ENERGY PROGRESS. LLC BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By application dated December 21, 2015 (Reference 12), as supplemented by letters dated June 29, July 13, August 15, November 1, November 17, 2016, and February 27, 2017 (References 13-17), Duke Energy Progress, Inc. (Duke Energy or the licensee) requested changes to the technical specifications (TSs) for Brunswick Steam Electric Plant (Brunswick),

Units 1 and 2, which are contained in Appendix A of Renewed Facility Operating Licenses DPR-71 and DPR-62. The supplemental letters provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register (FR) on March 29, 2016 (81 FR 17504).

The licensee requested to revise the Brunswick Units 1 and 2 TSs by relocating specific surveillance requirement (SR) frequencies to a licensee-controlled program. Specifically, the licensee requested to adopt NRG-approved Technical Specifications Task Force (TSTF) traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -

RITSTF Initiative Sb" (Reference 1). When implemented, TSTF-425 relocates most periodic frequencies of TS surveillances to a licensee controlled program, the Surveillance Frequency Control Program (SFCP), and provides requirements for the new program in the Administrative Controls section of the TSs. All surveillance frequencies can be relocated except:

Frequencies that reference other approved programs for the specific interval (such as the lnservice Testing Program or the Primary Containment Leakage Rate Testing Program);

Frequencies that are purely event-driven (e.g., "each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching ~ [greater than or equal to] 95% RTP [Reactor Thermal Power]"); and Enclosure 3

Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywall to suppression chamber differential pressure decrease").

The licensee also proposed to add a new program to the Administrative Controls of TS Section 5 as Specification 5.5.14. The new program is called the Surveillance Frequency Control Program (SFCP) and describes the requirements for the program to control changes to the relocated surveillance frequencies. The TS Bases for each of the affected surveillance requirements are revised to state that the frequency is set in accordance with the SFCP. The proposed licensee changes to the Administrative Controls of the TSs to incorporate the SFCP include a specific reference to Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies,"

Revision 1 (Reference 2) as the basis for making any changes to the surveillance frequencies once they are relocated out of the TSs.

In a letter dated September 19, 2007 (Reference 3), the NRC staff approved NEI 04-10, Revision 1, as acceptable for referencing in licensing actions to the extent specified and under the limitations delineated in NEI 04-10, and the safety evaluation providing the basis for NRC acceptance of NEI 04-10.

The NRC staff reviewed this license amendment request (LAR) to adopt the above NRC accepted TSTF-425 qnd approved NEI 04-10. After completing the review, the NRC staff found that the LAR satisfies the key principles of risk-informed decision making applied to changes to TSs as delineated in Regulatory Guide (RG) 1.177 and RG 1.174, in that:

The proposed change meets current regulations;

The proposed change is consistent with defense-in-depth philosophy;

The proposed change maintains sufficient safety margins;

Increases in risk resulting from the proposed change are small and consistent with the Commission's Safety Goal Policy Statement; and

The impact of the proposed change is monitored with performance measurement strategies.

Furthermore, the regulatory requirements in 10 CFR 50.65, and 10 CFR Part 50, Appendix 8, Criterion XVI, and the performance monitoring required by NEI 04-10, Revision 1, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied and that any performance deficiencies will be identified and appropriate corrective actions taken. The staff concludes the licensee's SFCP ensures that Surveillance Requirements (SRs) specified in the TSs are performed at intervals sufficient to assure the above regulatory requirements are met.

The details of the review are discussed as follow:

2.0 REGULATORY EVALUATION

2.1 Applicable Commission Policy Statements In the "Final Policy Statement: Technical Specifications for Nuclear Power Plants," dated July 22, 1993 (58 FR 39132), the NRC addressed the use of Probabilistic Safety Analysis (PSA, currently referred to as Probabilistic Risk Assessment or PRA) in Standard Technical Specifications. In this 1993 publication, the NRC states:

The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria [of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36]1 to be deleted from Technical Specifications based solely on PSA (Criterion 4). However, if the results of PSA indicate that Technical Specifications can be relaxed or removed, a deterministic review will be performed ....

The Commission Policy in this regard is consistent with its Policy Statement on "Safety Goals for the Operation of Nuclear Power Plants," 51 FR 30028, published on August 21, 1986. The Policy Statement on Safety Goals states in part, "* *

probabilistic results should also be reasonably balanced and supported through use of deterministic arguments. In this way, judgments can be made*** about the degree of confidence to be given these [probabilistic] 2 estimates and assumptions. This is a key part of the process for determining the degree of regulatory conservatism that may be warranted for particular decisions.

This defense-in-depth approach is expected to continue to ensure the protection of public health and safety." ...

The Commission will continue to use PSA, consistent with its policy on Safety Goals, as a tool in evaluating specific line-item improvements to Technical Specifications, new requirements, and industry proposals for risk-based Technical Specification changes.

Approximately 2 years later the NRC provided additional detail concerning the use of PRA in the "Final Policy Statement: Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities,"

dated August 16, 1995 (60 FR 42622). In this publication, the NRC states:

The Commission believes that an overall policy on the use of PRA methods in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that would promote regulatory stability and efficiency... In addition, the Commission believes that the use of PRA technology in NRC regulatory activities should be increased to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach ...

PRA addresses a broad spectrum of initiating events by assessing the event frequency. Mitigating system reliability is then assessed, including the potential 1

This clarification is not part of the original policy statement.

2 The Federal Register Notice 58 FR 39135 (Alteration in Original) explains the brackets.

for multiple and common cause failures. The treatment therefore goes beyond the single failure requirements in the deterministic approach. The probabilistic approach to regulation is, therefore, considered an extension and enhancement of traditional regulation by considering risk in a more coherent and complete manner ...

... Therefore, the Commission believes that an overall policy on the use of PRA in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that promotes regulatory stability and efficiency. This policy statement sets forth the Commission's intention to encourage the use of PRA and to expand the scope of PRA applications in all nuclear regulatory matters to the extent supported by the state-of-the-art in terms of methods and data ...

Therefore, the Commission adopts the following policy statement regarding the expanded NRC use of PRA:

1. The use of PRA technology should be increased in all regulatory matters to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

2. PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements, regulatory guides, license commitments, and staff practices. Where appropriate, PRA should be used to support the proposal for additional regulatory requirements in accordance with 10 CFR 50.109 (Backfit Rule). Appropriate procedures for including PRA in the process for changing regulatory requirements should be developed and followed. It is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are revised.

3. PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

4. The Commission's safety goals for nuclear power plants and subsidiary numerical objectives are to be used with appropriate consideration of uncertainties in making regulatory judgments on the need for proposing and backfitting new generic requirements on nuclear power plant licensees.

2.2 Applicable Regulations In 10 CFR 50.36, "Technical specifications," the NRC established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. These categories will remain in the Brunswick TSs.

Paragraph 50.36(c)(3) of 10 CFR states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The FR notice published on July 6, 2009 (74 FR 31996),

which announced the availability of TSTF-425, Revision 3, states that the addition of the SFCP to the TSs provides the necessary administrative controls to require that surveillances frequencies relocated to the SFCP are conducted at a frequency to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The FR notice also states that changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, Revision 1, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and are required to be documented.

Existing regulatory requirements, such as 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants" (i.e., the Maintenance Rule), and 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," require licensee monitoring of surveillance test failures and implementing corrective actions to address such failures. Such failures can result in the licensee increasing the frequency at which a surveillance test is performed. In addition, the SFCP implementation guidance in NEI 04-10, Revision 1, requires monitoring the performance of SSCs for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs.

2.3 Applicable NRC Regulatory Guides and Review Plans RG 1.174, Revision 2, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" (Reference 4), describes an acceptable risk-informed approach for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

RG 1.177, Revision 1, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications" (Reference 5), describes an acceptable risk-informed approach specifically for assessing proposed TS changes.

RG 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities" (Reference 7), describes an acceptable approach for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision making for light-water reactors.

General guidance for evaluating the technical basis for proposed risk-informed changes is provided in NUREG-0800, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Chapter 19, Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance." Guidance on evaluating PRA technical adequacy is provided in SRP, Chapter 19, Section 19.1, Revision 3, "Determining the Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment Requests After Initial Fuel Load," More specific guidance related to risk-informed TS changes is provided in SRP, Chapter 16,

Section 16.1, Revision 1, "Risk-Informed Decisionmaking: Technical Specifications," which includes changes to surveillance test intervals (STls) (i.e., surveillance frequencies) as part of risk-informed decision making. Section 19.2 of the SRP references the same criteria as RG 1.177, Revision 1, and RG 1.174, Revision 2, and states that a risk-informed application should be evaluated to ensure that the proposed changes meet the following key principles:

The proposed change meets the current regulations, unless it explicitly relates to a requested exemption or rule change.

