Text

Proposed Tech Specs 3.8.1 & 3.8.7 Re Balance of Plant/ Emergency Bus Allowable Outage Time Extension
	ML20153D879
Person / Time
Site:	Brunswick
Issue date:	09/14/1998
From:	; CAROLINA POWER & LIGHT CO.
To:	;
Shared Package
ML20153D876	List: BSEP-98-0172, Forwards Addl Info Re Balance of Plant/Emergency Bus AOT Extension,Discussion of Changes to ITS 3.8.1,L.15 & 3.8.7, L.2 and Units 1 & 2 ITS Section 3.8 & Bases; ML20153D879;
References
	TAC-M97243, TAC-M97244, NUDOCS 9809250229
	Download: ML20153D879 (200)
	v • d • e

ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 ADDITIONAL INFORMATION REGARDING BALANCE OF PLANT / EMERGENCY BUS ALLOWABLE OUTAGE TIME EXTENSION (NRC TAC NOS. M97243 AND M97244)

DISCUSSION OF CIIANGES ITS 3.8.1, L.15 AND 3.8.7, L.2 9809250229 980914 PDR ADOCK 05000324<

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DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.14 requirement of ITS SR 3.8.1.7 must met. In addition, other (cout'd) Technical Specification DG starting requirements are adequate to ensure that the DGs are capable of starting within the required time period. As a result, adequate assurance of DG OPERABILITY will continue to provided by the Technical Specifications, while degradation resulting from fast start testing will be minimized.

L.15 With one or both units operating (in MODE 1, 2, or 3) and two offsite circuits inoperable, CTS 3.8.1.1 ACTION d requires restoration of one of the offsite circuits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and restoration of the remaining inoperable offsite circuit within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . B0P buses ID, IC, 20, and 2C supply 4.16 kV emergency buses El, E2, E3, and E4, respectively. Each of the BOP buses is b

supplied from two physically independent circuits to the offsite transmission network. Consequently, removing one of the BOP buses from service results in the loss of both sources of offsite power to the downstream emergency power system load group. Therefore, with one or both units operating, CTS 3.8.1.1 ACTION d is required to be entered. ITS 3.8.1 ACTION 8 provides a 7 day Allowed Outage Time (A0T) for restoration of two inoperable opposite unit offsite circuits made inoperable for planned maintenance due to one inoperable opposite unit BOP circuit path to the downstream b

4.16 kV emergency bus and the DG associated with the affected downstream 4.16 kV emergency bus (made inoperable in order to do 8

concurrent planned maintenance on the associated 4.16 kV emergency bus). In addition, a maximum Completion Time of 10 days from d

discovery of failure to meet LC0 3.8.1.a or b is also provided for consistency with the changes described in comment L.3. This 7 day b

A0T is only applicable for planned maintenance if the opposite unit is in MODE 4 or 5. If the opposite unit is in MODE 1, 2, or b

3, the ACTIONS of ITS 3.8.1 for the opposite unit would require -

entry into LCO 3.0.3 for this condition. In addition, ITS 3.8.1 Required Action B.1 will require declaring required feature (s) )

with no offsite power available inoperable when the redundant required feature (s) are inoperable. The completion Time for this Required Action is immediately from discovery of Condition B concurrent with the inoperability of redundant required feature (s). Also to ensure that the remaining offsite circuits remain OPERABLE during this time period, it is necessary to verify the availability of the remaining offsite circuits more frequently b

than the normal Surveillance Frequency. Therefore, ITS 3.8.1 Required Action B.2 is provided to verify the availability of the remaining OPERABLE offsite circuits by the performance of ITS 4

SR 3.8.1.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter.

The BNP Units 1 and 2 Class IE AC Electrical Power Distribution System is divided into four load groups. Each load group consists of a primary emergency bus, its downstream secondary emergency bus,120 VAC vital bus, and transformers and interconnecting .

cables. The buses associated with each of the four load groups !

are defined as follows:

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BNP UNITS 1 & 2 16 Revision 0 I

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l DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING I

l TECHNICAL CHANGES - LESS RESTRICTIVE t

L.15 Load group El consists of 4.16 kV bus El, 480 V bus ES, and

(cont'd) 120 VAC vital bus IES.-

Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus IE6.

. Load group E3 consists of 4.16 kV bus E3, 480 V bus E7, and

! 120 VAC vital bus 2E7.

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Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8.

The El and E2 load groups are supplied from Unit 1 balance of !

l plant (BOP) buses 10 and IC, respectively, and primarily serve 1 Unit 1 loads. The E3 and E4 load grcups are supplied from Unit 2 80P buses 20 and 2C, respectively, and primarily serve Unit 2 loads. In some instances loads associated with one unit are i actually supplied from the opposite unit's load group buses.

Each primary emergency bus (4.16 kV escr3ency bus) has access to two offsite sources of power via a common circuit path from its associated upstream B0P bus (master and slave breakers and interconnecting cables). In addition each 4.16 kV emergency bus A can be provided power from an onsite diesel generator (DG) source. 2 The upstream B0P bus associated with each 4.16 kV emergency bus is normally conne'ted c to the main generator output via the unit auxiliary transformer. During a loss of the normal power source to the 4.16 kV B0P bus, the preferred source supply breaker attempts to close. If all offsite sources are unavailable, the affected 4.16 kV emergency bus is isolated from its associated upstream 4.16 kV B0P bus and the onsite emergency DG will supply power to the 4.16 kV emergency bus. Control power for each 4.16 kV emergency bus is supplied from a Class IE battery with manual transfer capability to another Class IE battery.

The secondary plant distribution system includes 480 VAC emergency buses E5, E6, E7, and E8 and associated motor control centers (MCCs), transformers, and interconnecting cables. Secondary emergency buses E5, E6, E7, and E8 are supplied from primary emergency buses El, E2, E3, and E4, respectively. Control power for each 480 VAC emergency bus is supplied from a Class IE battery with manual transfer capability to another Class IE battery.

The 120 VAC vital buses IES. IE6, 2E7, and 2E8 are arranged in four load groups and are powered from secondary emergency buses E5, E6, E7, and E8, respectively.

j BNP UNITS 1 & 2 17 Revision 0

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.15 Since loads associated with one unit are actually supplied from (cont'd) the opposite unit's load group buses, loss of an emergency bus associated with a shutdown unit, through de-energization of the associated BOP bus, affects some loads credited for support of systems used for mitigation of accidents and transients on the b

operating unit.

The CTS 3.8.1.1 A0T does not provide sufficient time to perfom adequate planned maintenance on the BOP buses and buses of the 1 associated AC Electrical Power Distribution System load groups. C Planned maintenance on the shutdown unit's electrical buses cannot be performed because the LCO still applies to the operating unit.

Hence, dual unit catages are required in order to perform this maintenance. Future dual unit outages are no longer planned for the BNP units. Therefore, a 7 day A0T is provided for the subject BOP buses consistent with the 7 day A0T provided for the associated AC Electrical Power Distribution System load groups (addressed in comment L.2 for ITJ 3.8.7). This A0T would only apply to BOP buses associated with the shutdown unit and would allow de-energization of only one balance-of-plant bus at a time.

De-energization of both a B0P bus (which results in two inoperable offsite circuits) and its associated downstream emergency power system load group are expected to occur concurrently under ,

ITS 3.8.1 ACTION B and ITS 3.8.7 ACTION A. (This condition also '

results in the associated DG becoming inoperable.) To preclude ;

de-energization of a B0P bus and an emergency power system load j group supplied from a different B0P bus for the 7 day period, i ITS 3.8.1 Required Action B.1 is added. ITS 3.8.1 Required Action B.1 requires declaring required feature (s) with no offsite

' power available inoperable when the redundant required feature (s) are inoperable. The Completion Time for this Required Action is A immediately from discovery of Condition B concurrent with the inoperability of redundant required feature (s). Should 80P buses associated with any other Unit 1 or Unit 2 emergency power system load group be lost concurrent with the planned B0P bus outage, the current 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months A0T (ITS 3.8.1 ACTION E) would apply.

The proposed A0T for the B0P buses is acceptable for the following reasons:

1) The most restrictive requirement for restoring a BOP bus is the need to restore offsite power to the emergency buses.

Hence, A0Ts for the 4.16 kV BOP buses are limited by the downstream buses cf the AC Electrical Power Distribution System which they supply. Increasing the A0T to 7 days for '

restoration of one inoperable AC electrical power distribution division load group primarily associated with the shutdown unit is acceptable for the following reasons:

BNP UNITS 1 & 2 18 Revision 0

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING I

TECHNICAL CHANGES --LESS RESTRICTIVE l L.15 a) Operation with only three AC Electrical Power l (cont'd) Distribution System load groups is already enveloped l by the existing accident analysis which considers a l

' LOCA/ LOOP on one unit and a safe shutdown of the other l unit concurrent with the worst-case single failure l- (e.g., loss of one DG). As part of the outage l planning and risk assessment, outage planning will ensure the OPERABILITY of required redundant Technical Specification equipment on the other three load groups of the AC Electrical Power Distribution System prior to removing a shutdown unit's load group from service. '

In addition, the requirements of ITS 5.5.11 " Safety Function Determination Program," will ensure that any concurrent inoperabilities that result in a loss of j l safety function do not exist (since the Technical l

! Specification for the supported systems would not allow a 7 day A0T when a loss of safety function exists). ,

b) The proposed A0T for the inoperable AC Electrical ,

Power Distribution System load group buses does not l exceed the most restrictive A0T associated with the A equipment they support. In some instances loads 11 .

associated with one unit are supplied from the I emergency power system buses associated with the other unit. Tables 1 through 4 identify the most restrictive A0Ts for equipment supplied from each AC Electrical Power Distribution System load group for each unit. The tables were each prepared assuming that one load group primarily associated with the shutdown unit is removed from service while the other unit is operating. Each table identifies the ,

operating unit's Technical Specification related loads '

supported from the load group to be taken out of service and caused to be inoperable by de-energization of the load group and provides the operating unit's most restrictive A0T duration associated with each of these loads. Tables 1 through 4 provide this information for all four load groups of AC Electrical Power Distribution System.

Based on Tables 1 through 4, the most restrictive A0T for Technical Specification equipment supported from an inoperable load group is 7 days. Hence, an A0T of 7 days is appropriate for an inoperable AC Electrical Power Distribution System load group (E3 or E4 with Unit 1 operating when Unit 2 is shutdown; El or E2 I with Unit 2 operating when Unit 1 is shutdown).

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BNP UNITS 1 & 2 19 Revision 0 l

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l l DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.15 c) The change in core damage probability for the operating unit has been evaluated and is not

!b (cont'd) significantly increased by extending the A0T of these buses to 7 days. This slight increase in core damage probability is due to the longer period of time that a t load group of the AC Electrical Power Distribution System is unavailable; during this time the AC Electrical Power Distribution System would not be able to perform its safety function concurrent with a worst case single failure. Any small increases in risk g

resulting from longer A0Ts are offset by the improved reliability gained by having the capability to perform maintenance on a more optimum schedule. Longer A0Ts also provide additional flexibility in scheduling maintenance a.tivities and reduce the potential for unnecessary piant shutdowns caused by shorter A0Ts.

In addition, 10CFR50.65, " Requirements for monitoring i the effectiveness of maintenance at nuclear power '

plants," section (a)(2) acknowledges that preventive maintenance must be demonstrated to be effective in controlling the performance or condition of a structure, system or component (SSC) so that the SSC remains capable of performing its intended function.

As such, licensees are directed to establish appropriate preventive maintenance programs. The 7 day A0T will provide the necessary time for appropriate preventive maintenance, which is at present insufficient.

The Brunswick Maintenance Rule program requires that high safety significant systems have performance criteria to monitor the effectiveness of preventive d ,

maintenance. The performance criteria establish acceptance limits for reliability and availability of the system. The overall impact of the performance limits on safety is assessed by evaluating their impact on the plant core damage frequency. If the combination of the proposed reliability and availability limit- tor the system results in a core damage frequency ? .el that is within the limits of a non-risk significant condition, then the performance criteria are deemed acceptable. The core damage frequency acceptance limits are based on industry guidance. The performance criteria in the Brunswick i

Maintenance Rule Program include unavailability time for each B0P bus of 7 days, and they are acceptable per the core damage frequency limits. The impact on unavailability of the associated emergency buses is include in this assessment.

I BNP UNITS 1 & 2 20 Revision 0 l

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I DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING l

l II.CHNICAL CHANGES - LESS RESTRICTIVE L.15 Furthermore, the reliability and availability of the (cont'd) buses are monitored under the Brunswick Maintenance Rule Program such that if the reliability or availability perfo mance limits are exceeded for the buses, they are considered for section (a)(1) of the i l

l Maintenance Rule, which requires increased management attention and goal setting in order to restore their g

performance (i.e., reliability and availability) to an acceptable level. The intent of the Brunswick Maintenance Rule Program is to optimize reliability 1 i

i and availability of plant structures, systems and components by these methods.

2) The 4.16 kV B0P buses also supply nonsafety-related loads associated with power production, nlith a unit in MODE 4 or 5, most of these unit specific nonsafety-related loads are already not operating. Redundant loads on the other B0P buses can be operated to support nonsafety-related systems g

desired during a BOP bus outage.

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3) The reliability of the offsite power circuits (via the 80P buses) to the AC Electrical Power Distribution System buses will be increased as the longer A0T will allow planned C maintenance of the 80P buses to be performed on a more >

optimum schedule.

Extensive planning and reviews by BNP Safe Shutdown Risk Management personnel and the requirements of ITS 3.8.2, "AC Sources - Shutdown," will ensure that the AC sources necessary to 6

, support the OPERABILITY of required equipment is maintained for i the shutdown unit during an outage of a 80P bus. Hence, there

! will not be an adverse impact to the shutdown unit.

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BNP UNITS 1 & 2 21 Revision 0 l

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DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE I ALLOWED rUTAGE TIMES (A0Ts) 0F UNIT 2 TECHNICAL SPECIFICATION LOADS SUPPLIED BY UNIT I DIVISION I l

(THIS TABLE IDENTIFIES UNIT 2 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED BY UNIT I DIVISION I. THE TABLE ASSUNES UNIT 2 IS AT POWER AND UNIT I IS SHUTDOWN WITH ITS DIVISION I ENERGENCY AC POWER DISTRIBUTION SYSTEN OUT OF SERVICE.) i l

l MOST LOAD POWER APPUCABLE RESTRICTIVE COMMENTS TITLE SUPPLY ITS ACT RHRSW PUMP El 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABLE 14 DAYS -

2C MOTOR ONE RHRSW SUBSYSTEM INOPERABLE - 7 I DAYS RHR PUMP 2C El 3.5.1 7 DAYS LPCI- 7 DAY ACT PROVIDED BOTH UNIT 2 j MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE l

OPERABLE. BOTH UNIT 2 CORE SPRAY SUBSYSTEMS WOULD BE OPERABLE AS i THEY ARE SUPPUED FROM E3 AND E4. l SUPPRESSION POOL COOUNG 7 DAY AOT.