The proposed change is consistent with the defense-in-depth philosophy.

The proposed change maintains sufficient safety margins.

When proposed changes result in an increase in risk associated with core damage frequency (CDF) or large early release frequency (LERF), the increase(s) should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.

The impact of the proposed change should be monitored using performance measurement strategies.

3.0 TECHNICAL EVALUATION

The licensee's adoption of TSTF-425 for Brunswick provides for administrative relocation of applicable surveillance frequencies, and provides for the addition of the SFCP to the administrative controls of TSs. TSTF-425 also requires the application of NEI 04-1 O for any changes to surveillance frequencies within the SFCP. The licensee's application for the changes proposed in TSTF-425 included documentation regarding the PRA technical adequacy consistent with the requirements of RG 1.200. In accordance with NEI 04-10, PRA methods are used, in combination with plant performance data and other considerations, to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is in accordance with guidance provided in RG 1.17 4 and RG 1.177 in support of changes to surveillance test intervals.

3.1 RG 1.177 Five Key Safety Principles RG 1.177 identifies five key safety principles required for risk-informed changes to TSs. Each of these principles is addressed by NEI 04-10. Sections 3.1.1 through 3.1.5 of this safety evaluation contain a discussion of the five principles, including the NRC staffs evaluation of how the licensee's LAR satisfies each principle.

3.1.1 The Proposed Change Meets Current Regulations Paragraph 50.36(c)(3) of 10 CFR states that TSs will include surveillances which are "requirements relating to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." NEI 04-10, Revision 1, provides guidance for relocating the surveillance frequencies from the TSs to a licensee-controlled program by providing an NRG-approved methodology for control of the surveillance frequencies. The surveillances themselves would remain in the TSs, as required by 10 CFR 50.36(c)(3).

This change is consistent with other NRG-approved TS changes in which the surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in

accordance with the lnservice Testing Program or the Primary Containment Leakage Rate Testing Program. Thus, this proposed change meets the current regulations in 10 CFR 50.36.

Further, the NEI 04-1 O guidance provides for monitoring the performance of SSCs for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs. Thus, this proposed change meets the current regulations for monitoring surveillance test failures and implementing corrective actions to address such failures, as cited in 10 CFR 50.65 and 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action."

Thus, this proposed change meets the first key safety principle of RG 1.177 by complying with the current regulations.

3.1.2 The Proposed Change Is Consistent With the Defense-in-Depth Philosophy The defense-in-depth philosophy, the second key safety principle of RG 1.177, is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation.

Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g.,

no risk outliers). Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not impacted.

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed.

Independence of barriers is not degraded.

Defenses against human errors are preserved.

The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained.

TSTF-425 requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. NEI 04-10 uses both the CDF and the LERF metrics to evaluate the impact of proposed changes to surveillance frequencies. The guidance of RG 1.174 and RG 1.177 for changes to CDF and LERF is achieved by evaluation using a comprehensive risk analysis, which assesses the impact of proposed changes including contributions from human errors and common cause failures. Defense-in-depth is also included in the methodology explicitly as a qualitative consideration outside of the risk analysis, as is the potential impact on detection of component degradation that could lead to an increased likelihood of common cause failures.

The NRC staff concludes that both the quantitative risk analysis and the qualitative considerations assure a reasonable balance of defense-in-depth is maintained to ensure protection of public health and safety, satisfying the second key safety principle of RG 1.177.

3.1.3 The Proposed Change Maintains Sufficient Safety Margins The engineering evaluation that will be conducted by the licensee under the SFCP when frequencies are revised will assess the impact of the proposed frequency change to assure that sufficient safety margins are maintained. The guidelines used for making that assessment will include ensuring the proposed surveillance test frequency change is not in conflict with approved industry codes and standards or adversely affects any assumptions or inputs to the safety analysis, or, if such inputs are affected, justification is provided to ensure sufficient safety margin will continue to exist.

The design, operation, testing methods, and acceptance criteria for SSCs, specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the Updated Final Safety Analysis Report and the Bases to TSs), since these are not affected by changes to the surveillance frequencies. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Thus, the NRC staff concludes that safety margins are maintained by the proposed methodology, and the third key safety principle of RG 1.177 is satisfied.

3.1.4 When Proposed Changes Result in an Increase in Core Damage Frequency or Risk, the Increases Should be Small and Consistent with the Intent of the Commission's Safety Goal Policy Statement RG 1.177 provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies. This requires the identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. TSTF-425 requires application of NEI 04-10 in the SFCP. NEI 04-10 satisfies the intent of RG 1.177 requirements for evaluating the change in risk, and for assuring that such changes are small.

3.1.4.1 Quality of the PRA The quality of the licensee's PRA must be commensurate with the safety significance of the proposed TS change and the role the PRA plays in justifying the change. That is, the higher the change in risk or the greater the uncertainty in that risk from the requested TS change, or both, the more rigor that must go into ensuring the quality of the PRA.

RG 1.200 provides regulatory guidance for assessing the technical adequacy of a PRA.

Revision 2 of this RG endorses (with clarifications and qualifications) the use of the following:

(1) American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS)

RA-Sa-2009, "Addenda to ASME RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications" (Reference 8);

(2) NEI 00-02, "PRA Peer Review Process Guidelines" (Reference 9); and (3) NEI 05-04, "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard (Reference 10)." Revision 1 of this RG (Reference 6) had endorsed the internal events PRA standard ASME RA-Sb-2005, "Addenda to ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications" (Reference 11 ).

The licensee has performed an assessment of the PRA models used to support the SFCP using the guidance of RG 1.200, Revision 2, to assure that the PRA models are capable of

determining the change in risk due to changes to surveillance frequencies of SSCs, using plant-specific data and models. Capability Category II of the standard is required by NEI 04-10, Revision 1, for the internal events PRA, and any identified deficiencies to those requirements are assessed further to determine any impacts of proposed decreases to surveillance frequencies, including the use of sensitivity studies where appropriate.

Internal Events and Internal Flooding PRA The licensee submitted in Section 4 of Enclosure 2 to the LAR, the history of peer reviews for the internal events and internal flooding PRA. In 2001, an industry peer review was performed in accordance with the guidance in NEI 00-02 (Reference 9). In 2007 an industry peer review was performed against the 2005 version of the PRA standard, ASME RA-Sb-2005 (Reference 11) and RG 1.200, Revision 1 (Reference 6). In 2010 an industry peer review was conducted against the current version of the PRA standard, ASME/ANS PRA Standard RA-Sa-2009 (Reference 8), and RG 1.200, Revision 2 (Reference 7). This 2010 peer review was a full-scope peer review, as indicated in the Brunswick submittal for transition to the National Fire Protection Association (NFPA) Standard 805 (Reference 19). The results of this peer review superseded those from the 2007 review as it used the latest revisions of both RG 1.200 and the ASME/ANS PRA Standard as endorsed via clarifications and qualifications in Revision 2 of RG 1.200.

Additionally, as provided in supplement dated February 27, 2017 (Reference 18), in 2016 the licensee performed a focused-scope peer review of the internal flooding PRA model against ASME/ANS PRA Standard RA-Sa-2009 as clarified and qualified by RG 1.200, Revision 2. This focused-scope peer review was performed in response to NRC Request for Information (RAI) 2.

RAI 2 was issued because the NRC staff found that a number of internal flooding Findings &

Observations (F&Os) from the 2010 peer review appeared to indicate that the model or documentation were incomplete at the time of the 2010 peer review. Additionally, the NRC staff was unable to fully review licensee's resolution to the F&Os because they relied on references to many plant PRA reports, which were not available for NRC review. The licensee stated that the 2016 focused-scope peer review focused on the internal flooding supporting requirements identified in the F&Os from the 2010 peer review and closed all the internal flooding F&Os from the 2010 peer review (Reference 18).

The licensee provided in the LAR the history of changes to the PRA model of record (MOR) and stated that there were no upgrades to the internal events PRA model performed after the 2010 peer review. The licensee further stated that a review of all permanent plant modifications and engineering changes was performed and that there were no identified permanent plant modifications that have a significant impact on the PRA that have not been incorporated into the MOR.

The NRC staff reviewed the internal events F&Os from the 2010 full-scope peer review provided in the LAR. The NRC staff reviewed the summary of the peer review findings and the licensee's resolution or assessment of the impact on this application to determine whether any gaps in the PRA model were identified that could impact the application and to ensure that any gaps in meeting Capability Category II can be addressed for the SFCP per the NEI 04-10, Revision 1 methodology, and consistent with Revision 2 of RG 1.200.

The licensee stated that all but five internal events findings have been resolved. In Table 1 of to the LAR the licensee submitted the five F&Os that the licensee did not resolve, and in Table 2 submitted the rest of the F&Os. The staff's review of the five unresolved internal

events F&Os is discussed below. Three of them were assessed to have no impact on the application, while the other two can be addressed by the licensee when evaluating the surveillance frequencies:

1. Open F&O 2-3 related to supporting requirement HR-12 questioned the screening values used in the Human Failure Events (HFEs) screening methodology. In response to PRA RAI 18.d for the NFPA-805 application (Reference 20), the licensee clarified that HFEs were not screened out in the internal events PRA and that this F&O concerns a documentation issue related to the assignment of a relatively high screening Human Error Probability (HEP) that was used in identifying those HFEs needing more detailed analysis. Because this F&O affects only the PRA documentation and can be addressed by a minor update to the documentation.

The NRC staff finds this open F&O has no impact on the application.

2. Open F&O 3-12 found supporting requirements LE-C3 met only at Capability Category I.

The peer review team found that the process for identification of recovery and repair actions that can terminate or mitigate the progression of a severe accident was incorporated into the original analysis, rather than performing a review of significant accident progression sequences and then incorporating repair, as required by the supporting requirements. In response to RAI 1.a (Reference 14) the licensee stated that the PRA model credits two recovery actions for LERF consequences: restoring reactor pressure vessel injection and recovering low pressure systems after vessel breach, but before large early releases into the environment. High failure probabilities (0.91 and 0.84) were assigned to these recovery actions because they need to be performed in a short time window. The licensee further explained that the time to failure is scenario-specific and developed from thermal-hydraulic calculations.

The staff finds that the licensee provided appropriate justification for the two credited recovery actions for LERF, as required by supporting requirements LE-C3, and therefore this F&O has no impact on the application.

3. Open F&O 3-12 found supporting requirements LE-C10 and LE-C12 met only at Capability Category I. The peer review team could not find any evidence that significant accident sequences were reviewed to determine if engineering analyses could support continued equipment operation or operator actions that could reduce LERF. In response to RAI 1.b (Reference 14), the licensee stated that no credit for equipment survivability or human actions in adverse environments was taken that would satisfy supporting requirements LE-C 10 or LE-C 12. The NRC staff notes that while not crediting equipment survivability in adverse environments generally would result in a conservative LERF estimate, it could produce a non-conservative estimate of change in LERF when evaluating surveillance frequencies for some SSCs. However, as stated in the F&O, the licensee documented this approach with respect to equipment survivability in its uncertainty analysis.

The NRC staff concludes that the licensee will address and disposition this gap for each surveillance frequency evaluation per the NRC-approved NEI 04-10, Revision 1 methodology, which requires assessment of whether the STI can be adequately characterized by the PRA, refine the PRA model or perform a bounding assessment, and finally, perform sensitivity analyses to ensure that there is not an undue reliance on key assumptions and causes of uncertainty of the open gaps relative to Capability Category II that would impact the results of the assessment.

4. Open F&O 3-13 found supporting requirements LE-C 13 met only at Capability Category I. It stated that "scrubbing by the reactor building is treated in a conservative method." In response to RAI 1.c (Reference 14), the licensee clarified that no credit is taken for scrubbing in the reactor building. The NRC staff notes that while not crediting scrubbing results in a conservative LERF estimate, it could produce a non-conservative estimate for change in LERF when evaluating surveillance frequencies. However as stated in the F&O, the licensee identified this limitation in the uncertainty analysis.

The NRC staff concludes that the licensee will address and disposition this gap for each surveillance frequency evaluation per the NRG-approved NEI 04-10, Revision 1 methodology, which requires assessment of whether the Surveillance Test Interval (STI) can be adequately characterized by the PRA, refine the PRA model or perform a bounding assessment, and finally, perform sensitivity analyses to ensure that there is not an undue reliance on key assumptions and causes of uncertainty of the open gaps relative to Capability Category II that would impact the results of the assessment.

5. Open F&O 6-8 related to supporting requirements SC-C2 was entered because the PRA documentation did not contain a centralized discussion of computer code limitations (e.g.,

potential conservatisms or limitations that could challenge the applicability of computer models in certain cases) as required by the supporting requirements. In response to RAI 1.d (Reference 14) the licensee stated that the PRA documentation specifies the software limitations and provided a list of limitations for the computer codes that were used to establish PRA success criteria.

Since the computer code limitations have been documented, the NRC staff finds that this F&O has no impact on the application.

The resolved internal events F&Os provided by the licensee in Table 2 of Enclosure 2 to the LAR were also reviewed by the staff. (Table 2 also contained F&Os related to internal flooding, which were subsequently closed by the 2016 internal flooding focused-scope peer review.) For the internal events F&Os, not including internal flooding, the staff found that they were adequately dispositioned by the licensee or have no impact on the application. For two of the F&Os the NRC staff requested additional information as discussed below.

1. F&O 1-3 related to supporting requirement IE-C1 was entered because the peer review team found that initiating event frequencies for pipe breaks outside containment were a factor of 100 to 1000 too low. In resolution to this F&O the licensee stated that, as a result of an analysis performed using updated pipe break frequencies, Main Steam Line Break (MSLB) should be included as an initiator. In response to RAI 1.e, as supplemented (Reference 14, 16), the licensee stated that the MSLB initiator is included in the in-process model of record update.

Since the licensee will have included this initiator in its PRA model of record at the time it implements the SFCP, the staff finds that this F&O has no impact on the application.

2. F&O 6-12 related to supporting requirement LE-G5 was entered because the peer review team could not find sufficient documentation on the limitations of the LERF analysis that could impact different applications, as required by the supporting requirement. In response to RAI 1.f, as supplemented (Reference 14, 16), the licensee provided a summary of model uncertainty and limitations of the LERF analysis. The licensee stated that no

non-conservative uncertainties were identified. The licensee also stated that there were no limitations identified that would impact the SFCP because changes in surveillance intervals do not affect the LERF phenomena identified by these limitations.

Because the licensee identified and analyzed the limitations in LERF analysis and concluded that they have no impact on the SFCP, the staff finds the licensee's disposition to this F&O acceptable for the application.

The licensee stated that all the internal flooding F&Os from the 2010 peer review were considered closed, and new F&Os were generated in the recent 2016 peer review of the internal flooding PRA (Reference 18). The 2016 peer review assessed a total of 29 internal flooding supporting requirements, out of which 9 supporting requirements were evaluated as 'Not Met,'

1 supporting requirement met Capability Category I, 9 supporting requirements met Capability Category II with a finding, and finally 10 supporting requirements were assessed to meet Capability Category 11 with no findings. The staff reviewed the 2016 internal flooding F&Os provided in supplement dated February 27, 2017 (Reference 18), to determine whether any gaps in the internal flooding PRA model were identified that could impact the application and to ensure that any gaps in meeting Capability Category II can be addressed for the SFCP. The staff's assessment of the F&Os related to the supporting requirements found 'Not Met' or met at Capability Category I is provided below. For the remainder of the F&Os the staff found that they were adequately dispositioned by the licensee or have no impact on the application.

1. Supporting requirement IFSN-A3 was found 'Not Met' because automatic or operator responses to terminate or contain floods were not identified for the significant sequences, and there were only two operator actions modeled and generally applied to flooding scenarios. In resolution to this F&O the licensee described how it re-analyzed the significant flooding scenarios and developed additional scenario-specific operator actions that would terminate or contain the flood. Because the licensee performed a review of the significant accident sequences and applied scenario-specific operator actions as required by the supporting requirements.

The NRG staff finds the licensee's resolution to this F&O acceptable for the application.

2. Supporting requirements IFSN-A11 and IFEV-A4 were found 'Not Met' because multi-unit floods were not modeled in the PRA. The peer review identified potential multi-unit flood scenarios in the cable spreading rooms and the turbine buildings. In resolution to this F&O the licensee stated that multi-unit flood propagation is modeled for floods originating in one cable spreading room, and propagating to the opposite unit's cable spreading room and to the battery rooms. The licensee further assessed flooding propagation in the turbine buildings, and identified that the shared roll-up door between Unit 1 and Unit 2 turbine buildings could fail, and subsequently updated the PRA to include this scenario. The licensee stated that the model conservatively assumes that any flood in either turbine building that accumulates 4 inches of water on the floor within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months becomes a 3 foot flood in both units.

Because the licensee assessed the potential for multi-unit flood scenarios and updated its PRA model accordingly, the NRG staff finds the licensee's resolution to this F&O acceptable for the application.