NSW PUMP 1 A El 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE.

CSW PUMP 2C El 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP l INOPERABLE.

SUBSTATION E6 El 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER THIS DISCUSSION OF CHANGE.

120/208V VITAL E6 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER BUS 1E6 THIS DISCUSSION OF CHANGE.

INCOMING El 3.8.1 24 HOURS 7 DAY AOT PROPOSED FOR THIS FEEDER FROM INOPERABluTY DUE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS 1D

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BNP UNITS I & 2 22 Revision 0 l

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DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 1 (Continued) l MOST LOAD POWER APPUCAsti RESTIUC1WE eN TITLE SUPPLY ITS AOT CONTROL MCC1- 3.7.3 7 DAYS LDSS OF ONE CONTROL BUILDING HVAC i BUILDING HVAC ICA SYSTEM CONTROL Am COMPRESSOR l SYSTEM (E6) RESULTS IN THE CREV SYSTEM NO -

i CONTROL AIR LONGER MEETING SINGLE FAILURE COMPRESSOR, CRITERIA. AS A RESULT, ONE CREV 2-VA-28-AC-C8 SUSSYSTEM Witt BE DECLARED l

INOPERABLE WHICH RESULTS IN A 7 DAY AOT.

CONTROL MCC1 3.7.4 30 DAYS NONE l BUILDING 1CA l SUPPLY FAN 1- (ES)

I VA.10-SF-C8 CONTROL MCC1- 3.7.4 30 DAYS NONE BUILDING A/C 1CA CONDENSER (E61 VA 10-CU-C8 CONTROL 120 VAC 3.7.4 30 DAYS NONE BUILDING 1 1C-SUPPLY FAN 120V VA-1D-SF C8 (HYO) l CONTROL (120/208 j CIRCulT VITAL '

i SUS 1E6) i 1 A 1 BATTERY CHARGER AC MCC1-1CA 3.8.4 7 DAYS NONE b INPUT NORMAL (E61 FEED 4

1 A 2 SATTEHY MCC1- 3.8.4 7 DAYS NONE I CHARGER AC 1CA INPUT NORMAL (ES) C FEED NSW PUMP 1 A MCC1- 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW STRAINER SW. 1PA PUMP AND ONE REQUIRED CSW PUMP 1 A440C-PMP- (ES) INOPERABLE.

STR b

NSW PUMP 1 A MCC1- 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW DISCHARGE 1PA PUMP AND ONE REQUIRED CSW PUMP VALVE SW V19 (ES) INOPERABLE.

Ib BNP UNITS I & 2 23 Revision 0 i , . _ .

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABt.E 1 (Continued)

MOST LOAD POWER APPUCABLE RESTIUCTIVE COMMENTS TITLE SUPPLY ITS AOT CSW PUMP 2C MCC1 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW DISCHARGE TO 1PA PUMP AND ONE REQUIRED C8W PUMP NUCLEAR (E6) INOPERA8LE. C e HEADER VALVE 2 SW-V18 CSW PUMP 2C MCC1 3.7.2 ' 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW DISCHARGE 1PA PUMP AND ONE REQUIRED CSW PUMP VALVE 2 SW. (E6) INOPERAP'1 i V17 CSW PUMP 2C MCC1 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW STRAINER 2-SW- IPA PUMP AND ONE REQUIRED CSW PUMP 2C-CONV-PMP-STR (ES) INOPERABLE. h RHR OUTBOARD MCC2 3.6.1 7 DAYS VALVES 2-E11-F016A ANO 2411-F017A INJECTION 2XA-2 3.8.1.3 ARE THE UNIT 2 LOOP A RHR INBOARD VALVE 2-E11- (E61 AND OUTBOARD INJECTION VALVES USED l F017A FOR LPCI. THE F016A VALVE IS NORMALLY CLOSED AND THE F017A VALVE IS NORMALLY OPEN. DURING AN ACCIDENT THE F016A OPENS WHEN REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCi INJECTION.

THESE VALVES ARE ALSO PRIMARY CONTAINMENT ISOLATION VALVES PER TS 3.8.1.3 OPERATION MAY CONTINUE i

WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8tf PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

RHRIN80ARD MCC2- 3.6.1 7 DAYS 3.8.1.3 INJECTION VALVE 2-E11 F016A 2XA-2 (ES)

THis TS CAN SE MET DUIUNG THE MCC OUTAGE BY PLACING BOTH VALVES IN A h

CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVES.

UNDER TS 3.6.1 THIS WILL CAUSE THE UNIT 2 LOOP A OF LPCI TO BE INOPERA8LE. WITH ONE LPCI SUBSYSTEM INOPERABLE ITS 3.6.1 REQUIRES THAT THE SUSSYSTEM BE RESTORED WITHIN i 7 DAYS PROVIDED BOTH CORE SPRAY SuSSYSTEMS ARE OPERABLE. BOTH UNIT 2 CORE SPRAY SUSSYSTEM SYSTEMS WOULD BE OPERA 8LE AS THEY ARE SUPPUED FROM E3 AND E4.

[ BNP UNITS 1 & 2 24 Revision 0 b

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I DISCUSSION OF CHANGES l

1 ITS: 3.8.1 - AC SOURCES-OPERATING TABLE I (Continued)

MOST LOAD POWER APPUCABLE RESTRICTIVE COMMENM TITLE SUPPLY ITS ACT RHR TORUS MCC2- 3.6.1 7 DAYS VALVE 2-E11-F028A IS THE RHR TORUS SPRAY VALVE 2XA 2 3.6.2,3 SPRAY DISCHARGE VALVE. THis VALVE l 2-E11-F028A (E6) 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI i

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INITIATION TO PROVIDE TORUS ISOLATION.

l l-THIS VALVE IS ALSO A PRIMARY l

CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERABLE PROVIDED THE PENETRATION IS ISOLATED.

THIS TS CAN BE MET DURING THE MCC 1 OUTAGE BY PLACING THIS VALVE IN A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVE.

TS 3.".1 REQUIRES THAT THE F028A VALVE CLOSE ON A LPCIINITIATION h

SIGNAL TO ENSURE AN OPERABLE PATH TO THE REACTOR VESSEL (IF F028A IS OPEN THE LPCI FLOW WOULD BE PARTIALLY DIVERTED BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERABILITY OF THIS LPCI LOOP.

HOWEVER, CLOSING THE F028A VALVE WOULD CAUSE LOOP A OF SUPPRESSION POOL COOUNG TO BE INOPERABLE. WITH ONE INOPERABE LOOP OF SUPPRESSION POOL COOUNG, TS 3.6.2.3 REQUIRES THAT THE LOOP BE RESTORED WITHIN 7 DAYS.

BNP UNITS 1 & 2 25 Revision 9

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1 DISCUSSION OF CHANGES ITS. 3.8.1 - AC SOURCES-OPERATING TABLE I (Continued) 1 MOST LOAD POWER APPUCABLE RESTRICTIVE COMMelfs TITLE SUPPLY ITS ACT h

RX McC2 3.6.1 7 DAYS THE ABIUTY OF THESE VALVES TO CLOSE RECIRCULATION 2XA-2 IS A REQUIREMENT FOR LPCI PUMP 2A (E6) OPERA 81UTY. IF THESE VALVES ARE DISCHARGE INOPERABUI AND OPEN, THEN FER Tl'E VALVE 2432 BASES OF TG 3.6.1 THE ASSOQATED LPCI F031A SUBSYSTEM MUST BE DECLARED INOPERA8LE. 7 DAY ACT FOR ONE INOPERABLE LPCI SUSSYSTEM PROVIDED RX MCC2 3.6.1 7 DAYS SOTH CORE SPRAY SUBSYSTEMS ARE RECIRCULATION 2XA.2 OPERA 8tE. BOTH CORE SPRAY PUMP 2A (E6) SUBSYSTEMS WOULD SE OPERA 8tf AS C DISCHARGE THEY ARE SUPPUED FROM E3 AND E4 BYPASS VALVE

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2-832-F032A 1

AREA 120VAC 3.3.7.1 N/A LOSS OF THIS CIRCUIT WILL CAUSE A RADIATION 1 1 A8 CONTROL BUILDING EAF (MTIATION l MONITORING, SIGNAL DUE TO THE LOSS OF THE i D22 M ,ES. (120/208 REQUIRED RADIATION MOMTORS IN THE K603A VITAL BUS CONTROL ROOM AREA. PER TG 3.3.7.1 REQUIRED ACTION A.1 THE LOSS OF h

1E6) MORE THAN ONE DETECTOR REQUIRES THAT SOTH SUBSYSTEMS SE DECLARED INOPERABLE WITHIN ONE HOUR. THIS CAN BE AVOIDED BY TRANSFERRING j 120VAC PANEL 1 1 A8 FROM ITS NORMAL l 1E6 SUPPLY (FROM E146) TO ITS 1E6 ALTERNATE SUPPLY (FROM E246) DURING h

THE DE-ENERGIZATION OF E146/1E6.

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DG 1 MCC2 3.8.1 7 DAYS ALSO,7 DAY AOT PROPOSED FOR TWO AUXIUARIES DGA OFFSITE ORCulTS INOPERABLE AND DG (E.G., STARTING (E6) INOPERA8LE DUE TO 80P BUS OUTAGE l AIR COM. PER THIS DISCUSSION OF CHANGE.

PRESSORS) l-b l

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l BNP UNITS 1 & 2 26 ReYision 0 '

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DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 2 i

ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT 2 TECHNICAL SPECIFICATION LOADS SUPPLIED BY UNIT I DIVISION II (THIS TABLE IDENTIFIES UNIT 2 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED BY UNIT I DIVISION II. THE TABLE ASSUMES UNIT 2 IS AT POWER AND UNIT 1 IS SHUTDOWN WITH ITS DIVISION II EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF SERVICE.)

MOST LOAD POWER APPUCABLE RESTRICTWE COMMENTS l TITLE SUPPLY ITS AOT l RHRSW PUMP E2 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABE 14 DAYS 20 MOTOR ONE RHRSW SUBSYSTEM INOPERABLE . 7 I DAYS I i

RHR PUMP 20 E2 3.6.1 7 DAYS LPCI- 7 DAY ACT PROVIDED BOTH UNIT 2 I MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE OPERABLE. BOTH UNIT 2 CORE SPRAY l

SUBSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM E3 AND E4.

SUPPRESSION POOL COOUNG 7 DAY ACT NSW PUMP 1B E2 3.7.2 7 DAYS NONE MOTOR l

SUBSTATION E6 E2 3.8.7 8 HOURS 7 DAY ACT PROPOSED FOR THIS BUS PER THIS DISCUSSION OF CHANGE.

120/208V VITAL E6 3.8.7 8 HOURS 7 DAY ACT PROPOSED FOR THIS BUS PER BUS 1E6 THIS DISCUSSION OF CHANGE.

(NO TECHNICAL SPECIFICATION LOADS REQUIRED FOR UNIT 2) h INCOMING E2 3.8.1 24 HOURS 7 DAY AOT PROPOSED FOR THIS FEEDER FROM INOPERABluTY DUE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS 1C 18-1 BATTERY MCC1- 3.8.4 7 DAYS NONE CHARGER AC 1CB INPUT NORMAL (E6)

FEED l

BNP UNITS I & 2 27 Revision 0 I

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DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 2 (Continued) 1 MOST - A LOAo POWER APPuCA882 RESTIUCTIVE COMMG4Ts (_A\

TITlf SUPPLY ITS AOT 18-2 BATTERY MCC1 3.7.4 7 DAYS NONE CHARGER AC 1C8 INPUT NORMAL (E6)

FEED NSW PUMP 18 McC1- 3.7.2 7 DAYS NONE STRAINER SW. 1P8 18-NUC-PMP- (E6)

STR NSW PUMP 1B MCC1 3.7.2 7 DAYS NONE g

DISCHARGE 1PB VALVE SW V20 (E6) C RHR OUTBOARD MCC2- 3.6.1 7 DAYS VALVES 2-E11.F0168 AND 2-E11.F0178 INJECTION 2X8 2 3.6.1.3 ARE THE UNIT 2 LOOP B RHR IN80ARD I VALVE 2 E11 F0178 (E6) AND OUT80ARO INJECTION VALVES USED FOR LPCI. THE F0168 VALVE IS h l I

NORMALLY CLOSED AND THE F0178 l VALVE IS NORMALLY OPEN. DURING AN l ACCIDENT THE F0168 OPENS WHEN !

REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCI INJECTION.

THESE VALVES ARE ALSO PRIMARY '

CONTAINMENT ISOLATION VALVES. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERABLE PROVIDED THE AFFECTED PENETRATION IS RHRIN80ARD MCC2 3.6.1 7 DAYS INJECTION 2X8 2 3.6.1.3 VALW 2M THIS TS CAN BE MET DURING THE MCC (E61 F0168 OUTAGE BY PLACING BOTH VALVES IN A MSED POSIM M REMOM

l CONTROL POWER TO THE VALVES.

UNDER TS 3.5.1 THIS WILL CAUSE THE UNIT 2 LOOP B OF LPCI TO BE INOPERA8LE. WITH ONE LPCI SUBSYSTEM INOPERABLE TS 3.6.1 REQUIRES THAT h

THE SUBSYSTEM BE RESTORED WITHIN j 7 DAYS PROVIDED BOTH CORE SPRAY SUBSYSTEMS ARE OPERA 8LE. BOTH UNIT 2 CORE SPRAY SYSTEMS WDULD BE OPERA 8ti AS THEY ARE SUPPUED FROM E3 AND E4.

I

, BNP UNITS 1 & 2 28 Revision 0 1

i

i o

. DISCUSSION OF CHANGES l ITS: 3.8.1 - AC SOURCES-OPERATING j- TABLE 2 (Continued)

MOST LOAD TITLE POWER SUPPLY APPLICABLE ITS RESTRICTIVE AOT COMMENTS h

RHR TORUS MCC2, 3.5.1 7 DAYS VALVE 2411-F0288 IS THE RHR TORUS i SPRAY VALVE 2X8 2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE l

2{11 F0288 IE61 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI 4 NIT 1ATION TO PROVIDE TORUS ISOLATION.

l THAS VALVE IS ALSO A PRIMARY l CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ,

ISOLATION VALVE INOPERA8LE PROVIDED I THE AFFECTED PENETRATION IS ISOLATED. ,

THis TS CAN BE MET DURING THE MCC OUTAGE SY PLACING THis VALVE IN A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVE.

TS 3.5.1 REQUIRES THAT THE F0288 VALVE CLOSE ON A LPCIINITIATION 7NAL To ENSURE AN OPERABLE PATH 19 .'HE REACTOR VESSEL (if F0288 is OPEN THE LPCI FLOW WOULD BE PARTIALLY DIVERTED BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 84UTY OF THIS LPCI LOOP.

HOWEVER. CLOSING THE F0288 VALVE WOULD CAUSE LOOP 8 OF SUPPRES$40N POOL COOUNG TO BE INOPERABLE. WITH l ONE INOPERA8LE LOOP OF SUPPRESS 4ON POOL COOUNG, TS 3.6.2.3 REQUIRES l l

THAT THE LOOP BE RESTORED WITHIN 7 DAYS.

1 RX MCC2 3.6.1 7 DAYS THE A88UTY OF THESF VALVES TO CLOSE RECIRCULATION 2X8-2 IS A REQUIREMENT Rie.LPCI ,

PUMP 28 (E61 OPERA 86UTY. 4F M4SE VALVES ARE DISCHARGE INOPERABLE AND OPEN. THEN PER THE VALVE 2-832- BASES OF TS 3.5.1 THE ASSOCIATED LPCI F0318 SUBSYSTEM MUST BE DECLARED INOPERABLE. 7 DAY AOT FOR ONE RX M CC2- 3.5.1 7 DAYS INOPERABLE LPCI SUBSYSTEM PROVIDED RECIRCULATION 2X8-2 80TH CORE SPRAY SUBSYSTEMS ARE PUMP 28 (E6) OPERABLE. BOTH CORE SPRAY DISCHARGE SU8 SYSTEMS WOULD BE OPERABLE AS BYPASS VALVE THEY ARE SUPPUED FROM E3 AND E4.

2-832-F0328 l BNP UNITS 1 & 2 29 ReYision 0 l

l I

~ . . .__. . . . . . . . . ~ . .___

, DISCUSSION OF CHANGES

j. ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 2 (Continued) l MOST LOAD POWER APPUCABLE RESTNCTWE COMMENTS l TITLE SUPPLY ITS ACT

^

DG 2 MCC2 8.8.1 7 DAYS ALSO,7 DAY AOT PROPOSED FOR TWO AUXIUARIES DGB OFFSITE CIRCulTS INOPERABLE AND DG (E.G., STARTING AIR COM.

(E6) INOPERABLE DUE TO BOP BUS OUTAGE PER THIS DISCUSSION OF CHANGE.

lh PRES 80RS) I b

! BNP UNITS 1 & 2 30 Revision 0

(

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 3 ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT 1 TECHNICAL SPECIFICATION LOADS ,

SUPPLIED BY UNIT 2 DIVISION I l

l l I (THIS TABLE IDENTIFIES UNIT 1 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED l BY UNIT 2 DIVISION I. THE TABLE ASSUMES UNIT 1 IS AT POWER AND UNIT 2 IS l SHUTDOWN WITH ITS DIVISION I EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF SERVICE.) l I

MOST LOAD POWER APPUCABLE RESTRICTIVE COMMENTS TITLE SUPPLY ITS AOT RHRSW PUMP E3 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABLE 14 DAYS 1 A MOTOR ONE RHRSW SUBSYSTEM INOPERABLE - 7 DAYS l

RHR PUMP 1 A E3 3.5.1 7 DAYS LPCI 7 DAY AOT PROVIDED BOTH UNIT 1 MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE l OPERABLE. BOTH UNIT 1 CORE SPRAY I SUBSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM El AND E2.

SUPPRESSION POOL COOUNG - 7 DAY AOT.

NSW PUMP 2A E3 3.7.2 7 DAYS NONE MOTOR SUBSTATION E7 E3 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER THIS DISCUSSION OF CHANGE.

120/208V VITAL E7 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER BUS 2E7 THIS DISCUSSION OF CHANGE. h INCOMING E3 3.8.1 24 HOURS 7 DAY AOT PROPOSED FOR THIS FEEDER FROM INOPERABluTY DUE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS 2D 2A 1 BATTERY MCC2 3.8.4 7 DAYS NONE CHARGER AC 2CA INPUT NORMAL (E7)

FEED Ss 2A 2 BATTERY MCC2 3.8.4 7 DAYS NONE CHARGER AC 2CA taVT NORMAL FEED (E7) h I ds BNP UNITS 1 & 2 31 ReYision 0

l DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 3 (Continued) i MOST ,

LOAD POWER APPLICA8LE RESTRICTIVE COMMENTS TITLE SUPPLY ITS AOT )

NSW PUMP 2A MCC2- 3.7.2 7 DAYS NONE l STRAINER SW- 2PA l 2A-NUC-PMP- (E7) ,

STR l

l.SW PUMP 2A MCC2 3.7.2 7 DAYS NONE '

DISCHARGE SW- 2PA V19 (E7)

CONTROL MCC2- 3.7.3 7 DAYS LOSS OF ONE CONTROL BUILDING HVAC

, BUILDING HVAC 2CA SYSTEM CONTROL AIR COMPRESSOR SYSTEM (E7) RESULTS IN THE CREV SYSTEM NO CONTROL AIR LONGER MEETING SINGLE FAILURE COMPRESSOR, CRITERIA. AS A RESULT, ONE CREV VA-2A-AC-C8 SUBSYSTEM WILL BE DECLARED i

INOPERABLE WHICH RESULTS 1N A 7 DAY OT. b CONTROL MCC2- 3.7.3 7 DAYS LOSS OF ONE CONTROL ROOM BUILDING 2CA EMERGENCY FILTRATION UNIT RESULTS IN l EMERGENCY (E7) A 7 DAY AOT.

RECIRCULA-TION AIR FAN VA 2A-ERF-C8 h' i

i CONTROL MCC2- 3.7.4 30 DAYS NONE BUILDING A/C 2CA CONDENSER (E7)

VA-20-CU-C8 CONTROL MCC2- 3.7.4 30 DAYS NONE BUILDING 2CA SUPPLY FAN (E7)

VA-20-SF-C8 CONTROL 120 VAC 3.3.7.1 7 DAYS CREV SYSTEM AUTO INtTIATION ON HIGH BUILD 4NG PANEL 2- 3.7.4 RADIATION (D(V 1) WILL BE DISASLED.

SUPPLY FAN 2- 2C LOSS OF THE AUTO INITIATION WILL VA-2D-6F-CB (120/208 RESULT IN A 7 DAY ACT. PER TS 3.7.4, l

AND CREV SYSTEM HIGH VITAL BUS (DSS OF ONE SUPPLY FAN IS A 30 DAY AOT.

h

! RADIATION 2E7)

DIV i INITIATION /\

l RELAY CIRCutT QA i

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! BNP UNITS 1 & 2 32 Revision 0 l

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DISCUSSION OF CHANGES ITS; 3.8.1 - AC SOURCES-OPERATING TABLE 3 (Continued)

MOST LOAD POWER APPUCABLE RESTNCTIVE COMMENTS 11TLE SUPPLY iTS ACT DMSiON 1 120 VAC 3.7.3 7 DAYS LOSS OF ONE CONTROL ROOM CONTROL PANEL 2 EMERGENCY FILTRATION UNIT RESULTS IN BUILDING LOGIC 2C A 7 DAY ACT FOR CREV (120/206 SYSTEM VITAL RECIRCULA. BUS TION FAN 2A 2E7)

DAMPER CONTROL RHR OUTBOARD MCC1 3.6.1 7 DAYS VALVE 1-E11-F016A AND 1 E11 F017A INJECTION 1XA 2 3.6.1.3 ARE THE UNIT 1 LOOP A RHR IN80ARD VALVE 1 E11 (E7) AND OUTBOARD INJECTION VALVE 1 USED F017A FOR LPCI. THE Fol6A VALVE IS NORMALLY CLOSED AND THE F017A VALVE IS NORMALLY OPEN. DURING AN ACCIDENT THE F016A OPENS WhEN REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCI INJECTION.

THESE VALVES ARE ALSO PRIMARY CONTAINMENT ISOLATION VALVES. PER TS 3.6.1.3 OPERATION MAY CONTINUE h

WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8LE PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

RHR INBOARD MCC1 3.6.1 7 DAYS INJECTION 1XA 2 3.6.1.3 THIS TS CAN BE MET DURING THE MCC VALVE 1E11 (E7) OUTAGE BY PLACING BOTH VALVES IN A C F016A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVES.

UNDER TS 3.6.1 THIS WILL CAUSE THE UMT 1 LOOP A OF LPCI TO BE INOPERABLE. WITH ONE LPCI SUBSYSTEM INOPERABLE, TS 3.6.1 REQUIRES THAT THE SUSSYSTEM BE RESTORED WITH6N g 7 DAYS PROVIDED BOTH CORE SPRAY m SUBSYSTEMS ARE OPERABLE. BOTH UNIT 1 CORE SPRAY SYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM El AND E2.

BNP UNITS 1 & 2 33 ReYision 0

DISCUSSION OF CHANGES ITsi 3.8.1 - AC SOURCES-OPERATING TABLE 3 (Continued) l MMT LOAD POWER APPUCABLE RESTRICTIVE COMMENTS TITLE SUPPLY 11 5 AOT RHR TORUS MCC1 3.6.1 7 DAYS VALVE 1 E11 F028A IS THE RHR TORUS SPRAY VALVE 1XA.2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE 1411 F028A IE7) 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI INITIATION TO PROMDE TORUS ISO:ATION.

THdS VALVE IS ALSO A PRIMARY CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVE INOPERABLE PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

MS TS CAN BE MET DURING THE MCC OUTAGE BY PLAQNG THIS VALVE IN A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVE.

TS 3.5.1 REQUIRES THAT THE FO28A VALVE CLOSE ON A LPCI INITIATION SIGNAL TO ENSURE AN OPERABLE PATH TO THE REACTOR VESSEL (IF F028A IS OPEN THE LPCI FLOW WOULD BE PARTIAU.Y DIVERTED BACK TO THE TORUS). CLOS 4NG THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 84UTY OF THIS LPQ LOOP.

HOWEVER, CLOSING THE F028A VALVE WOULD CAUSE LOOP A OF SUPPRESSION POOL COOUNG TO 8E INOPERABLE. WITH ONE INOPERABLE LOOP OF SUPPRESSION POOL COOUNG. TS 3.6.2.3 REQUIRES THAT THE LOOP BE RESTORED WITHIN 7 DAYS.

RX REQRCULA- MCC1 3.5.1 7 DAYS THE A830TY OF THESE VALVES TO CLOSE TION PUMP 1 A 1XA 2 IS A REQUIREMENT FOR LPQ DISCHARGE (E7) OPERA 84U fY. IF THESE VALVES ARE VALVE 1-832- INOPERA8LE AND OPEN. THEN PER THE F031A SASES OF TS 3.5.1 THE ASSOCIATED LPCI SUBSYSTEM MUST BE DECL/JIED INOPERA8LE. 7 DAY ACT FOR ONE RX REORCULA- MCC1 3.5.1 7 DAYS INOPERA8LE LPCI SUBSYSTEM PROVIDED TlON PUMP 1 A 1XA.2 BOTH CORE SPRAY SUBSYSTEMS ARE DISCHARGE (E7) OPERA 8LE. SOTH CORE SPRAY C BYPASS VALVE SUBSYSTEMS WOULD SE OPERABLE AS 1832-F032A THEY ARE SUPPUED FROM El AND E2.

BNP UNITS 1 & 2 34 Revision 0 I

i j .

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 3 (continued)

MOST LOAD TITLE POWER SUPPLY APPUCABLE ITS RESTRICTIVE AOT COMMENTE h DG S MCC.2 3.8.1 7 DAYS ALSO,7 DAY ACT PROPOSED FOR THE AUXIUARIES DGC OFF84TE CIRCulTS INOPERA8LE ANO DG .

(E.G., STARTING (E7) INOPERABLE DUE TO BOP SUS AIR COM. INOPERA84UTY PER THIS DISCUSSION OF PRESSORS) CHANGE.

b BNP UNITS 1 & 2 35 Revision 0

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 4 ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT 1 TECHNICAL SPECIFICATION LOADS SUPPLIED BY UNIT 2 DIVISION II l (THIS TABLE IDENTIFIES UNIT 1 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED BY UNIT 2 DIVISION II. THE TABLE ASSUMES UNIT 1 IS AT POWER AND UNIT 2 SHUTDOWN WITH ITS DIVISION II EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF SERVICE.)

MOST LOAD POWER APPUCABLE RESTRICTIVE COMMENTS TITLE SUPPLY ITS AOT RHRSW PUMP E4 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABLE 14 DAYS 18 MOTOR ONE RHRSW SUBSYSTEM INOPERABLE - 7 l DAYS l

RHR PUMP 1B E4 3.S.1 7 DAYS LPCI- 7 DAY AOT PROVIDED BOTH UNIT 1 MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE OPERABLE. BOTH UNIT 1 CORE SPRAY SUBSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM El AND E2.

SUPPRESSION POOL COOLING . 7 DAY a AOT.

NSW PUMP 2B E4 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE.

CSW PUMP 1 A E4 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE.

SUBSTATION E8 E4 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER .

THIS DISCUSSION OF CHANGE. I 120/208V E8 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER VITAL BUS 2E8 THIS OlSCUSSION OF CHANGE.

INCOMING E4 3.8.1 24 HOURS 7 DAY AOT PROPOSED FOR THIS FEEDER FROM INOPERABlWTY DUE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS 2C BNP UNITS 1 & 2 36 ReYision 0 l

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_ _- ._- . ~ - - - . . - _ . _ . . .. .

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-0PERATING TABLE 4 (Continued)

LOAD POWER APPUCASE MOST RESTNCTIVE COMMENTS h TITLE SUPPLY ITS AOT CONTROL McC2 3.7.3 7 DAYS LOSS OF ONE CONTROL ROOM BUILDING 2C8 EMERGENCY FILTRATION UNIT RESULTS IN EMERGENCY (E81 A 7 DAY AOT.

REClRCULATION AIR FAN 2 VA.

28-ERF-C8 28-2 BATTERY MCC2- 3.8.4 7 DAYS NONE CHARGER AC 2C8 INPUT NORMAL (E8) !C FEED 28-1 BATTERY MCC2- 3.8.4 7 DAYS NONE CHARGER AC 2C8 INPUT NORMAL (E8)

FEED CONTROL MCC2- 3.7.4 30 DAYS NONE BUILDING 2C8 A/C (E8)

CONDENSER VA-2E-CU-C8 CONTROL MCC2- 3.7.4 30 DAYS NONE BUILDING 2C8 SUPPLY FAN (E8) ;

VA 2E-SF-C8 l NSW PUMP 28 MCC 2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW STRAINER SW- 2PB PUMP AND ONE REQUIRED CSW PUMP 28-NUC-PMP- (E8) INOPERABLE. '

l STR l NSW PUMP 28 MCC 2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REOVIRED NSW DISCHARGE 2PB PUMP AND ONE REQUIRED CSW PUMP i VALVE SWV20 (E8) INOPERABLE.

h CSW PUMP 1 A MCC2 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW j DISCHARGE TO 2PA PUMP AND ONE REQUIPED CSW PUMP i NUCLEAR (E8) INOPERABM.