3. Supporting requirement IFEV-AS was found 'Not Met' because the frequency of flooding initiating events was not appropriately considered for large pipes. While the licensee

included the frequency of major floods from EPRI TR [Technical Report] 3002000079 (Reference 28), if failed to include the dominant frequency corresponding to non-major floods, which have lower flowrates, but higher frequency of occurrence.

In resolution to this F&O, the licensee updated the flooding initiating event frequencies to include the frequencies for both major and non-major floods. Thus, the NRC staff finds the licensee's resolution to this F&O acceptable for the application.

4. Supporting requirements IFQU-A5 and IFQU-A6 pertaining to Human Reliability Analysis (HRA) were found 'Not Met' because only two flood isolation operator actions were developed and generically applied to multiple scenarios without taking into account scenario-specific timing. In resolution to these F&Os, the licensee stated that it updated the model with scenario-specific HEPs that meet the requirements of the standard and summarized how they were developed, which included consideration for timing, performance shaping factors, dependency analysis, operator interviews, and documentation of all assumptions and bases.

Because the licensee developed scenario-specific operator actions in accordance with the current HRA practices, the NRC staff finds the licensee's resolution to this F&O acceptable for the application.

5. Supporting requirement IFQU-A9 was found 'Not Met' because indirect effects of pipe whip and jet impingement have not been addressed. In resolution to this F&O, the licensee stated that high energy line breaks inside the reactor building and primary containment are screened based on plant design consideration. For SSCs located in the turbine building the licensee concluded, based on a bounding assessment, that pipe whip and jet impingement effects would not impact PRA conclusions under the SFCP.

Because the licensee assessed the impact from pipe whip and jet impingement, the NRC staff finds this F&O has no impact on the application.

6. Supporting requirement IFQU-B1 was found 'Not Met' because the documentation for model quantification and sequence identification did not facilitate peer review, and the cutsets were not sufficiently described. In resolution to this F&O and associated F&Os on supporting requirements IFQU-B2, IFQU-A1 and IFQU-A10 the licensee stated that the model was re-quantified and a cutset review was completed in accordance with the standard, the accident sequences have been reviewed and documented, and descriptions of the top cutsets have been included in the documentation.

Because the licensee performed a review of the sequences and updated the documentation, as required by the supporting requirement, the NRC staff finds the licensee's resolution of this F&O acceptable for the application.

7. Supporting requirement IFQU-B2 was found 'Not Met'. Among other issues, identified also individually in other F&Os, the peer review team identified that the documentation did not justify screening of the flood sources. In resolution to this F&O and associated F&Os IFSN-A15 and IFSN-A16, the licensee stated that documentation was added on the processes used to determine the applicable flooding sequences and on the process for screening flood sources. The licensee stated that it re-performed source screening and documented all the sources that have been screened. To screen maintenance induced

floods, the licensee reviewed on-line preventative maintenance schedule and verified the screening results through interviews with plant operation personnel.

Because the licensee provided justification for source screening and updated the documentation, the NRC staff finds the licensee's resolution of F&Os IFQU-B2, IFSN-A 15 and IFSN-A16 acceptable for the application.

8. Supporting requirement IFEV-A6 was found met only at Capability Category I because the internal flood frequencies were based on generic data, without documentation or justification for not integrating the plant specific experience. In resolution to this F&O the licensee performed a review of the plant operational experience and concluded that the plant-specific experience does not contain any events that impact the generic failure rates.

Because the licensee analyzed the plant specific operational experience and justified the applicability of the generic data, the NRC staff finds the licensee's resolution to this F&O acceptable for the application.

9. The licensee's disposition of impact on the application for certain F&Os (IFSN-A2, IFSN-A 15, IFSN-A 16, IFQU-A 1, and IFQU-A 10) stated that they are limited to documentation only. The staff finds that this disposition is incomplete, because these F&Os appear to not be restricted to documentation only.

However the NRC staff concluded that the issues identified in the F&Os have been adequately addressed by the licensee, as discussed above, and therefore there is no impact on the application.

Fire Probabilistic Risk Assessment The licensee stated in the LAR that the fire PRA was developed using the guidance in NUREG/CR-6850 (Reference 22, 23, 24). As indicated in Reference 21, a full-scope peer review of the fire PRA was conducted in 2012 against the PRA Standard ASME/ANS RA-Sa-2009 and RG 1.200, Revision 2. The licensee stated that 18 supporting requirements were assessed as meeting Capability Category I and 36 supporting requirements were assessed as not met. All other applicable supporting requirements met Capability Category II or better. A focused-scope peer review was also performed between September 2014 and May 2015 for the incorporation of sensitive electronics into the fire PRA in response to NFPA 805 implementation items. The licensee stated that this peer review focused on the technical elements FSS (Fire Scenario Selection and Analysis), IGN (Fire Ignition Frequency}, FQ (Fire Risk Quantification),

and UNC (Uncertainty and Sensitivity Analyses) and found that all applicable supporting requirements within these technical elements were assessed as meeting Capability Category II or better, with no findings.

The F&Os from the 2012 peer review of the fire PRA and their dispositions were provided by the licensee in Table 3 of Enclosure 2 to the LAR. The staff reviewed these F&Os to determine whether any gaps in the fire PRA model were identified that could impact the application and to ensure that any gaps in meeting Capability Category II or being cited as "Met" can be addressed for the SFCP.

The staff's review of the F&Os identified a number of gaps in the fire PRA as discussed below.

The staff concludes that the licensee will address and disposition these gaps for each

surveillance frequency evaluation per the NRG-approved NEI 04-10, Revision 1 methodology, including performing appropriate sensitivity analyses and reviews of the PRA model results.

1. Resolution to F&O 1-36 related to supporting requirements QU-82, QU-F2, QU-83, FQ-81, and FQ-F1 identified that the process for establishing the truncation limits used in the quantification of the fire PRA (1 E-09/year for CDF and 1E-1 O/year for LERF) did not demonstrate that the overall results converge. Because supporting requirement QU-82 was not met the staff asked the licensee to justify the selected truncation levels in the fire PRA.

In response to RAI 4.c, as supplemented (Reference 15, 16), the licensee performed a sensitivity study on truncation levels and showed that lower truncation values are necessary to establish convergence. The licensee stated that the fire PRA that will be used to support the SFCP will establish the appropriate truncation limits to achieve result convergence as required by the supporting requirements.

The NRC staff concludes that the licensee can appropriately address this gap when implementing the SFCP.

2. F&O 2-10 related to supporting requirements QU-E4, UNC-A 1, and PRM-810 identified components assumed failed in the fire PRA and suggested that sensitivity studies should be performed to investigate the risk importance of these failed systems/functions. The resolution to this F&O stated that the assumption of items considered always failed in the fire PRA represents a conservatism in the calculated fire CDF. The NRC staff notes that this assumption may be non-conservative when estimating the increase in CDF or LERF from extending the surveillance frequencies for some SSCs. In response to RAI 4.d (Reference 14) the licensee described how it will use the process in NEI 04-10, Revision 1, in evaluating each surveillance frequency.

The NRC staff concludes that the licensee will address and disposition this gap for each surveillance frequency evaluation per the NRG-approved NEI 04-10, Revision 1 methodology, which requires assessment of whether the STI can be adequately characterized by the PRA, refine the PRA model or perform a bounding risk assessment, and finally, perform sensitivity analyses to ensure that there is not an undue reliance on key assumptions and causes of uncertainty of the open gaps to the Capability Category II that would impact the results of the assessment.

3. F&O 4-1 related to supporting requirement FSS-A 1 identified that the fire PRA uses a severity factor of 0.1 for cabinet breaching factor for well-sealed Motor Control Centers (MCCs). The NRC staff notes that Frequently Asked Question (FAQ) 14-0009 (Reference

26) assigns a breaching factor of 0.23 for well-sealed MCCs above 440 V (if not well-sealed, the breaching factor is always 1.0). In RAI 4.h the staff asked the licensee to confirm that the accepted values for breaching factors will be used in the surveillance frequency calculations. In response to RAI 4.h (Reference 14) the licensee stated that the fire PRA currently does not use a breaching factor of 0.23 for well-sealed MCCs, but the update to the accepted breaching factor values will be addressed through the normal PRA maintenance process. The licensee further stated that until the accepted breaching factor is updated in the fire PRA, it will perform sensitivity calculations with a breaching factor of 0.23 when estimating surveillance frequencies in the SFCP.

Consistent with step 14 of the process described in NEI 04-10, Revision 1, the NRC staff finds that the licensee will address and disposition this gap for each surveillance frequency evaluation by performing sensitivity analyses to ensure that there is not an undue reliance

on key assumptions and causes of uncertainty of the open gaps to the Capability Category II that would impact the results of the assessment.

4. F&O 6-7 related to supporting requirement CF-A1 identified that cable failure probabilities are based on the older Chapter 10 tables in NUREG/CR-6850. The NRC staff asked the licensee to confirm that the updated cable failure probabilities from NUREG/CR-7150 (Reference 27) will be used in the surveillance frequency calculations. In response to RAI 4.m (Reference 14) the licensee stated that the update to the cable failure probabilities is addressed through the normal PRA maintenance process and that these cable failure probabilities will be applied to both the base and the adjusted PRA when calculating change in CDF/LERF in support of the surveillance frequency calculations.

The staff concludes that the licensee will address and disposition this gap for each surveillance frequency evaluation per the NRG-approved NEI 04-10, Revision 1 methodology, through performing appropriate sensitivity analyses and reviews of the PRA model results.

5. F&O 5-16 related to supporting requirements LE-F1, LE-F2, LE-G3, UNC-A1, FQ-E1 and FQ-F1 identified an asymmetry between Unit 1 and Unit 2 with regards to fire LERF results, whereby 98.1 % of the Unit 2 fire LERF is due to fires in the Unit 2 Main Control Room (MCR), vs. approximate 60% contribution from the Unit 1 MCR to the Unit 1 fire LERF. The staff asked the licensee to assess this asymmetry given the updated ignition frequencies for a Main Control Board fire from NUREG-2169 (Reference 25). In response to RAI 4.k (Reference 14) the licensee explained that the unit LERF asymmetries resulted from different cables being routed above different panels. The licensee however stated that the current fire PRA does not use the updated ignition frequencies from NUREG-2169, and that the update to the ignition frequencies will be addressed through the normal PRA maintenance process.

The staff concludes that the licensee will address and disposition this gap for each surveillance frequency evaluation per the NRG-approved NEI 04-10, Revision 1 methodology, through performing appropriate sensitivity analyses and reviews of the PRA model results.

The staff review of the remainder of the F&Os found that they were adequately dispositioned by the licensee or have no impact on the application. The staff requested additional information from the licensee for the F&Os discussed below:

1. F&Os 1-19 and 1-20 related to supporting requirement FSS-A 1 identified that transient fires in the battery rooms were not developed where the transient damages or ignites the batteries. In RAI 4.a the staff asked the licensee to justify the exclusion of batteries as transient fire targets. In response to RAI 4.a, as supplemented (Reference 14, 16), the licensee clarified that transient ignition sources were postulated in the battery rooms, but with impact on the cables, consistent with the methodology in NUREG/CR-6850, Section H.2. The licensee justified that the ignition of batteries themselves does not need to be postulated, since the operating experience does not support a trend of transient fires damaging or igniting batteries.

The NRC staff finds that the licensee appropriately justified the exclusion of batteries as transient fire targets, and therefore these F&Os have no impact on the application.

2. F&O 1-24 related to supporting requirements FSS-B1, HRA-A2, HRA-C1 and HRA-D1 identified that neither the control room evacuation actions nor the local manual actions, which are included in the fire procedure for Unit 1 reactor building north, were reviewed as part of the fire PRA. The licensee's resolution to this F&O stated that possible conservatism associated with not modeling other Alternate Safe Shutdown (ASSD) actions is not considered to be significant. In RAI 4.b the staff asked the licensee to provide justification why not modeling the ASSD actions is not significant for the SFCP. In response to RAI 4.b (Reference 14) the licensee explained that the fire PRA was systematically reviewed to identify both beneficial and detrimental actions which could be relevant to the fire PRA.

Where the beneficial actions were not modeled, the potential credit was considered small. Modeling of the detrimental actions was found unnecessary since the fire PRA already fails equipment whose performance is impacted by fire.

Because the licensee systematically reviewed the actions and determined their impact, the staff finds that this F&O has no impact on the application.

3. F&O 2-19 related to supporting requirement FQ-A 1 identified that some non-conservatism could exist for some Hot Gas Layer (HGL) scenarios (whole room burnout) where the mapping tables appeared to not cover all the components that would be affected by the fire-induced failures. In response to RAI 4.e (Reference 14) the licensee clarified that this F&O described an inconsistency in the mapping tables where an individual ignition source in a room affected more components than a burnout of the whole room. In resolution to this F&O the licensee corrected the mapping tables, which updated the individual ignition source scenarios.

Because the licensee considered both the HGL and the individual ignition source scenarios and updated the fire-induced component failures accordingly, the NRC staff finds that the licensee appropriately addressed this F&O.

4. F&O 2-20 related to supporting requirement FQ-A 1 identified an assumption that cable trays with solid bottoms, which are present above some transformers in the Diesel Generator Basement, will prevent damage to cables for ignition sources with heat release rates (HRRs) of 69 kilowatt (kW) or less based on the discussion provided in section Q.2.2 of NUREG/CR-6850. In RAI 4.f the NRC staff asked the licensee to provide further justification for not assuming damage to these cable trays. In response to RAI 4.f (Reference 14) the licensee explained that the transformers in question are dry (i.e., Bin 23b) and the guidance in NUREG/CR-6850 recommends assuming that a dry transformer HRR is equivalent to that of electric motors, with a 98th percentile HRR of 69 kW. The licensee further stated that a formal rigorous Fire Dynamic Simulator (FDS) analysis of the spray shields was performed that concluded no damage to the cables. This analysis was provided in the plant PRA documentation.

Because the licensee justified the selection of HRR and performed FDS analysis, the NRC staff finds that this F&O has no impact on the application.

5. F&O 3-6 related to supporting requirement SF-A3 noted that common cause failure of gaseous suppression systems was not addressed. The licensee resolution to this F&O justified that there is no potential for common cause failure between the carbon dioxide (C02) system for Unit 1 and the C02 system for Unit 2 because their supplies are separated

by a large open distance. In response to RAI 4.g (Reference 14) the licensee further confirmed that both the piping and the supply tanks are widely separated between units.

The licensee provided adequate justification for excluding common cause failure of gaseous suppression systems between units and therefore the NRC staff finds that this F&O has no impact on the application.

6. F&O 5-4 related to supporting requirements ES-A5, ES-B2, ES-01, and PRM-B9 identified

. six fire-induced spurious events that were screened, but could cause a plant trip (or manual shutdown) and impact equipment that is credited for accident mitigation in the fire PRA. In resolution to this F&O, the licensee stated that five of the six cited initiators would neither cause an automatic plant trip nor require a manual shutdown in less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . For one of the six initiators (draining the reactor pressure vessel through the Scram Discharge Volume vent and drain valves) the licensee stated that it could cause an automatic plant trip or manual shutdown, but it does not introduce a new scenario that is not already modeled.

Furthermore, in response to RAI 4.i (Reference 14) the licensee explained that this assumption has no impact on the initiating event frequencies because these screened spurious operation events are induced by the fire initiating event, and a plant trip is already postulated for every fire.

Because the licensee adequately justified the screening of these fire-induced spurious events, the NRC staff finds that this F&O has no impact on the application.

7. F&O 5-8 related to supporting requirements IGN-A4 and IGN-B4 identified that the bases for excluding Brunswick historical fires related to the heater drain pumps should be strengthened to support the use of generic ignition frequency data. In response to RAI 4.j (Reference 14) the licensee explained that the historical heater drain pumps issue, which was identified in 2000, has been corrected. Pump motors have been replaced and modifications for improved pump cooling and air flow were implemented and there have been no subsequent failures since the pump repair. The licensee concluded that the cause of these previous fire events has been corrected, and therefore these historical events can be excluded, consistent with the guidance in NUREG/CR-6850 for effective correction of a common cause.

Because the licensee adequately justified excluding the heater drain pump fire historical events, the staff finds that this F&O has no impact on the application.

8. Resolution to F&O 6-1 related to supporting requirement CS-B1 identified that three raceways in the Unit 2 electrical equipment room that could not be routed are identified as a source of uncertainty. It further states that the risk associated with the assumed failure of these raceways is "qualitatively addressed as a non-conservative assumption [ ... ] that is likely mitigated in the HGL scenarios by other failures for the respective power supplies." In response to RAI 4.1 as supplemented (Reference 14, 16), the licensee provided both qualitative and quantitative arguments to conclude this assumption has no impact on the SFCP. Qualitatively the licensee discussed how the cables of interest in the three raceways are already included in the target set for HGL scenarios. With regards to the ignition sources, the cables of interest are either already in the Zone of Influence (ZOI) for ignition sources, or are protected by solid bottom cable trays that were credited. Additionally the licensee performed a sensitivity study in which added equipment failure to the affected scenarios and showed no impact on the results.