HEADER VALVE 1 SW-V14

)

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l BNP UNITS 1 & 2 37 Revision 0

_ . _ _ _ . . . _ . _ . _ _ _ _ _ _ . - . . _ _ _ . . . _ _ _ . _ _ _ . . _ . . _ _ _ . ~ . . _ _ . _ _ __

1

. DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING 4

TABLE 4 (Continued) 1 MOST LOAD POWER APPUCA8LE RESTRICTIVE COMMENTS J MT12 SUPPLY ITS AST CSW PUMP 1 A MCC2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW I i DISCHARGE 2PA PUMP AND ONE REQUIRED C8W PUMP '

VALVE 1 SW- (ESI INOPERA8LE.

V13

, CSW PUMP 1 A MCC2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW 4 STRAINER 2PA PUMP AND ONE REQUIRED CSW PUMP l VALVE 1 SW- (ESI INOPERABLE. l 1 A<,0NV-PMP-STR i

RHR OUT80ARD MCC1 3.6.1 7 DAYS VAL'4ES 1-E11.F0168 AND 1-E11-F0178 l

INJECTION 1XB-2 3.6.1.3 ARE THE UNIT 1 LOOP 8 RHR $N80ARD VALVE 1-E11 (E8) AND OUTBOARD INJECTION VALVES USED 4 F0178 FOR LPCI. THE Fol68 VALVE IS l 3 NORMALLY CLOSED AND THE F0178 VALVE IS NORMALLY OPEN. DURING AN i ACCIDENT THE F0168 OPENS WHEN i REACTOR PRESSURE DROPS TO 410 PSIG l TO PERMIT LPCI INJECTION. l THESE VALVES ARE ALSO PRIMARY CONTAIN. MENT ISOLATION val?AS. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLADON VALVE INOPERABLE PR'OVIDED THE AFFECTED PENETRATION IS ISOLATED.

RHR INBOARD MCC1 3.5.1 7 DAYS INJECTION 1X8-2 3.6.1.3 THis TS CAN BE MET DURING THE MCC VALVE 1-E11- (ES) OUTAGE BY FLACING 8OTH VALVES IN A C F0168 CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVES.

LNA ER TS 3.6.1 THIS WILL CAUSE THE UNIT 1 LOOP B OF LPCI TO BE INOPERA8LE. VMH ONE LPCI SUBSYSTEM INOPERA8LE, TS 3.5.1 REQUIRES THAT THE SUBSYSTEM BE RESTORED WITHIN 7 DAYS PROVIDED BOTH CORE SPRAY h

SUBSYSTEMS ARE OPERA 8LE. BOTH UNIT 1 CORE SPRAY SUBSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM El AND E2.

BNP UNITS 1 & 2 38 Revision 0 l

__ _ - _ _ _ . - - ._ ~ ._ _ _ _ _ _ - ._ _ _ _ _ _ _ .

DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING TABLE 4 (Continued)

I MCST LOAD TITLE POWER SUPPLY APPUCA842 ITS RESTRICTIVE AOT COMMENTS h l RHR TORUS l MCC1- 3.5.1 7 DAYS VALVE 1-E11 F0288 IS THE RHR TORUS SPRAY VALVE 1X8-2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE 1-E11-F0288 (E8) 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI INITIATION TO PROVIDE TORUS h )

ISOLATION.

THIS VALVE IS ALSO A PRIMARY CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERABLE PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

THIS TS CAN BE MET DURING THE MCC OUTAGE BY PLACING THis VALVE IN A CLOSED POSITION AND REMOVING l CONTROL POWER TO THE VALVE.

TS 3.5.1 REQUIRES THAT THE F0288 VALVE CLOSE ON A LPCI INITIATION SIGNAL TO ENSURE AN OPERABLE PATH TO THE REACTOR VESSEL (IF F0288 IS '

OPEN THE LPCI FLOW WOULD BE PARTIALLY DIVERTED BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 81UTY OF THIS LPCI LOOP.

HOWEVER CLOSING THE F0288 VALVE j WOULD CAUSE LOOP 8 OF SUPPRESSION j POOL COOUNG TO BE INOPERABLE. WITH ONE INOPERABLE LOOP OF SUPPRESSION POOL COOUNG, TS 3.6.2.3 REQUIRES THAT THE LOOP BE RESTORED WITHIN 7 DAYS.

RX MCC1- 3.5.1 7 DAYS THE ABluTY OF THESE VALVES TO CLOSE RECIRCULATION 1X8-2 IS A REOUIREMENT FOR LPCI PUMP 18 DISCHARGE (E8) OPERA 81UTY. IF THESE VALVES ARE INOPERA8LE AND OPEN, TitEN PER THE h

BYPASS VALVE BASES OF TS 3.5.1 THE ASSOCIATED LPCI 1-832-F0318 SUBSYSTEM MUST BE DECLARED INOPERABLE 7 DAY ACT FOR ONE INOPERABLE LPCl SUBSYSTEM PROVIDED h RX MCC1 3.5.1 7 DAYS BOTH CORE SPRAY SUBSYSTEMS ARE RECIRCULATION 1X8-2 OPERA 8LE. BOTH CORE SPRAY PUMP 18 (E8) SUBSYSTEMS WOULD BE OPERABLE AS DISCHARGE THEY ARE SUPPUED FROM E1 AND E2.

8YPASS VALVE 1-832-F0328 BNP UNITS 1 & 2 39 Revision 0

l l

l DISCUSSION OF CHANGES

! ITS: 3.8.1 - AC SOURCES-OPERATING l TABLE 4 (continued)

MOST LOAD TITLE POWER SUPPLY APPUCASLE ITS RESTRICTIVE AOT COMMENTS h CONTROL 120 VAC 3.7.4 30 DAYS NONE BUILDING PANEL SUPPLY FAN 2 2-20 VA 2E-SF-C8 (120/208 VITAL SUS 2E3)

DIV ll CONTROL 120 VAC 3.3.7.1 7 DAYS AUTO INITIATION ON HIGH RADIATION BUILDING LOGIC PANEL 3.7.3 (OlV lil WLL BE DISA8 LED. LOSS OF THE FOR CREV 2 AUTO INITIATION WLL RESULTIN A 7 DAY RECIRCULATION 120V AOT. LOSS OF ONE CONTROL ROOM FAN 28 (120/208 EMERGENCY FILTRATION UNIT ALSO DAMPER CONTROL AND VITAL BUS RESULTS IN A 7 DAY ACT.

h CREV SYSTEM 2E8)

HIGH RADIA-TION DIV 11 INITIATION RELAY CIRCUIT 00 4 MCC 3.8.1 7 DAYS ALSO,7 DAY AOT PROPOSED FOR TWO AUXILIARIES DGD OFFSITE ClhCulTS INOPERABLE AND DG (E.G., (E8) INOPERABM DUE TO BOP BUS (

STARTING AIR INOPERABIUTY PER TNis DISCUSSION OF COMPRESSORS) CHANGE.

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BNP UNITS 1 & 2 40 ReYision 0

, - - . . .- - - - - - - - _ - - = - - . . . _ - . - - - _ _ -

1 1

DISCUSSION OF CHANGES !

ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING l TECHNICAL CHANGES - LESS RESTRICTIVE LA.2 C.3 only allows this required equipment to be declared OPERABLE (cont'd) upon completion of transfer of the required equipment's DC electrical power distribution subsystem to its OPERABLE alternate DC source. For the DC electrical power distribution subsystem to be considered OPERABLE, it must be energized (i.e., power ;

available) . Therefore, to ensure compliance with the requirements !

of ITS 3.8.7 Required Action C.3 prior to declaring the affected '

required equipment OPERABLE, it will be necessary to ensure that the transfer has occurred to the OPERABLE alternate source by verifying the affected DC electrical power distribution subsystem is energized (i.e., power available) from the alternate source. A Therefore, the requirements of ITS 3.8.7 and the definition of &L '

OPERABLE-0PERABILITY are adequate to ensure that power is available to the affected supported equipment's DC electrical power distribution subsystem from its alternate source. As a result, the details of the method of performing actions (i.e., ,

l verification of power availability) are not necessary to be included in the Technical Specifications to provide adequate protection of the public health and safety. Changes to the Bases will be controlled by the provisions of the ITS Bases Control Program described in Chapter 5 of the ITS.

" Specific" i L.1 Not used. b L.2 With one or both units operating (in MODE 1, 2, or 3), the ACTION of CTS 3.8.2.1 provides an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Allowed Outage Time (A0T) for restoration of one or more inoperable 4.16 kV emergency buses (El, '

E2, E3, and E4), 480 V emergency buses (ES, E6, E7, and E8), and 120 V AC vital buses (IE5, IE6, 2E7, and 2E8). BNP Unit i ITS 3.8.7 ACTION,A provides a 7 day A0T for restoration of one AC l electrical power distribution subsystem made inoperable for planned maintenance due to either inoperable load group E3 or E4 d I buses and BNP Unit 2 ITS 3.8.7 ACTION A provides a 7 day A0T for ;

restoration of one AC electrical power distribution subsystem made inoperable for planned maintenance due to either inoperable load A group El or E2 buses. In addition, a maximum Completion Time of f.B l 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet the LCO is also l provided for consistency with the changes described in comment M.l. These 7 day A0Ts are only applicable for planned maintenance in the opposite unit is in MODE 4 or 5. If the opposite unit is Q 1 in MODE 1, 2, or 3, the ACTIONS of ITS 3.8.7 for the opposite unit would continue to require restoration of the affected AC electrical power distribution subsystem within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet the LCO.

g BNP UNITS 1 & 2 5 Revision 0

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.2 The BNP Units 1 and 2 Class IE AC Electrical Power Distribution (cont'd) System is divided into four load groups. Each load group consists of a primary emergency bus, its downstream secondary emergency bus, 120 VAC vital bus, and transformers and interconnecting cables. The buses associated with each of the four load groups are defined as follows:

Load group El consists of 4.16 kV bus El, 480 V bus ES, and 120,VAC vital bus IES.

l Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus IE6.

Load group E3 consists of 4.16 kV bus E3, 480 V bus'E7, and 120 VAC vital bus 2E7. ,

Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8.

The El and E2 load groups are supplied from Unit 1 balance of plant (B0P) buses and primarily serve Unit I loads. The E3 and E4 load groups are supplied from Unit 2 B0P buses and primarily serve Unit 2 loads. In some instances loads associated with one unit are actually supplied from the opposite unit's load group buses.

Each primary emergency bus (4.16 kV emergency bus) has access to two offsite sources of power via a coarm, circuit path from its associated upstream BOP bus (master ano -;4ve breakers and b

interconnecting cables). In addition each 4.16 kV emergency bus can be provided power from an onsite diesel gen m tor (DG) source.

The upstream B0P bus associated with each 4.16 SJ emergency bus is normally connected to the main generator output via the unit auxiliary transformer. During a loss of the normal power source to the 4.16 kV BOP bus, the preferred source supply breaker attempts to close. If all offsite sources are unavailable, the affected 4.16 kV emergency bus is isolated from its associated upstream 4.16 kV B0P bus and the onsite emergency DG will supply power to the 4.16 kV emergency bus. Control power for each 4.16 kV emergency bus is supplied from a Class IE battery with manual tranibr capability to another Class IE battery.

The seconk ry w t distribution system includes 480 VAC emergency i buses ES, E6, Ef, and E8 and associated motor control centers (NCCs), transformers, and interconnecting cables. Secondary emergency buses ES, E6, E7, and E8 are supplied from primary emergency buses El, E2, E3, and E4, respectively. Control power for each 480 VAC emergency bus is supplied from a Class IE battery with manual transfer capability to another Class IE battery.

The 120 VAC vital buses 1ES, IE6, 2E7, and 2E8 are arranged in four load groups and are powered from secondary emergency buses ES, E6, E7, and E8, respectively.

BNP UNITS 1 & 2 6 Revision 0 i i

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.2 Since loads associated with one unit are actually supplied from (cont'd) the opposite unit's load group buses, loss of an emergency bus associated with a shutdown unit affects some loads credited for support of systems used for mitigation of accidents and transients on the operating unit.

g The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months restoration time provided for one or more inoperable AC buses in CTS 3.8.2.1 does not provide sufficient time.to perform adequate planned maintenance on these buses. Planned maintenance on the shutdown unit's electrical buses cannot be performed Ib because the LCO still applies to the operating unit. Hence, dual unit outages are required in order to perform this maintenance.

Future dual unit outages are no longer planned for the BNP units.

Therefore, a 7 day A0T for the subject buses is required to provide sufficient ~ time to perform adequate preventive or I l corrective maintenance on the buses. This 7 day A0T would only i apply to buses primarily associated with the shutdown unit and would allow de-energization of only one emergency power system load group at a time. Should electrical buses associated with any l other Unit 1 or Unit 2 emergency power system load group be lost l concurrent with the planned load group outage, ITS 3.8.7 ACTION 8 (which provides an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months A0T) and ITS 3.8.7 ACTION F (which requires entry into LC0 3.0.3) would apply, as applicable.

l An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months A0T is provided for one or more inoperable AC buses in ,

CTS 3.8.2.1 when either one or both units are operating. This A0T !

l is based on the loss of multiple ECCS due to the loss of an AC !

l electrical power distribution system division when a unit is in !

l MODES 1, 2, or 3 and assumes that in this condition that the unit is vulnerable to a complete loss of AC power. This assumption A 1 would be true for a unit with only two 4.16 kV emergency buses.

However, the BNP design of the AC Electrical Power Distribution System includes four 4.16 kV emergency buses. In addition, the loads required for mitigation of accidents and transients are not ,

equally distributed across all four load groups (i.e., the El and i E2 load groups primarily serve Unit I loads and the E3 and E4 load groups primarily serve Unit 2 loads). Therefore, this A0T for the operating unit is overly restrictive with respect to the AC f electrical power distribution division load groups primarily associated with the shutdown unit. Increasing the A0T for restoration of one inoperable AC electrical power distribution division load group primarily associated with the shutdown unit is acceptable for the following reasons:

l 1) Operation with only three AC Electrical Power Distribution System load groups is already enveloped by the existing accident analysis which considers a LOCA/ LOOP on one unit and a safe shutdown of the other unit concurrent with the worst-case single failure (e.g., loss of one EDG). As part of the outage planning and risk assessment, outage planning will ensure the operability of required redundant Technical Specification equipment on the other three load groups of i BNP UNITS 1 & 2 7 Revision 0 i

1

. _ - - - - . - - - - - - - -.. - - . - =. - -. - -

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.2 the AC Electrical Power Distribution System prior to (cont'd) removing a shutdown unit's load group from service. In addition, the requirements of ITS 5.5.11. " Safety function Determination Program," will ensure that any concurrent inoperabilities that result in a loss of safety function do not exist (since the Technical Specification for the supported systems would not allow a 7 day A0T when a loss of safety function exists).