The licensee adequately justified that the assumption identified in the F&O has no impact on the SFCP; therefore, the staff finds that this F&O has no impact on the application.

High Winds and External Flooding PRA The licensee has PRA models for high winds and external flooding that it will use in the SFCP.

These models were peer reviewed in 2012 against the ASME PRA Standard ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2. The NRC staff reviewed the F&Os from the 2012 peer review submitted in Table 4 of Enclosure 2 to the LAR. The staff reviewed the summary of the findings, the licensee's resolution to the findings, and the licensee's assessment of the impact on this application. The NRC staff assessed these peer review F&Os to ensure that any deficiencies in meeting Capability Category II can be addressed for the SFCP per the NEI 04-10, Revision 1 methodology. For most F&Os the staff found the licensee's resolution submitted in the LAR acceptable for the application. For four F&Os the staff requested additional information, as discussed below:

1. F&O WPR-A5-02 related to supporting requirement WPR-A5 and WPR-A8 was related to human actions considered for increased HEPs due to high winds. This F&O identified that ex-control room actions in areas not impacted by high winds do not need increased HEPs and that some ex-control room actions may have a guaranteed failure due to high winds.

Additionally, F&O WPR-A11-01 identified that the impact of high winds on any credited system recovery should be evaluated. In response to RAI 5.a and 5.b the licensee clarified that the operator actions performed inside Category I buildings (e.g., control room, reactor and turbine buildings) are not assigned increased HEPs because they are not impacted by high winds. Operator actions that would take place in unprotected areas during the first hour of the high wind event are assumed failed. If those actions are to be performed outside Category I buildings after the first hour of the event, the HEP is re-evaluated in conjunction with the adjusted equipment failure due to high winds.

Based on the licensee's justification on how it addressed the concerns in these F&Os, the staff finds they have no impact on the application.

2. F&O WPR-B2-01 related to supporting requirement WPR-B2 found that the uncertainties in each of the inputs and for all important dependencies and correlations have not been assessed, as required by the supporting requirement. In response to RAI 5.c, the licensee confirmed that the uncertainties due to all important dependencies and correlations have been assessed and documented.

The NRC staff finds that this F&O has been adequately dispositioned for the application.

3. F&O WPR-C3-01 related to supporting requirement WPR-C3 was entered because the sources of uncertainty and assumptions were not identified as required by the supporting requirements. In response to RAI 5.d, as supplemented (Reference 14, 16), the licensee described the sources of uncertainty and assumptions and stated that the change in risk for each STI considered in the SFCP will be assessed for the impact of the identified uncertainties in the high winds analysis.

Because the licensee identified the sources of uncertainty and will assess the impact of these uncertainties for each surveillance frequency evaluation, consistent with the process

described in NEI 04-10, Revision 1 the NRC staff finds that this F&O has no impact on the application.

Based on the licensee's assessments using the currently applicable PRA standard and revision of RG 1.200, the NRC staff concludes that the level of PRA quality, combined with the proposed evaluation and disposition of gaps, will be sufficient to support the evaluation of changes proposed to surveillance frequencies within the SFCP, and is consistent with Regulatory Position 2. 3. 1 of RG 1. 177.

3.1.4.2 Scope of the Probabilistic Risk Assessment The licensee is required to evaluate each proposed change to a relocated surveillance frequency using the guidance contained in NEI 04-10 to determine its potential impact on risk (CDF and LERF) from internal events, fires, seismic, other external events, and shutdown conditions. In cases where a PRA of sufficient scope or quantitative risk models were unavailable, the licensee uses bounding analyses, or other conservative quantitative evaluations. A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero.

Brunswick has full-power internal events, internal floods, as well as internal fire, high winds and external flooding PRA models. These models received peer reviews as discussed above in Section 3.1.4.1 of this safety evaluation. In accordance with NEI 04-10, Revision 1, the licensee will use these models to perform quantitative evaluations to support the development of changes to surveillance frequencies in the SFCP. This is acceptable because the NRG-approved methodology in NEI 04-10, Revision 1, allows for more refined analysis to be performed to support changes to surveillance frequencies in the SFCP.

Brunswick does not have PRA models for seismic events and transportation and nearby facility accidents, which were assessed in the Individual Plant Examination of External Events (IPEEE).

The IPEEE used Seismic Margin Analysis (SMA) to assess seismic risk. The licensee recently completed a seismic hazard evaluation and screening in response to Fukushima Dai-ichi accident (Reference 29, 30). The licensee stated that the results of this evaluation have shown that the SMA is adequate to support screening of the updated seismic hazard for Brunswick and that the risk insights obtained from the SMA are still valid under the current plant configuration.

The licensee will use the SMA to assess seismic risk for the SFCP. Potential accidents associated with nearby air traffic, runways, roads, railways, waterways, pipelines, and fixed military and industrial facilities were not considered a significant hazard in the IPEEE studies. In response to RAI 7 the licensee confirmed that based on more recent studies there were no significant changes to the plant site and surrounding areas that could invalidate the IPEEE conclusion with regards to potential accidents associated with nearby air traffic, runways, roads, railways, waterways, pipelines, and fixed military and industrial facilities. In accordance with NEI 04-10, Revision 1, the licensee can perform an initial qualitative screening analysis, and, if the qualitative information is not sufficient to provide confidence that the net impact of the STI change would be negligible, a bounding analysis will be performed. The bounding analysis will be performed in accordance with Step 10b of NEI 04-10, Revision 1. This is an acceptable approach in accordance with NEI 04-10, Revision 1.

The licensee stated that for assessing the shutdown risk, the shutdown risk management program for implementation of NUMARC 91-06 will be used for the proposed changes to surveillance frequencies under the SFCP. This is an acceptable approach in accordance with NEI 04-10, Revision 1.

Thus, the staff concludes that through the application of NRG-approved NEI 04-10, Revision 1, the licensee's evaluation methodology is sufficient to ensure the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation, and is consistent with Regulatory Position 2.3.2 of RG 1.177.

3.1.4.3 Probabilistic Risk Assessment Modeling The licensee's methodology includes the determination of whether the SSCs affected by a proposed change to a surveillance frequency are or can be modeled in the PRA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact is carried out.

The methodology adjusts the failure probability of the impacted SSCs, including any impacted common cause failure modes, based on the proposed change to the surveillance frequency.

Where the SSC cannot be modeled in the PRA, bounding analyses are performed to characterize the impact of the proposed change to the surveillance frequency. Potential impacts on the risk analyses due to screening criteria and truncation levels are addressed by the requirements for PRA technical adequacy consistent with guidance contained in RG 1.200, and by sensitivity studies identified in NEI 04-10.

Thus, the NRC staff concludes that through the application of NEI 04-10, the Brunswick PRA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with Regulatory Position 2.3.3 of RG 1.177.

3.1.4.4 Assumptions for Time Related Failure Contributions The failure probabilities of SSCs modeled in PRAs may include a standby time-related contribution and a cyclic demand-related contribution. NEI 04-10, Revision 1, criteria adjust the time-related failure contribution of SSCs affected by the proposed change to a surveillance frequency. This is consistent with RG 1.177, Section 2.3.3, which permits separation of the failure rate contributions into demand and standby for evaluation of surveillance requirements.

Further, consistent with the guidance, the licensee states in Enclosure 2 to the LAR that if the breakdown between the standby time-dependent failure rate and the demand-related failure rate probability for affected SSCs is unknown, then the total failure probability will be assumed to be time-related to obtain the maximum test-limited risk condition. The SSC failure rate (per unit time) is assumed to be unaffected by the change in test frequency, such that the failure probability is assumed to increase linearly with time, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is implemented. The process requires consideration of qualitative sources of information with regards to potential impacts of test frequency on SSC performance, including industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test intervals. Thus the process is not reliant upon risk analyses as the sole basis for the proposed changes.

The potential benefits of reduced surveillance frequency, including reduced downtime, lesser potential for restoration errors, reduction of potential for test caused transients, and reduced test-caused wear of equipment, are identified qualitatively, but not quantitatively assessed.

Thus, through the application of NEI 04-10, Revision 1, the licensee has employed reasonable assumptions with regard to extensions of surveillance test intervals, and is consistent with Regulatory Position 2.3.4 of RG 1.177.

3.1.4.5 Sensitivity and Uncertainty Analyses NEI 04-10, Revision 1, requires sensitivity studies to assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact on the frequency of initiating events, and any identified deviations from Capability Category II of the PRA standard. Where the sensitivity analyses identify a potential impact on the proposed change, revised surveillance frequencies are considered, along with any qualitative considerations that may bear on the results of such sensitivity studies. Required monitoring and feedback of SSC performance once the revised surveillance frequencies are implemented will also be performed. Thus, through the application of NEI 04-10, the licensee has appropriately considered the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations, and is consistent with Regulatory Position 2.3.5 of RG 1.177.

3.1.4.6 Acceptance Guidelines The licensee will quantitatively evaluate the change in total risk (including internal and external events contributions) in terms of GDF and LERF for both the individual risk impact of a proposed change in surveillance frequency and the cumulative impact from all individual changes to surveillance frequencies using the guidance contained in NRG approved NEI 04-10, Revision 1, in accordance with the TS SFCP. Each individual change to surveillance frequency must show a risk increase below 1E-6 per year for GDF, and below 1E-7 per year for LERF. These are consistent with the acceptance criteria of RG 1.17 4 for very small changes in risk. Where the RG 1.174 acceptance criteria are not met, the process either considers revised surveillance frequencies which are consistent with RG 1.174 or the process terminates without permitting the proposed changes. Where quantitative results are unavailable for comparison with the acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible. Otherwise, bounding quantitative analyses are required that demonstrate the risk impact is at least one order of magnitude lower than the RG 1.174 acceptance guidelines for very small changes in risk. In addition to assessing each individual SSC surveillance frequency change, the cumulative impact of all changes must result in a risk increase less than 1E-5 per year for GDF, and less than 1E-6 per year for LERF, and the total GDF and total LERF must be reasonably shown to be less than 1E-4 per year and 1E-5 per year, respectively. These are consistent with the acceptance criteria of RG 1.174, as referenced by RG 1.177 for changes to surveillance frequencies.

Consistent with the NRC's safety evaluation dated September 19, 2007, for NEI 04-10, Revision 1, the TS SFCP will require the licensee to calculate the total change in risk (i.e., the cumulative risk) by comparing a baseline model that uses failure probabilities based on surveillance frequencies prior to being changed per the SFCP to a revised model that uses failure probabilities based on the changed surveillance frequencies. The staff further notes that NEI 04-10, Revision 1, includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (less than 5E-8 GDF and 5E-9 LERF) once the baseline PRA models are updated to include the effects of the revised surveillance frequencies.

The quantitative acceptance guidance of RG 1.174 is supplemented by qualitative information to evaluate the proposed changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, and industry standards, or at least bounding, quantitative results of sensitivity studies and SSC performance data and test history.

The final acceptability of the proposed change is based on all of these considerations and not solely on the PRA results. Post implementation performance monitoring and feedback are also required to assure continued reliability of the SSC's. The licensee's application of NEI 04-10 provides acceptable methods for evaluating the risk increase associated with proposed changes to surveillance frequencies, consistent with Regulatory Position 2.4 of RG 1.177. Therefore, the proposed methodology satisfies the fourth key safety principle of RG 1.177 by assuring any increase in risk is small consistent with the intent of the Commission's Safety Goal Policy Statement.

3.1.5 The Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-425 requires application of NEI 04-10 in the SFCP. NEI 04-10 requires performance monitoring of SSCs whose surveillance frequency has been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of maintenance rule monitoring of equipment performance. In the event of degradation of SSC performance, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may apply as part of the maintenance rule requirements. The performance monitoring and feedback specified in NEI 04-10 is sufficient to reasonably assure acceptable SSC performance and is consistent with Regulatory Position 3. 2 of RG 1.177. Thus, the fifth key safety principle of RG 1.177 is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee proposed including the SFCP and specific requirements into the Brunswick TSs, Section 5.5.14, as follows:

Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure that the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

The proposed program is consistent with the model application of TSTF-425 and, therefore, the staff concludes that it is acceptable.

3.3 Deviations from TSTF-425 and Other Changes The definition of STAGGERED TEST BASIS is being retained in the Brunswick TS due to its continued use in Administrative TS Section 5.5.13, "Control Room Envelope Habitability Program," for each unit. Since this defined term is still used elsewhere in the TSs it is required to remain in the TS according to the NUREG-1433 guidance. This is an administrative deviation and the staff recognizes that the definition should be retained for the reason stated; therefore, this deviation is acceptable.

NRC letter dated April 14, 2010 (i.e., Agencywide Documents Access and Management System (ADAMS) Accession No. ML100990099), provided a change to an optional insert (Insert #2) to the existing TS Bases to facilitate adoption of the Traveler. The changes as proposed for this LAR are described on page 2 of 4 of Enclosure 1 of the original LAR. The NRC staff reviewed the changes and determined that they are consistent with NRC approved TSTF-425, Revision 3, and the Commission's final policy statement on TS as published in the FR on July 22, 1993 (55 FR 39132). The NRC staff has determined that these changes are consistent with NRC approved TSTF-425 and should be processed by the licensee in accordance with each unit's TS 5.5.10, "Technical Specification Bases Control Program."

Brunswick TSs contain some SRs that differ in the identifying number from those contained in the approved traveler TSTF-425, Revision 3. The NRC staff reviewed each SR and determined that these are administrative deviations only with no impact on the conclusions reached in the NRC's model Safety Evaluation dated July 6, 2009 (74 FR 31996) and are therefore acceptable.

There are surveillances included in TSTF-425 that are not included in the Brunswick TSs.

Additionally Brunswick has SRs that are not included in the NUREG-1431 guidance. TSTF-425 transfers control of frequencies for existing surveillances to a licensee established and controlled Surveillance Frequency Control Program (SFCP) at TS 5.5.14. The NRC staff reviewed each change proposed in the original LAR and the supplements to verify that the content of the surveillance actions themselves will remain in the TSs and that the licensee's program does not add, delete, or modify the TS SRs. The amendments, for Brunswick, represent plant-specific adoption of TSTF-425, Revision 3, and they relocate only existing fixed periodic surveillance frequencies for existing surveillances in the Brunswick Units 1 and 2 current TSs. This is consistent with the Commission's final policy statement on TSs as published in the FR on July 22, 1993 (55 FR 39132) and will ensure that the Brunswick SRs will continue to meet 10 CFR 50.36( c)(3). Thus, the NRC staff finds these deviations from the TSTF traveler approved mark-ups acceptable.

In an RAI dated November 11, 2016, the NRC staff asked whether the entire frequency of SR 3.3.1.2.4 could be relocated to the licensees proposed SFCP since the first part of the frequency, "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during CORE ALTERATIONS," appeared to meet one of the four exclusion criteria of part 2.0 of the approved TSTF-425, Revision 3 traveler as a "frequency that is related to a specific condition ... " SR 3.3.1.2.4 pertains to the state of the source range nuclear instruments that are monitored from the control room.

On November 17, 2016 (Reference 17), the licensee responded that no specific guidance was found that defines a frequency that is related to a specific condition. However, the licensee's response did not appear to be consistent with an information response from the TSTF on January 17, 2008 (i.e., ADAMS Accession No. ML080280272) regarding station batteries.

In NUREG-1433 SR 3.8.6.6, and NUREG-1434 SR 3.8.6.6, TSTF-425 will relocate the 12-month and 24-month surveillance frequencies associated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity. This is inconsistent with the proposed changes to similar SRs in NUREG-1430, NUREG-1431, and NUREG-1432, which would only relocate the 60-month frequency associated with non-degraded batteries. The staff considers the specific conditions of battery degradation, age, and capacity as not within the scope of NEI 04-10. Provide a revision to TSTF-425 which retains, in NUREG-1433 and NUREG-1434, the SRs for degraded or old batteries.

The RAI response of January 17, 2008, from the TSTF did address the fact that certain frequencies concerning station batteries indicated a different frequency based on the specific degradation level component of concern. The licensee further explained that unlike that RAI from the TSTF, the qualifier on the 12-hour frequency for SR 3.3.1.2.4 is not related to a specific condition (i.e., state) of the components to be tested. The qualifier only affected the frequency and, therefore, the frequency did not meet the TSTF-425 exception.

The NRC staff reviewed the licensee's response and agrees with the licensee's reasoning that the SR frequency is not related to the condition of the component to be tested. Since SRs exist in part to ensure that " ... the necessary quality of systems and components is maintained ... " as stated in 10 CFR 50.36(c)(3) the NRC staff agrees with the licensee assessment that this SR frequency does not meet the TSTF-425 exception. Therefore, the relocation of the entire frequency of SR 3.3.1.2.4 for Brunswick Units 1 and 2 is acceptable.