2) The proposed A0T for the inoperable AC Electrical Power Distribution System load group buses does not exceed the most restrictive A0T associated with the equipment they support. j i

, In some instances loads associated with one unit are l l supplied from the emergency power system buses associated I with the other unit. Tables 1 through 4 identify the most I

restrictive A0Ts for equipment supplied from each AC Electrical Power Distribution System load group for each unit. The tables were each prepared assuming that one load group primarily associated with the shutdown unit is removed from service while the other unit is operating. Each table identifies the operating unit's Technical Specification related loads supported from the load group to be taken out of service and caused to be inoperable by de-energization of the load group and provides the operating unit's most restrictive A0T duration associated with each of these loads. Tables 1 through 4 provide this information for all four load groups of AC Electrical Power Distribution System.

Based on Tables 1 through 4, the most restrictive A0T for Technical Specification equipment supported from an inoperable load group is 7 days. Hence, an A0T of 7 days is appropriate for an inoperable AC Electrical Power l Distribution System load group (E3 or E4 with Unit I l operating when Unit 2 is shutdown; El or E2 with Unit 2 i operating when Unit 1 is shutdown). )

3) The reliability of the affected huses will be increased as the longer A01 will allow planned maintenance of these buses C to be performed on a more optimum schedule. g

4) The change in core damage probability for the operating unit has been evaluated and is not significantly increased by d

extending the A0T of these buses to 7 days. This slight l increase in core damage probability is due to the longer period of time that a load group of the AC Electrical Power

! Distribution System is unavailable; during this time the AC Electrical Power Distribution System would not be able to b !

perform its safety function concurrent with a worst case single failure. Any small increases in risk resulting from BNP UNITS 1 & 2 8 Revision 0

1 DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE L.2 longer A0Ts are offset by the improved reliability gained by (cont'd) having the capability to perform maintenance on a more optimum schedule. Longer A0Ts also provide additional flexibility in scheduling maintenance activities and reduce the potential for unnecessary plant shutdowns caused by shorter'A0Ts.

In addition, 10CFR50.65, " Requirements for monitoring the effectiveness of maintenance at nuclear power plants,"

section (a)(2) acknowledges that preventive maintenance must be demonstrated to be effective in controlling the performance or condition of a structure, system or component (SSC) so that the SSC remains capable of performing its intended function. As such, licensees are directed to i establish appropriate preventive maintenance programs. The l 7 day A0T will provide the necessary time for appropriate !

preventive maintenance, which is at present insufficient. l l

The Brunswick Maintenance Rule program requires that high !

safety significant systems have performance criteria to '

monitor the effectiveness of preventive maintenance. The performance criteria establish acceptance limits for reliability and availability of the system. The overall impact of the performance limits on safety is assessed by evaluating their impact on the plant core damage frequency.

If the combination of the proposed reliability and availability limits for the system results in a core damage i frequency level that is within the limits of a non-risk significant condition, then the performance criteria are g

deemed acceptable. The core damage frequency acceptance l limits are based on industry guidance. The performance i criteria in the Brunswick Maintenance Rule Program include '

unavailability time for each B0P bus of 7 days, and they are acceptable per the core damage frequency limits. The impact on unavailability of the associated emergency buses is include in this assessment. l Furthermore, the reliability and availability of the buses are monitored under the Brunswick Maintenance Rule Program such that if the reliability or availability performance limits are exceeded for the buses, they are considered for section (a)(1) of the Maintenance Rule, which requires increased management attention and goal setting in order to restore their performance (i.e., reliability and availability) to an acceptable level. The intent of the Brunswick Maintenance Rule Program is to optimize reliability and availability of plant structures, systems and components by these methods.

BNP UNITS 1 & 2 9 Revision 0

DISCUSSION Of CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE l 1. 2 Extensive planning and reviews by BNP Safe Shutdown Risk l l (cont'd) Management personnel and the requirements of ITS 3.8.8,

" Distribution Systems - Shutdown," will ensure that the AC electrical power distribution subsystems necessary to support the ,

OPERABILITY of~ required equipment is maintained for the shutdown A unit during an outage of an AC Electrical Power Distribution m l System load group. Hence, there will not be an adverse impact to )

the shutdown unit. .

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BNP UNITS 1 & 2 10 Revision 0

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING l 1

TABLE 1 ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT 2 TECHNICAL SPECIFICATION LOADS !

SUPPLIED BY UNIT 1 DIVISION I ;

1 (THIS TABLE IDENTIFIES UNIT 2 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED l BY UNIT 1 DIVISION I. THE TABLE ASSUMES UNIT 2 IS AT POWER AND UNIT 1 IS ,

SHUTDOWN WITH ITS DIVISION I EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF l SERVICE.) l MOST LOAD POWER APPUCABLE RESTRIC1WE COMMENTS TITLE SUPPLY STS AOT RHRSW PUMP El 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABLE - 14 DAYS 2C MOTOR ONE RHRSW SUBSYSTEM INOPERABLE 7 DAYS RHR PUMP 2C El 3.5.1 7 DAYS LPCI - 7 DAY AOT PROVIDED BOTH ONIT 2 MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE OPERABLE. BOTH UNIT 2 CORE SPRAY SUBSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM E3 AND E4.

SUPPRESSION POOL COOUNG - 7 DAY AOT.

NSW PUMP 1 A El 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE, CSW PUMP 2C El 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE.

SUBSTATION E6 El 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER THIS DISCUSSION OF CHANGE.

120/208V VITAL E6 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER BUS 1E6 THIS DISCUSSION OF CHANGE.

l l

INCOMIN( . E1 3.8.1 24 HOURS 1 DAY AOT PROPOSED FOR THIS l FEEDER FOM INOPERABluTY DUE TO BOP BUS OUTAGE l 4160 V BO& PER THIS DISCUSSION OF CHANGE.

BUS 10 l

)

BNP UNITS 1 & 2 11 Revision 0 I

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DISCUSSION OF CHANGES ITS: 3c8.7 - DISTRIBUTION SYSTEMS-OPERATING l

( TABLE 1 (Continued)

MOST LOAD TIT 1.E POWER SUPPLY APPUCABLE ITS RESTRICTIVE AOT CW h CONTROL MCC1- 3.7.3 7 DAYS LOSS OF ONE CONTROL SulLDiNG HVAC BUILDING HVAC 1CA SYSTEM CONTROL AIR COMPRESSOR l

SYSTEM (E6) RESULTS IN THE CREV SYSTEM No CONTROL AIR LONGER MEETING SINGLE FAaLURE COMPRESSOR, CRITERIA. AS A RESULT, ONE CREV 2-VA-28-AC-C8 SUBSYSTEM WILL BE DECLARED INOPERABLE WHICH RESULTS IN A 7 DAY AOT.

CONTROL MCC1- 3.7.4 30 DAYS NONE BUILD (NG 1CA SUPPLY FAN 1- (ES) C VA 10-SF C8 CONTROL MCC1 3.7.4 SODAYS NONE BUILDING ICA A/C (ES)

CONDENSER VA 10-CU-06 CONTROL 120 VAC 3.7.4 30 DAYS NONE BUILDING 1 1 C.

SUPPLY FAN 120V VA 10-SF-C8 (HYO)

CONTROL (120/208 CIRCUIT VITAL BUS 1E6) 1 A-1 BATTERY MCC1 3.8.4 7 DAYS NONE CHARGER AC ICA INPUT NORMAL FEED (E6) h 1 A 2 DATTERY MCC1- 3.8.4 7 DAYS NONE CHAF.3ER AC 1CA INPUT NORMAL FEED (ES) h NSW PUMP 1 A MCC1 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW b

STRAINER SW- 1PA PUMP AND ONE REQUIRED CSW PUMP 1 A-NUC-PMP- (E6) INOPERABLE.

STR BNP UNITS 1 & 2 12 ReYision 0

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DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING TABLE 1 (Continued) 1 TOAD ,0 - A,PuCA.m MOST

.ESn.C CO.M 18 k

TITLE SUPPLY ITS AOT l

NSW PUMP 1 A MCC1 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW DISCHARGE 1PA PUW AND ONE REQUIRED CSW PUMP VALW SW-V19 (ESI INOPERABLE.

CSW PUMP 2C MCC1 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW I

DISCHARGE TO 1PA PUMP ANO ONE REQU6AED CSW PUMP NUCLEAR (E6) INOPERA8LE. -

HEADER VALVE 2-SW-Vis CSW PUMP 2C MCC1 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW DISCHARGE 1PA PUMP AND ONE REQUIRED CSW PUMP /\

VALVE 2-SW. (ES) INOPERA8LE. lOC.

V17 CSW PUMP 2C MCC1 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW STRAINER 2.SW. IPA PUMP AND ONE REQUIRED CSW PUMP 2C-CONV-PMP.

STR (ES) INOPERABLE.

h .

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l BNP UNITS 1 & 2 13 Revision 0 l

.- . _ . . - - .. - - -.-- _._-.~.-- - _. -- -

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING 1

TABLE 1 (Continued)

LOAD POWER APPLICA8LE MOST RESTRICTIVE COMMENTS h TITLE SUPPLY ITS AOT RHR OUT80ARD MCC2 3.6.1 7 DAYS VALVES 2-E11-F016A AND 2-E11-F017A INJECTION 2XA-2 3.6.1.3 ARE THE UNIT 2 LOOP A HHR IN8OARD ,

VALVE 2-E11 (E6) AND OUT80ARD INJECTION VALVES USED I F017A FOR LPCI. THE F016A VALVE IS 1 NORMALLY Cl.OSED ANO THE F017A VALVE IS NORMALLY OPEN. DURING AN ACCIDENT THE F016A OPENS WHEN REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCI INJECTION.

l THESE VALVES ARE ALSO PRIMARY CONTAINMENT ISOLATION VALVES. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8LE PROVIDED THE AFFECTED PENETRATION 16 RHR IN80ARO MCC2- 3.6.1 7 DAYS ISOLATED.

INJECTION 2XA-2 3.6.1.3 VALVE 2-E11 (ES) C, i

F016A THIS TS CAN BE MET DURING THE MCC l OUTAGE BY PLACING SOTH VALVES IN A l CLOSED POSITION ANO REMOVING CONTROL POWER TO THE VALVES. i UNDEP. TS 3.6.1 THIS WILL CAUSE THE UN8T 2 LOOP A OF LPCI TO BE INO72RA8LE. WITH ONE LPCI SUBSYSTEM INOPERABLE ITS 3.6.1 REQUIRES THAT THE SU8 SYSTEM BE RESTORED WITHIN 7 DAYS PROVIDED BOTH CORE SPRAY SUBSYSTEMS ARE OPERA 8LE. BOTH UNIT 2 CORE SPRAY SUBSYSTEM SYSTEMS WOULD BE OPERABLE AS THEY AnF Rttppt IFn Fnou FM AMn Fd l

l I

i BNP UNITS 1 & 2 14 ReYision 0 i

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.. --- - - ..~. . . . - - -- - .-- _ _ . _ - - - - _ . .. . - . _ - - . - . .

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABt.E 1 (Continued)

MOST LOAD POWER APPUCABLE RESTRICTIVE COMIMNTS TITLE SUPPLY ITS AOT RHR TORUS MCC2- 3.5.1 7 DAYS VALVE 2-E11-F028A IS THE RHR TORUS SPRAY VALVE 2XA 2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE 2-E11-F028A (ES) 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI INITIATION TO PROVICE TORUS I ISOLATION.

THIS VALVE IS ALSO A PRIMARY CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT l ISOLATION VALVE INOPERA8tf PROVIDED THE PENETRATION IS ISOLATED.

THIS TS CAN BE MET DURING THE MCC OUTAGE BY PLACING THIS VALVE IN A CLOSED POSITION AND REMOVING CONTROL POMR TO THE VALVE.

TS 3.5.1 REQUIRES THAT THE F028A VALVE CLOSE ON A LPCIINITIATION I SIGNAL TO ENSURE AN OPERA 8LE PATH l TO THE REACTOR VESSEL (if F028A IS OPEN THE LPCI FLOW WOULD BE PARTIALLY DIVERTED BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 84UTY OF THIS LPCI LOOP.

HOWEVER, CLOSING THE F028A VALVE WOULD CAUSE LOOP A OF SUPPRESSION POOL COOUNG TO BE INOPERA8LE. WITH l CNE INOPERABLE LOOP OF SUPPRESSION I POOL COOUNG, TS 3.6.2.3 REOUIRES THAT THE LOOP BE RESTORED WITHIN 7 0AYS.

BNP UNITS 1 & 2 15 Revision 0

. .- - .- - . - - - - . . _ - . ~ . - - . _ - - -. _ _ _ -

I DISCUSSION OF CHANGES 1 ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING I TABLE 1 (Continued)

MOST LOAD POWER APPUCABLE RESTRICTWE TITLE SUPPLY ITS ACT COMANNTS A Ltu RX MCC2- 3.6.1 7 DAYS THE A8luTY OF THESE VALVES TO CLOSE REURCULATION 2XA-2 IS A REQUIREMENT FOR LPCI PUMP 2A (E6) OPERA 88UTY. OF THESE VALVES ARE DISQiARGE INOPERABLE AND OPEN, THEN PER THE j VALVE 2432 8ASES OF TS 3.5.1 THE ASSOCIATED LPCI '

F031A SUBSYSTEM MUST BE DECLARED INOPERA8LE. 7 DAY ACT FOR ONE INOPERA8LE LPCI SUBSYSTEM PROVIDED RX MCC2 3.6.1 7 DAYS SOTH CORE SPRAY SUBSYSTEMS ARE RECIRCULATION 2XA 2 OPERA 8LE. BOTH CORE SPRAY PUMP 2A (E6) SUBSYSTEMS WOULD BE OPERABLE AS .

DISCHARGE THEY ARE SUPPUED FROM E3 AND E4.

C l'

8YPASS VALVE 2432-F032A AREA 120 VAC 3.3.7.1 N/A LOSS OF THIS ORCUIT Wlu. CAUSE A RADIATION 1 1 A8 CONTROL BUILDING EAF INtTIATION MONITORING, (120/208 SIGNAL DUE TO THE LOSS OF THE D22-P600. ES. VITAL REQUIRED RADIATION MONITORS IN THE K603A BUS CONTROL ROOM AREA. PER TS 3.3.7.1 IE6) REQUIRED ACTION A.1 THE LOSS OF MORE THAN ONE DETECTOR REQUIRES THAT BOTH SUBSYSTEMS BE DECLARED INOPERA8LE WITHIN ONE HOUR. THIS CAN BE AVO4DED BY TRANSFERRING 120VAC PANEL 1 1 A8 FROM ITS NORMAL 1E6 SUPPLY (FROM E1K6) TO ITS 1E6 ALTERNATE SUPPLY (FROM E2K6) DURING THE DE-ENERGtZATION OF E1/EE/1E6.

DG 1 MCC2 3.8.1 7 DAYS ALSO 7 DAY ACT PROPOSED FOR TWO AUX 1UARIES DGA OFFSITE ORCulTS INOPERA8tE AND DG (E.G., STARTING (ES) INOPERA8LE DUE TO BOP BUS OUTAGE AIR CO M. PER THIS DISCUSSION OF CHANGE.

PRESSORS) b i

l l

?

BNP UNITS 1 & 2 16 Revision 0 k

i ._ _ _ _

_ _ _ -_. - - .-. ~.. . -- - - - .- - . -.

I DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING 1

TABLE 2 ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT 2 TECHNICAL SPECIFICATION LOADS SUPPLIED BY UNIT 1 DIVISION II 1

1 (THIS TABLE IDENTIFIES UNIT 2 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED BY UNIT 1 DIVISION II. THE TABLE ASSUMES UNIT 2 IS AT POWER AND UNIT 1 IS SHUTDOWN WITH ITS DIVISION II EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF SERVICE.)

MOST LOAD POWER APPUCABLE RESTRICTIVE COMMENTS TITLE SUPPLY ITS AOT RHRSW PUMP E2 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABLE - 14 DAYS 20 MOTOR ONE RHRSW SUBSYSTEM INOPERABLE - 7 DAYS RHR PUMP 2D MOTOR E2 3.6.1 3.6.2.3

/ DAYS LPCI- 7 DAY AOT PROVIDED BOTH UNIT 2 CORE SPRAY SUBSYSTEMS ARE h OPERABLE. BOTH UNIT 2 CORE SPRAY SUBSYSTEMS WOULD BE OPERABLE AS THEY' ARE SUPPUED FROM E3 AND E4.

SUPPRESSION POOL COOUNG - 7 DAY l ACT NSW PUMP IB E2 3.7.2 7 DAYS NONE MOTOR SUBSTATION E6 E2 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THis BUS PER THIS DISCUSSION OF CHANGE.

120/208V VITAL E6 3.8.7 8 HOURS 7 DAY ACT PROPOSED FOR THIS BUS PER BUS 1E6 THIS D(SCUSSION OF CHANGE.

(NO TECHNICAL SPECIFICATION LOADS REQUIRED FOR UNIT 2)

INCOMINO E2 3.8.1 24 HOURS 7 DAY AOT PROPOSED FOR THIS FEEDER FROM INOPERABluTY DUE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS IC 181 BATTERY MCC1- 3.8.4 7 DAYS NONE CHARGER AC ICB INPUT NORMAL (E6)

FEED l

BNP UNITS 1 & 2 17 Revision 0 l

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_ . .. _ _ _ _ . . . . .___ . _ _ ~ _ _ _ . _ _ _ _ . _ _ - __ _ _ _ . . _ _

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBLTTION SYSTEMS-OPERATING TABLE 2 (Continued)

MOST LOAD TITLE POWER SUPPLY APPLICABLE ITS flESTNCTIVE AOT C N mTS g 18-2 BATTERY MCC1 3.7.4 ' DAYS NONE CHARGER AC IC8 INPUT NORMAL (E61 r FEED NSW PUMP 18 MCC1 3.7.2 7 DAYS NONE STRAINER SW. 1P8 18-NUC-PMP- (E6)

STR NSW PUMP 18 MCC1 3.7.2 7 DAYS NONE DISCHARGE 1P6 VALVE SW-V20 (E6)

RHR OUT80ARD MCC2 3.6.1 7 DAYS VALVES 2-E11-F0158 AND 2-E11 F0178 INJECTION 2XB-2 3.6.1.3 ARE THE UMT 2 LOOP 8 RHR IN80ARD VALVE 2-E11 (E6) AND OUT8OARD INJECTION VALVES USED F0178 FOR LPCI. THE F0158 VALVE IS NORMALLY CLOSED AND THE F0178 VALVE IS NORMALLY OPEN. DURING AN ACCIDENT THE F0158 OPENS WHEN REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCI INJECTION.

THESE VALVES ARE ALSO PRIMARY CONTAINMENT ISOLATION VALVES. PER TS 3.6.1.3 OPERATION MAY CONTINUE W1TH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERABLE PROVIDED THE AFFECTED PENETRATION IS RHR IN80ARO MCC2- 3.6.1 7 DAYS INJECTION 2XB 2 3.6.1.3 THIS TS CAN BE MET DURING THE MCC l VALVE 2-E11 (E6)

OUTAOE BY PLACING BOTH VALVES IN A F0158 CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVES.

UNDER TS 3.5.1 THis WR1 CAUSE THE UNIT 2 LOOP 8 OF LPCI TO BE INOPERABLE. WITH ONE LPC1 SUBSYSTEM INOPERABLE, TS 3.5.1 REQUIRES THAT THE SUBSYSTEM BE RESTORED WITHIN et 7 DAYS PROVIDED BOTH CORE SPRAY SUBSYSTEMS ARE OPERABLE. BOTH UNIT 2 CORE SPRAY SYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM E3 AND E4.

BNP UNITS 1 & 2 18 Revision 0 i

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. - . - . - , .. -. - - - - - . . - . . . .. - - ~-_ -. __- . - - . - - -.

I DISCUSSION OF CHANGES l'

ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABLE 2 (Continued)

MOST LOAD TITLE POWER SUPPLY APPUCABLE ITS RESTRICTIVE AOT COMMENTS h

RHR 10808 MCC2 3.5.1 7 DAYS VALVE 2-E11.F0288 IS THE RHR TORUS SPRAY VALVE 2XB-2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE 2-E11-F0288 (E6) 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI INITIATION TO PROVIDE TORUS ISOLATION.

THIS VALVE IS ALSO A PRIMARY CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PR6 MARY CONTAINMENT ISOLATION VALVE INOPERABLE PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

THIS TS CAN SE MET DumNG THE MCC OUTAGE BY PLACING THIS VALVE IN A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVE.

TS 3.5.1 REQUIRES THAT THE F0288 l

VALVE CLOS; ON A LPCI INITIATION SIGNAL TO ENSURE AN OPERABLE PATH TO THE REACTOR VESSEL (IF F0288 IS l

OPEN THE LPCI FLOW WOULD BE PARTIALLY DIVERTEO BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 8tuTY OF THIS LPCI LOOP.

HOWEVER, CLOSING THE F0288 VALVE WOULD CAUSE LOOP 8 OF SUPPRESSION POOL COOUNG TO BE INOPERA8LE. WITH ONE INOPERABLE LOOP OF SUPPRESSION POOL COOUNG, TS 3.6.2.3 REQUIRES THAT THE LOOP SE RESTORED WITHIN 7 DAYS.

RX MCC2- 3.6.1 7 DAYS THE AIMUTY OF THESE VALVES TO CLOSE RECIRCULATION 2XB-2 IS A REQUIREMENT FOR LPCI PUMP 28 DISCHARGE (E6) OPERA 81UTY. IF THESE VALVES ARE INOPEl@BLE AND OPEN, THEN PER THE h

VALVE 2-832 BASES OF TS 3.6.1 THE ASSOCIATED LPCI F0318 SUBSYSTEM MUST BE DECLARED INOPERABLE. 7 DAY AOT FOR ONE RX McC2 3.8.1 7 DAYS INOPERABLE LPCI SUBSYSTEM PROVIDED RECIRCULATION 2X8 2 BOTH CORE SPRAY SU8 SYSTEMS ARE PUMP 28 DISCHARGE (E6) OPERA 8LE. SOTH CORE SPRAY SUBSYSTEMS WOULD SE OPERA 8LE AS h

8YPASS VALVE THEY ARE SUPPUED FROM E3 AND E4.

2-832-F0328 h

BNP UNITS 1 & 2 19 Revision 0

, . _ _ , ,, - . . _ _ _ . ~. . - - .. --

i l

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABLE 2 (Continued)

MOST l LOAD POWER APPUCASLE RESTRICTIVE COMMENTS I TITLE SUPPLY ITS AOT ' '

DG 2 MCC2 3.8.1 7 DAYS ALSO,7 DAY ACT PROPOSED FOR TWO AUXIUARIES DG8 OFFSITE CIRCUITS INOPERABLE ANO DG (E.G., STARTING (E6) INOPERABLE DUE TO BOP BUS OUTAGE AIR COM. PER THIS DISCUSSION OF CHANGE.

PRESSORS) b l l

1 BNP UNITS 1 & 2 20 Revision 0

f-i~

l DISCUSSION OF CHANGES 1 ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING l TABLE 3 ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT I TECHNICAL SPECIFICATION LOADS SUPPLIED BY UNIT 2 DIVISION I

(

l (THIS TABLE IDENTIFIES UNIT I TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED BY UNIT 2 DIVISION 1. THE TABLE ASSUMES UNIT I IS AT POWER AND UNIT 2 IS SHUTDOWN WITH ITS DIVISION I EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF SERVICE.)

MOST

! LOAD POWER APPUCABLE RESTRICTIVE COMMENTS l TITLE SUPPLY ITS AOT l RHRSW PUMP E3 3.7.1 7 DAYS ONE RHRSW PUMP INOPERA8LE - 14 DAYS 1 A MOTOR ONE RHRSW SUBSYSTEM INOPERA8LE - 7 DAYS f

RHR PUMP 1 A E3 3.6.1 7 DAYS LPCI . 7 DAY AOT PROVIDED BOTH UNIT 1 MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE /,\

OPERABLE. BOTH UNIT 1 CORE SPRAY W i j

SUBSYSTEMS WOULD BE OPERA 8LE AS THEY ARE SUPPUED FROM El AND E2.

SUPPRESSION POOL COOUNG - 7 DAY AOT.

NSW PUMP 2A E3 3.7.2 7 DAYS NONE l

MOTOR j SUBSTATION E7 E3 3.8.7 8 HOURS 7 DAY ACT PROPOSED FOR THIS BUS PER THIS DISCUSSION OF CHANGE.

120/208V VITAL E7 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER BUS 2E7 THIS DISCUSSION OF CHANGE. k INCOMING E3 3.8.1 24 HOURS 7 DAY ACT PROPOSED FOR THIS FEEDER FROM INOPERA88UTY DUE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS 20 2A 1 BATTERY MCC2 3.8.4 7 DAYS NONE CHARGER AC 2CA INPUT NORMAL FEED (E7) h 2A-2 BATTERY MCC2 3.8.4 7 DAYC NONE b

CHARGER AC 2CA INPUT NORMAL (E7) C FEED b

t

{ BNP UNITS I & 2 21 Revision 0 i

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DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING TA81.E 3 (Continued)

LOAo POWER APPuCAsts MOST RESnuCTivE cananaa mi h

TITLE SUPPLY ITS AOT NSW PUMP 2A MCC2 3.7.2 7 DAYS NONE STRAINER SW. 2PA 2A-NUC-PMP- (E7)

STR l

NSW PUMP 2A MCC2- 3.7.2 7 DAYS NONE DISCHARGE SW- 2PA V18 (E7) C CONTROL MCC2- 3.7.3 7 DAYS LOSS OF ONE CONTROL BUILDING HVAC BUILDING HVAC 2CA SYSTEM CONTROL AIR COMPRESSOR SYSTEM (E7) 'RESULTS IN THE CREV SYSTEM NO CONTROL AIR LONGER MEETWG SINGLE FAILURE COMPRESSOR. CRITERIA. AS A RESULT, ONE CREV l VA 2A AC-C8 SUBSYSTEM WILL BE DECLARED

! INOPERABLE WHICH RESULTS IN A 7 DAY

! /\

AOT. j

/A

, CONTROL MCC2- 3.7.3 7 DAYS LOSS OF ONE CONTROL ROOM l SUILDING 2CA EMERGENCY FILTRATION UNU DOLTS IN l EMERGENCY 'F7) A 7 DAY AOT.

RECIRCULA-TION AIR FAN VA 2A-ERF-C8 CONTROL MCC2- 3.7.4 30 DAYS NONE BUILDING 2CA NC (E7)

CONDENSER VA-20-CU-C8 CONTROL MCC-2 3.7.4 30 DAYS NONE l

BUILDING 2CA SUPPLY FAN (E7) I VA-2D-SF-C8 CONTROL 120 VAC 3.3.7.1 7 DAYS CREV SYSTEM AUTO INITIATION ON HIGH BUllDING PANEL 2- 3.7.4 RADIATION (DIV 1) WILL BE DISA8 LED. '

SUPPLY FAN 2- 2C LOSS OF THE AUTO NT!ATION WILL VA-2D-SF-C8 (120/208 RESULT IN A 7 DAY AOT. PER TS 3.7.4 ANO CREV VITAL LOSS OF ONE SUPPLY FAN IS A 30 DAY C SYSTEM HIGH BUS AOT.

RADIATION 2E7)

DfV 1 NTIATION RELAY CIRCUlT h

l i

BNP UNITS 1 & 2 22 Revision 0 t

h

- ax ,--

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING i TABLE 3 (Continued) 4 MOST LOAD POWER APPLICABLE RESTRICTIVE COMMENTS 11RE SUPPLY ITS ACT l l

DIVISION 1 120 VAC 3.7.3 7 DAYS LDSS OF ONE CONTROL ROOM CONTROL PANEL 2 EMERGENCY FILTRATION UNIT RESULTS IN BUILDING LOGIC 2C A 7 DAY ACT FOR CREV (120/208 SYSTEM VITAL RECIRCULA. BUS T10N FAN 2A 2E7)

DAMPER CONTROL A

w RHR OUT80ARD MCC1 3.5.1 7 DAYS VALVE 1-(11 F015A AND 1-E11.F017A INJECTION 1XA-2 3.8.1.3 ARE THE UNIT 1 LOOP A RHR IN80ARD VALVE 1-E11- (E7) AND OUT80ARD INJECTION VALVES USED C F017A FOR LPCI. THE F015A VALVE IS NORMALLY CLOSED AND THE F017A VALVE IS NORMALLY OPEN. DURING AN ACCIDENT THE F015A OPENS WHEN REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCI INJECTION.