Brunswick included SR 3.1.2.1, which was not included in the approved traveler TSTF-425 Revision 3. The licensee stated that the frequency of SR 3.1.2.1 is encompassed by the intent of TSTF-425 Revision 3, and therefore was within the scope of the NRC model safety evaluation (ADAMS Accession No. ML091800157). The licensee further stated that the NUREG-1433 markups within TSTF-425 include a similar core exposure based frequency in SR 3.3.1.1.6. During the NRC review of TSTF-425, Revision 1, an information response from the TSTF (ADAMS Accession No. ML080280272) specifically identified frequencies based on core exposure to be within the scope of TSTF-425 and NEI 04-10. Therefore, the NRC staff recognizes Brunswick SR 3.1.2.1 to be within scope of approved traveler TSTF-425, Revision 3 for the reasons stated and, therefore, accepts the markup of SR 3.1.2.1 proposed in the original LAR submittal letter dated December 21, 2015.

3.4 Summary and Conclusions The NRC staff has reviewed the licensee's proposed relocation of specific surveillance frequencies to a licensee-controlled document, and controlling changes to these surveillance frequencies in accordance with a new program, the SFCP, identified in the Administrative Controls of TSs. The NRC staff confirmed that the amendments do not relocate surveillance frequencies that reference other approved programs for the specific interval, are purely event-driven, are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs, or are related to specific conditions. The SFCP and TS Section 5.5.14 reference NEI 04-10, Revision 1, which provides a risk-informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TSs to a licensee-controlled document, provided those frequencies are changed in accordance with NEI 04-10, Revision 1, which is specified in the Administrative Controls section of the TSs.

The licensee's proposed adoption of TSTF-425, Revision 3, and risk-informed methodology of NRG-approved NEI 04-10, Revision 1, as referenced in the Administrative Controls section of TSs, satisfies the key principles of risk-informed decision making applied to changes to TSs as delineated in RG 1.177 and RG 1.174, in that:

The proposed change meets current regulations;

The proposed change is consistent with defense-in-depth philosophy;

The proposed change maintains sufficient safety margins;

Increases in risk resulting from the proposed change are small and consistent with the Commission's Safety Goal Policy Statement; and

The impact of the proposed change is monitored with performance measurement strategies.

The regulatory requirements in 10 CFR 50.65, and 10 CFR Part 50, Appendix B, Criterion XVI, and the performance monitoring required by NEI 04-10, Revision 1, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied and that any performance deficiencies will be identified and appropriate corrective actions taken. The staff concludes the licensee's SFCP ensures that SRs specified in the TSs are performed at intervals sufficient to assure the above regulatory requirements are met.

Based on the above evaluation, the NRC staff concludes that, with the proposed relocation of surveillance frequencies to a licensee-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet the requirements in 10 CFR 50.36(c)(3), 10 CFR 50.65, and 10 CFR Part 50, Appendix B, Criterion XVI.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments on April 27, 2017. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (81 FR 17504, March 29, 2016).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b," March 18, 2009 (ADAMS Accession No. ML090850642).

2. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 58, Risk-Informed Method for Control of Surveillance Frequencies," April 2007 (ADAMS Accession No. ML071360456).

3. Final Safety Evaluation for Nuclear Energy Institute Topical Report 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 58, Risk-Informed Method for Control of Surveillance Frequencies," September 19, 2007 (ADAMS Accession No. ML072570267).

4. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 2, May 2011 (ADAMS Accession No. ML100910006).

5. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," Revision 1, May 2011 (ADAMS Accession No. ML100910008).

6. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1, January 2007 (ADAMS Accession No. ML070240001 ).

7. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 2, March 2009 (ADAMS Accession No. ML090410014).

8. ASME/ANS PRA Standard ASME/ANS RA-Sa-2009, Addenda to ASME RA-S-2008, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications."

9. NEI 00-02, Revision 1 "Probabilistic Risk Assessment (PRA) Peer Review Process Guidance," Revision 1, May 2006 (ADAMS Accession No. ML061510621).

10. NEI 05-04, "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard," Revision 0, August 2006.

11. ASME PRA Standard ASME RA-Sb-2005, Addenda to ASME RA-S-2002, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications."

12. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Risk-informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," December 21, 2015 (ADAMS Accession No. ML16004A249).

13. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Supplement to Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," dated June 29, 2016 (ADAMS Accession No. ML16196A240).

14. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding License Amendment Request for Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," July 13, 2016 (ADAMS Accession No. ML16209A225).

15. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding License Amendment Request for Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," August 15, 2016 (ADAMS Accession No. ML16238A152).

16. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Clarification of Responses for Request for Additional Information [Re.] License Amendment Request for Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," November 1, 2016 (ADAMS Accession No. ML16321A406).

17. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding License Amendment Request for Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program, November 17, 2016 (ADAMS Accession No. ML16348A548).

18. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Supplement - License Amendment Request Regarding Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program, February 27, 2017 (ADAMS Accession No. ML17059C189).

19. Annacone, Michael J., Carolina Power and Light Company, letter to U.S. Nuclear Regulatory Commission, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2, Docket Nos. 50-325, 50-324, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), September 25, 2012 (ADAMS Accession No. ML12285A428).

20. Hamrick, George T., Duke Energy Progress, Inc., letter to U.S. Nuclear Regulatory Commission, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2, Docket Nos. 50-325, 50-324, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805," July 15, 2013 (ADAMS Accession No. ML13205A016).

21. Hon, Andrew, U.S. Nuclear Regulatory Commission, letter to Gideon, William R., Duke Energy, "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (TAC Nos. ME9623 and ME9624)," January 28, 2015 (ADAMS Accession No. ML14310A808).

22. U.S. Nuclear Regulatory Commission, NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Volume 1: Summary and Overview,"

September 2005 (ADAMS Accession No. ML052580075).

23. U.S. Nuclear Regulatory Commission, NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Volume 2: Detailed Methodology,"

September 2005 (ADAMS Accession No. ML052580118).

24. U.S. Nuclear Regulatory Commission, NUREG/CR-6850, Supplement 1, "Fire Probabilistic Risk Assessment Methods Enhancements," September 2010 (ADAMS Accession No. ML103090242).

25. U.S. Nuclear Regulatory Commission, NUREG-2169, "Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database," January 2015 (ADAMS Accession No. ML15016A069).

26. Frequently Asked Question (FAQ) 14-0009, "Treatment of Well-Sealed Electrical Panels Greater than 440V," Revision 1, October 2014 (ADAMS Accession No. ML15118A810).

27. U.S. Nuclear Regulatory Commission, NUREG/CR-7150, "Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE)," October 2012 and May 2014 (ADAMS Accession Nos. Volume 1: ML12313A105 and Volume 2:

ML14141A129).

28. EPRI TR-3002000079, "Pipe Rupture Frequencies for Internal Flooding Probabilistic Risk Assessments," Revision 3, April 2013.

29. Vega, Frankie G., U.S. Nuclear Regulatory Commission letter to Gideon, William R.,

Duke Energy, "Brunswick Steam Electric Plant, Units 1 and 2 - Staff Assessment of Information Provided Pursuant to Title 1O of the Code of Federal Regulations Part 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (CAC Nos.

MF3824 and MF3825)," March 1, 2016 (ADAMS Accession No. ML16041A435).

30. Gideon, William R., Duke Energy, letter to U.S. Nuclear Regulatory Commission, "Individual Plant Examination of External Events (IPEEE) Supplement to Seismic Hazard Screening Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," December 15, 2016 (ADAMS Accession No. ML16365A023).

Principal Contributors: M. Biro P. Snyder Date of issuance: May 24, 2017

ML17096A129

By Memo ML17076A380, +

By Memo ML16336A834

B*v E-ma1*1 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DRA/APLA/BC# DSS/S BP B/BC* DE/El CB/BC NAME AH on BClayton SRosenberg RDennig MWaters DATE 5/12/2017 5/12/2017 3/30/2017 5/2/2017 4/28/2017 OFFICE DE/EE EB DE/EE EB DE/EEEB DE/EEEB DE/EEEB/BC NAME SRay RMathew SMatharu TMartinez-Navedo JZimmerman (non-concur) (non-concur) (non-concur) (non-concur) (non-concur)

DATE OFFICE DSS/SRXB/BC* DSS/STSB/BC+ OGC- NLO DORL/LPL2-2/BC DORL/LPL2-2/PM NAME EOesterle AKlein AGhosh BBeasley A Hon DATE 4/10/2017 12/5/2016 5/11/2017 5/22/2017 5/24/2017

v t e Letter Sequence Approval
CAC:MF7206, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed) CAC:MF7207, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed)
Initiation Request, Request Acceptance... Supplement, Supplement Administration Questions 15 June 2016 28 July 2016 14 November 2016 Answers 15 August 2016 17 November 2016 13 July 2016 Results Approval Other:
MONTHYEAR2016-06-15 [Table View]

ML17096A129

Text

SUBJECT:

Dear Mr. Gideon:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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