THESE VALVES ARE ALSO PRIMARY CONTAINMENT ISOLATION VALVES. PER l TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8LE PROVIDED -

THE AFFECTED PENETRATION IS I ISOLATED.

RHR IN8OARD MCC1- 3.5.1 7 DAYS INJECTION IXA-2 3.6.1.3 THIS TS CAN BE MET DURING THE MCC VALVE 1-E11- (E7) OUTAGE BY PLACING SOTH VALVES IN A F015A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVES.

UNDER TS 3.5.1 THIS WILL CAUSE THE UNIT 1 LOOP A OF LPCI To bE INOPERA8tE. WITH ONE LPCI SUBSYSTEM INOPE.M. TS 3.5.1 REQUIRES THAT THE SUBSYSTEM be etESTORED WITHIN 7 DAYS PROVIDED BOTH CORE SPRAY SUBSYSTEMS ARE OPERA 8LE. 80TH UNIT 1 CORE SPRAY SYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM Et AND E2.

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BNP UNITS 1 & 2 23 Revision 0 4

i

.- _ _ _ _ . - .__m .__ ___ - . _ . _ _ _ _ _ . . _ . . . _ .- _ . . . _ _ . _ . _ . . _ _ _ _

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DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING L

TABLE 3 (Continued)

MOST LOAD TITLE POWER SUPPLY APPUCABLE ITS RESTRICTIVE AOT COMMOfTS h RHR TORUS MCC1 3.5.1 7 DAYS VALVE 1-E11 F028A IS THE RHR TORUS SPRAY VALVE 1XA 2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE 1-E11 F02SA (E7) 3.6.1.3 AUTOMATICALLY CLOSES ON LPCI INIT1ATION TO PROVIDE TORUS ISOLATION.

THis VALVE IS ALSO A PRIMARY CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8LE PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

THIS TS CAN BE MET DURING THE MCC OUTAGE BY PLACING THIS VALVE IN A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVE.

TS 3.5.1 REQUIRES THAT THE F028A VALVE CLOSE ON A LPCIINITIATION -

SIGNAL TO ENSURE AN OPERABLE PATH l TO THE REACTOR VESSEL (IF F028A IS OPEN THE USCI FLOW WOULD BE PARTIALLY DIVERTED BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 84UTY OF THIS LPCI LOOP.

HOWEVER. CLOSING THE F028A VALVE WOULD CAUSE LOOP A OF SUPPRESSION POOL COOUNG TO BE INOPERA8LE. WITH ONE INOPERABLE LOOP OF SUPPRESSION l POOL COOUNG, TS 3.6.2.3 REQUtRES THAT THE LOOP BE RESTORED WITHIN 7 DAYS.

RX RECIRCULA- MCC1 3.6.1 7 DAYS THE A8iUTY OF THESE VALVES To CLOSE TION PUMP 1 A 1XA 2 IS A REQUIREMENT FOR LPCI DISCHARGE (E7) OPERA 84UTY. IF THESE VALVES ARE VALVE 1-832 INOPERABLE AND OPEN. THEN PER THE F031A BASES OF TS 3.5.1 THE ASSOCIATED LPCI

, SUBSYSTEM MUST BE DECLARED RX RECIRCULA- MCC1 3.5.1 7 DAYS INOPERA8LE. 7 DAY AOT FOR ONE INOPERA8LE LPCI SUBSYS TEM PROV10ED h

TION PUMP 1 A 1XA 2 80TH CORE SPRAY SUBSYSTEMS ARE DISCHARGE BYPASS VALVE (E7) OPERABLE. 80TH CORE SPRAY SUBSYSTEMS WOULD BE OPERA 8LE AS h

1832f032A THEY ARE SUPPUED FROM El AND E2.

! BNP UNITS 1 & 2 24 Revision 0 4

I l

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DISCUSSION Of CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABLE 3 (c.'ntinued)

MOST LOAD POWER APPUCABLE RESTNCTIVE COMMENTS TITLE SUPPLY ITS ACT DG 3 MCC.2 3.8.1 7 DAYS ALSO. 7 DAY ACT PROPOSED FOR THE l AUXiUARIES - DCC OFFSITE CIRCulTS INOPERABLE ANO DG (E.G., STARTING AIR COM.

(E7) INOPERABLE DUE TO BOP BUS INOPERA84UTY PER THIS D4SCUSSION OF lh PRESSORS) CHANGE, b f 1

l 1

1 l

l BP UNITS 1 & 2 25 Revision 0 i

DISCUSSION OF CHANGES s ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABLE 4 ALLOWED OUTAGE TIMES (A0Ts) 0F UNIT 1 TECHNICAL SPECIFICATION LOADS SUPPLIED BY UNIT 2 DIVISION II (THIS TABLE IDENTIFIES UNIT 1 TECHNICAL SPECIFICATION LOADS WHICH ARE SUPPLIED BY UNIT 2 DIVISION II. THE TABLE ASSUMES UNIT I IS AT POWER AND UNIT 2 SHUTDOWN WITH ITS DIVISION II EMERGENCY AC POWER DISTRIBUTION SYSTEM OUT OF SERVICE.)

MOST LOAD POWER APPUCABLE RESTP8CTIVE COMMENTS TITLE SUPPLY ITS AOT RHRSW PUMP E4 3.7.1 7 DAYS ONE RHRSW PUMP INOPERABLE .14 DAYS 18 MOTOR ONE RHRSW SUBSYSTEM INOPERABLE 7 DAYS RHR PUMP 18 E4 3.5.1 7 DAYS LPCI 7 DAY ACT PROVIDED BOTH UNIT 1 MOTOR 3.6.2.3 CORE SPRAY SUBSYSTEMS ARE OPERA 8LE. BOTH UNIT 1 CORE SPRAY SUBSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM El AND E2.

g SUPPRESSION POOL COOUNG 7 DAY AOT.

.e NSW PUMP 2B E4 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE.

CSW PU!AP 1 A E4 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW MOTOR PUMP AND ONE REQUIRED CSW PUMP INOPERABLE.

SUBSTATION E8 E4 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER THIS DISCUSSION OF CHANGE.

120/208V E8 3.8.7 8 HOURS 7 DAY AOT PROPOSED FOR THIS BUS PER VITAL BUS 2E8 THIS DISCUSSION OF CHANGE.

INCOMING E4 3.8.1 24 HOURS 7 DAY ACT PROPOSED FOR THIS FEEDER FROM INOPERABluTY DOE TO BOP BUS OUTAGE 4160 V BOP PER THIS DISCUSSION OF CHANGE.

BUS 2C CONTROL MCC2- 3.7.3 7 DAYS LOSS OF ONE CONTROL ROOM BUILDING 2CB EMERGENCY FILTRATION UNIT RESULTS IN EMERGENCY RECIRCULATION (E8) A 7 DAY AOT.

h AIR FAN 2.VA.

28-ERF-C8 BNP UNITS I & 2 26 ReYision 0

DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTENS-OPERATING TABLE 4 (Continued)

MOST LOAD POWER APPUCA8LE RESTWCTIVE COMMetTE TITLE SUPPLY ITS AOT 28-2 BATTERY MCC2- S.8.4 7 DAYS NONE CHARGER AC 2C8 INPUT NORMAL (ES)

FEED 281 BATTERY MCC 2 3.8.4 7 DAYS NONE CHARGER AC 2C8 INPUT NORMAL (ES)

FEED CONTROL MCC2- 3.7.4 30 DAYS NONE BUILDING 2C8 NC (E8)

CONDENSER VA-2E-CU-C8 CONTROL MCC2 3.7.4 30 DAYS NONE BUILDING 2CD SUPPLY FAN (E8)

VA-2E-SF48 NSW PUMP 28 MCC2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW STRAINER SW- 2PB PUMP AND ONE REQUIRED CSW PUMP 28-NUC PMP- (E8) INOPERABLE-STR NSW PUMP 28 MCC2- 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW OISCHARGE 2PB PUMP AND ONE REQUIRED CSW PUMP VALVE SW-V20 (E8) INOPERABLE.

CSW PUMP 1 A MCC2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQUIRED NSW OtSCHARGE TO 2PA PUMP AND ONE REQUIRED CSW PUMP NUCLEAR (ES) INOPERABLE.

HEADER VALVE 1-SW-V14 CSW PUMP 1 A MCC2- 3.7.2 7 DAYS 7 DAY ACT FOR ONE REQUIRED NSW DISCHARGE 2PA PUMP AND ONE REQUIRED CSW PUMP VALVE 1 SW- (E8) INOPERA8LE.

V13 CSW PUMP 1 A MCC2- 3.7.2 7 DAYS 7 DAY AOT FOR ONE REQU(RED NSW STRAINER 2PA PUMP AND ONE REQUIRED CSW PUMP VALVE 1 SW. (E8) INOPERABLE.

1 A-CONV-PMP-STR h

BNP UNITS 1 & 2 27 Revision 0

l DISCUSSION OF CHANGES l ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABLE 4 (Continued) j MOST )

LOAD- POWER APPUCABLE RESTRICTIVE COMMENTS 1 TITLE SUPPLY ITS AOT h '

RHR OUTBOARD MCC1- 3.6.1 7 DAYS I VALVES 1-E11-F0158 AND 1-E11-F0178 -

INJECTION 1X8 2 3.6.1.3 - ARE THE UNIT 1 LOOP B RHR IN80ARD VALVE 1-E11- (E8) AND OUTBOARD INJECTION VALVES USED ,

F0178 FOR LPCI. THE F0158 VALVE IS i NORMALLY CLOSED AND THE F0178 l

VALVE IS NORMALLY OPEN. DURING AN ACCIDENT THE F0158 OPENS WHEN REACTOR PRESSURE DROPS TO 410 PSIG TO PERMIT LPCIINJECTION.

THESE VALVES ARE ALSO PRIMARY CONTAIN- MENT ISOLATION VALVES. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8tf .PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

RHR INBOARD MCC1- 3.5.1 7 DAYS )

INJECTION 1XB-2 3.6.1.3 THIS TS CAN 8E MET DURING THE MCC VALVE 1-E11 (ES) OUTAGE BY PLACING SOTH VALVES IN A F0158 CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVES.

UNDER TS 3.5.1 THIS WILL CAUSE THE UNIT 1 LOOP 8 OF LPCI TO BE INOPERABLE. WITH ONE LPCI SUBSYSTEM INOPERABLE, TS 3.6.1 REQUIRES THAT THE SUBSYSTEM BE RESTORED WITHIN I 7 DAYS PROVIDED BOTH CORE SPRAY l SUBSYSTEMS ARE OPERABLE. BOTH ;

UNIT 1 CORE SPRAY SUSSYSTEMS WOULD BE OPERABLE AS THEY ARE SUPPUED FROM E1 AND E2.

l.

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BNP UNITS I & 2 28 Revision 0 I

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l' l DISCUSSION OF CHANGES

l. ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING l

TABLE 4 (Continued)

MOST LOAo TIT W POwsn SUPPLY APPuCA8u ITS REsincTIVE AOT COMMENTS g l

RHR TORUS McC1- 3.5.1 7 DAYS VALVE 1411 F0248 IS THE RHR TORUS SPRAY VALVE 1X8-2 3.6.2.3 SPRAY DISCHARGE VALVE. THIS VALVE i

1411M288 (ES) 3.6.1.3 AUTOMATICALLY CthSES ON LPCI

l. INITIATION TO PROVIDE TORUS ISOLATION.

THIS VALVE IS ALSO A PRIMARY CONTAINMENT ISOLATION VALVE. PER TS 3.6.1.3 OPERATION MAY CONTINUE WITH A PRIMARY CONTAINMENT ISOLATION VALVE INOPERA8E PROVIDED THE AFFECTED PENETRATION IS ISOLATED.

l THIS TS CAN 8E MET DURING THE MCC OUTAGE BY PLACING THis VALVE IN A CLOSED POSITION AND REMOVING CONTROL POWER TO THE VALVE.

TS 3.6.1 REQUIRES THAT THE F0288 VALVE CLOSE ON A LPCIINITIATION SIGNAL TO ENSURE AN OPERABLE PATH '

TO THE REACTOR VESSEL (IF F0288 IS OPEN THE LPQ FLOW WOULD BE PARTIALLY OlVERTED BACK TO THE TORUS). CLOSING THE VALVE AND REMOVING CONTROL POWER WOULD ENSURE OPERA 84UTY OF THIS LPCI LOOP.

HOWEVER, CLOSING THE F0288 VALVE WOULD CAUSE LOOP 8 OF SUPPRESSION POOL COOUNG TO BE INOPERA8M. WITH ONE INOPERABLE LDOP OF SUPPRESSION POOL COOUNG, T3 3.6.2.3 REQUIRES THAT THE LOOP BE RESTORED WITHIN 7 DAYS, l

RX MCC1- 3.5.1 7 DAYS THE A81UTY OF THESE VALVES TO CLOSE REQRCULATION 1X8-2 IS A REQUIREMENT FOR LPQ l

PUMP 18 (E8) OPERA 88UTY. IF THESE VALVES ARE DISCHARGE INOPERA8W AND OPEN, THEN PER THE BYPASS VALVE BASES OF TS 3.5.1 THE ASSOCIATto LPCI 143240318 SUBSYSTEM MUST BE DECLARED l

j.

INOPERA8LE. 7 DAY AOT FOR ONE INOPERABLE LPQ SUBSYSTEM PROVIDED h 4 l RX MCC1- 3.5.1 7 DAYS BOTH CORE SPRAY SU8 SYSTEMS ARE l REQRCULATION 1X8-2 OPERA 8LE. BOTH CORE SPRAY l I

PUMP 18 (E8) SUBSYSTEMS WOULD BE OPERA 83 AS l DISCHARGE THEY ARE SUPPUED FROM El AND E2. i l BYPASS VALVE l 1-832-F0328 h l l

BNP UNITS 1 & 2 29 ReYision 0 ;

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CISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TABLE 4 (Continued)

MOST LOAD POWER APPUCABLE RESTRfCTIVE COMMENTS TITLE SUPPLY iTS AOT h

CONTROL 120 VAC 3.7.4 30 DAYS NONE BUILDING PANEL 2 SUPPLY FAN 2 2D VA-2E-SF-C8 (120/208 VITAL BUS -

2E8)

DIV la CONTROL 120 VAC 3.3.7.1 7 DAYS AUTO INITIATION ON HIGH RADIATION BUILDING LOGlc PANEL 2 3.7.3 (DIV II) WILL BE DISABLED LOSS OF THE FOR CREV 20-120V AUTO INITIATION WILL RESULT IN A 7 DAY :

RECIRCULATION (120/208 AOT. LOSS OF ONE CONTROL ROOM FAN 28 VITAL l EMERGENCY F?LTRATION UNIT ALSO DAMPER BUS RESULTS IN A 7 DAY AOT.

CONTROL AND 2E8)

CREV SYSTEM HIGH RAD 4A-TION DIV 11 INITIATION RELAY CIRCulT DG 4 MCC 3.8.1 7 DAYS ALSO,7 DAY ACT PROPOSED FOR TWO AUXIUARIES DGD OFFSITE CIRCulTS INOPERABLE AND DG (E.G., (E8) INOPERABLE DUE TO BOP BUS 3

STARTING AIR INOPERA8luTY PER THIS DISCUSSION OF i COMPRESSORS) C', ) NGE.

i b

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BNP UNITS 1 & 2 30 Revision 0 4

ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 ,

ADDITIONAL INFORMATION REGARDING BALANCE OF PLANT / EMERGENCY BUS ALLOWABLE OUTAGE TIME EXTENSION (NRC TAC NOS. M97243 AND M97244)

UNIT 1 ITS SECTION 3.8 AND BASES l

l l

1 l

l

AC Sources-0perating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-_0perating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two Unit 1 qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System;

b. Four diesel generators (DGs); and

c. Two Unit 2 qualified circuits between the offsite transmission network and the onsite Class 1E AC I Electrical Power Distribution System. I 1

APPLICABILITY: MODES 1, 2, and 3.

I ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME l

l A. ---------NOTE--------- A.1 Restore Unit 2 45 days

Only applicable when offsite circuit to Unit 2 is in MODE 4 OPERABLE status, or 5.

One Unit 2 offsite circuit inoperable.

l (continued) l l l

l-l Brunswick Unit 1 3.8-1 Amendment No. l

l AC Sources-Operating 3.8.1 ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME B. Two Unit 2 offsite B.1 Declare required Immediately from circuits inoperable feature (s) with no discovery of due to one Unit 2 offsite power Condition B balance of plant available inoperable concurrent with circuit path to the when the redundant inoperability of downstream 4.16 kV required feature (s) redundant emergency bus are inoperable. required inoperable for planned feature (s) maintenance.

AND AND DG associated with the B.2 Perform SR 3.8.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months affected downstream for OPERABLE offsite 4.16 kV emergency bus circuit (s). AND inoperable for planned maintenance. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.3 Restore both Unit 2 7 days offsite circuits and DG to OPERABLE AND status.

10 days from

, discovery of I

failure to meet LC0 3.8.1.a or b C. One offsite circuit C.1 Perform SR 3.8.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable for reasons for OPERABLE offsite other than Condition A circuit (s). AND or B.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter l

l AND i

(continued) a Brunswick Unit 1 3.8-2 Amendment No. l l

l

1 AC Sources--Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature (s) with no discovery of no i offsite power offsite power to available inoperable one 4.16 kV when the redundant emergency bus required feature (s) concurrent with ]

are inoperable. inoperability of redundant required feature (s)

AND C.3 Restore offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 10 days from discovery of failure to meet LC0 3.8.1.a or b D. One DG inoperable for D.1 Perform SR 3.8.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reasons other than for OPERABLE offsite Condition B. circuit (s). AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND D.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature (s), supported discovery of by the inoperable DG, Condition D inoperable when the concurrent with redundant required inoperability of feature (s) are redundant inoperable. required feature (s)

AND (continued)

Brunswick Unit 1 3.8-3 Amendment No. l

l AC Sources-0perating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

DG(s) are not

! inoperable due to l

common cause failure.

1 OR D.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months i for OPERABLE DG(s). j l AND D.4 Restore DG to 7 days OPERABLE status.

AND 10 days from discovery of failure to meet l LC0 3.8.1.a or b E. Two or more offsite E.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from ,

circuits inoperable feature (s) inoperable discovery of '

i for reasons other than when the redundant Condition E

! Condition B. required feature (s) concurrent with are inoperable. inoperability of redundant required feature (s)

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

offsite circuit to l OPERABLE status.

l (continued) l l Brunswick Unit 1 3.8-4 Amendment No. I 1

l

.. , .. - =_ - . - - - - - . - . - _ . ._ . .

AC Sources--Operating ,

3.8.1 l l ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite circuit ------------NOTE-------------

inoperable for reasons Enter applicable Conditions other than and Required Actions of Condition B. LC0 3.8.7, " Distribution ;

Systems--Operating," when 1 AND Condition F is entered with no AC power source to any One DG inoperable for 4.16 kV emergency bus.

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

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

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

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

H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, AND B, C, D, E, F or G not met. H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued) l l

Brunswick Unit 1 3.8-5 Amendment No. I

_ . . . . - . ~ . . . - - .- . . - .-..-. - ~. .- .... . - . . . ..~ . . . . . . . - . - . -

AC Sources-Operating 3.8.1 ACTIONS ~(continued)

CONDITION REQUIRED ACTION COMPLETION TIME I. One or more offsite I.1 Enter LC0 3.0.3.- Immediately .

circuits and two or {

more DGs inoperable. '

DE

.Two or more offsite j circuits and one DG '

inoperable for reasons other than <

Condition B.

5URVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each offsite circuit.

(continued) l I

I Brunswick Unit 1 3.8-6 Amendment No. I

l AC Sources--Operating 3.8.1 l

l SURVEILLANCE RZQUIREMENTS (continued) l SURVEILLANCE FREQUENCY SR 3.8.1.2 -------------------NOTES-------------------

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

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

l

3. A single test at the specified r Frequency will satisfy this

! Surveillance for both units.

Verify each DG starts from standby 31 days conditions and achieves steady state voltage 2: 3750 V and s 4300 V and frequency 2: 58.8 Hz and s 61.2 Hz.

(continued) l l

l l

i Brunswick Unit 1 3.8-7 Amendment No. l l

l _ -

.a u u +..s. -u -=.a

. - -. a - -._.. . . _ _ . . . . - , a a r. . > . . - . - . _ _ -

l l AC Sources--Operating 3.8.1 l

3URVEILLANCE REQUIREMENTS (continued)

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

i

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 l

on only one DG at a time.

4. This SR shall be preceded by and l immediately follow, without shutdown, l a successful performance of SR 3.8.1.2 l 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 31 days and operates for at 60 minutes at a load 2: 2800 kW and s 3500 kW.

SR 3.8.1.4 Verify each engine mounted tank contains 31 days 2: 150 gal of fuel oil.

SR 3.8.1.5 Check for and remove accumulated water from 31 days each engine mounted tank.

! SR 3.8.1.6 Verify the fuel oil transfer system 31 days operates to transfer fuel oil from the day fuel oil storage tank to the engine mounted tank.

1 (continued) t Brunswick Unit 1 3.8-8 Amendment No. I I

1 l

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7 -------------------NOTES------------------- !

1. All DG starts may be preceded by an !

engine prelube period.

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

Verify each DG starts from standby 184 days condition and achieves, in s 10 seconds, voltage at 3750 V and frequency 2: 58.8 Hz, and after steady state conditions are reached, maintains voltage 2: 3750 V and s 4300 V and frequency 2: 58.8 Hz and s 61.2 Hz.

(continued)

J 1

I 1

i I

l Brunswick Unit 1 3.8-9 Amendment No. I

_ _ _ . __ _ _ _ _ . . _ . _ - - _ .- _ . _ _ _ _ ~ _

i I

1 AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) l l

SURVEILLANCE FREQUENCY SR 3.8.1.8 -------------------NOTES------------------- l

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 l

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: 24 months 1

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

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

1 (continued) l l

l l

l t

l Brunswick Unit 1 3.8-10 Amendment No. I 1.

I 1

. - . _ . - . . -_ _. . _ . _ _ _ _ __. _ _ _ _ . _ _ ._ .. _ .. _ . _ . . _ . _ ~ _ . _ _ _

, 1 AC Sources--Operating 3.8.1 4

i SURVEILLANCE REQUIREMENTS (continued) I 1

SURVEILLANCE FREQUENCY !

j- 1 SR 3.8.1.9 -------------------NOTES-------------------

i

1. This Surveillance shall .not be performed in M00E 1, 2, or 3 for DG 1

ar.d DG 2. However, credit may be i taken for unplanned events that

, satisfy this SR.

2. If performed with the DG synchtenized with offsite power, it shall be performed at a power factor s 0.9.

J

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

Verify each DG rejects a load greater than 24 months or equal to its associated core spray pump without tripping.

(continued) l I

1 l

Brunswick Unit 1 3.8-11 Amendment No. I

AC Sources-_0perating l 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.10 -------------------NOTE--------------------

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

Verify each DG's automatic trips are 24 months bypassed on an actual or simulated ECCS l initiation signal except:

a. Engine overspeed; l

b. Generator differential overcurrent; 4

c. Low lube oil pressure;

, d. Reverse power;

e. Loss of field; and

f. Phase overcurrent (voltage restrained).

(continued) 4 e

Brunswick Unit 1 3.8-12 Amendment No. I

. 4 a >.,, a . s >.a- -- - - . - , . - - - . - - - . . . .

AC Sources--Operating 3.8.1 j

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 -------------------NOTES-------------------

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 24 months l s; 0.9 operates for 2: 60 minutes loaded to 2: 3500 kW and s; 3850 kW.

SR 3.8.1.12 -------------------NOTE--------------------

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

Verify an actual or simulated ECCS 24 months initiation signal is capable of overriding the test mode feature to return each DG to ready-to-load operation.

(continued) l l

l l

r i

Brunswick Unit 1 3.8-13 Amendment No. I I

l

l AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l SR 3.8.1.13 -------------------NOTE--------------------

l This 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.

i l

Verify interval between each sequenced load 24 months block is within i 10% of design interval for each load sequence relay.

(continued) l

\ l l

l l

t l

4 Brunswick Unit 1 3.8-14 Amendment No. l l

AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l

SR 3.8.1.14 -------------------NOTES-------------------

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 l

and DG 2. However, credit may be taken for unplanned events that satisfy this SR.

Verify, on actual or simulated loss of 24 months l offsite power signal in conjunction with an

' actual or simulated ECCS initiation signal:

l a. De-energization of emergency buses;

b. Load shedding from emergency buses; and i

c. DG auto-starts from standby condition i

and:

I

1. energizes permanently connected loads in s 10.5 seconds, .

I

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

3. maintains steady state voltage ,

2 3750 V and s 4300 V, j i

l 4. maintains steady state frequency l 2 58.8 Hz and s 61.2 Hz, and l

5. supplies permanently connected and

! auto-connected emergency loads for

! 2 5 minutes. !

)

I l

i Brunswick Unit 1 3.8-15 Amendment No. I 1

1

AC Sources--Shutdown 3.8.2 I 3.8 ELECTRICAL POWER SYSTEMS I l

3.8.2 AC Sources--Shutdown -

4 LC0 3.8.2 The following AC electrical power sources shall be OPERABLE:

.a. One Unit 1 qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem (s) required by '

LCO 3.8.8, " Distribution Systems--Shutdown";

b. Two diesel generators (DGs) capable.of supplying onsite Class IE AC electrical power distribution subsystem (s) )

required by LC0 3.8.8; and !

c. One Unit 2 qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem (s) needed to l support the Unit 2 equipment required to be OPERABLE by LC0 3.7.3, " Control Room Emergency Ventilation (CREV)

System," LC0 3.7.4, " Control Room Air Conditioning (AC)

System," and LC0 3.8.5, "DC Sources--Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

1 i

i I

l l

l I Brunswick Unit 1 3.8-16 Amendment No. l l

1 -

l l

AC Sources-Shutdown 3.8.2 ACTIONS l

' -------------------------------------NOTE-------------------------------------

LC0 3.0.3 is not applicable.

l l

CONDITION REQUIRED ACTION COMPLETION TIME l

l t

A. One or more required ------------NOTE-------------

l offsite circuits Enter applicable Condition inoperable. and Required Actions of LC0 3.8.8, with one or more l l required 4.16 kV emergency I buses de-energized as a result of Condition A. I 1

l A.1 Declare affected Immediately l required feature (s),

i with no offsite power available, l inoperable.

OR I

A.2.1 Suspend CORE Immediately ALTERATIONS.

i AND A.2.2 Suspend movement of Immediately

[

irradiated fuel assemblies in the secondary containment.

AND A.2.3 Initiate action to Immediately suspend operations with a potential for l draining the reactor vessel (0PDRVs).

AND l

(continued)

J Brunswick Unit 1 3.8-17 Amendment No. I 1

I i

[

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

A. (continued) A.2.4 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

B. One required DG B.1 Declare affected Immediately inoperable, required feature (s)

! with no DG available inoperable.

0_8 B.2.1 Suspend CORE Immediately ALTERATIONS.

AND B.2.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.2.3 Initiate action to Immediately suspend OPDRVs.

AND B.2.4 Initiate action to Immediately restore required DG to OPERABLE status.

(continued) l l Brunswick Unit 1 3.8-18 Amendment No. I

l l AC Sources--Shutdown l 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two required DGs C.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND l

C.2 Suspend movement of Immediately irradiated fuel assemblies in i secondary containment.

AND C.3 Initiate' action to Immediately i suspend OPDRVs.

AND C.4 Initiate action to Immediately restore required DGs to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -------------------NOTE--------------------

Unless required to be performed by Unit 2 Specification 3.8.1, the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.14.

For AC sources required to be OPERABLE the In accordance SRs of Specification 3.8.1, except with applicable SR 3.8.1.8 and SR 3.8.1.12, are applicable. SRs l

Brunswick Unit 1 3.8-19 Amendment No. l .

l l _.

-- - .. =. . - . _.

Diesel Fuel Oil l 3.8.3 l 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil LC0 '3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE. j ACTIONS

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

Separate Condition entry is allowed for each DG.

__________________..__. _______...__..._________ ._____________ .._______ ..__ {

l CONDITION REQUIRED ACTION COMPLETION TIME 1

l A. One or more required A.1 Restore required day 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months DGs with fuel oil fuel oil storage tank level in the level to within associated day fuel limit.

oil storage tank (s)

< 22,650 gal per required DG and 2: 17,000 gal per required DG, AND Fuel oil level in the l main fuel oil storage tank 2: 20,850 gal per required DG.

(continued)

Brunswick Unit 1 2.8-20 Amendment No. l

l l l

Diesel Fuel Oil 3.8.3

( ACTIONS (continued) J f CONDITION REQUIRED ACTION COMPLETION TIME l-1

! B. One or more required B.1 Restore main fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months DGs with fuel oil storage tank level to level in the main fuel within limit. {

oil storage tank !

< 20,850 gal per !

l required DG and l 2: 13,900 gal per required DG.

i AND

! Fuel oil level in the required day fuel oil storage tank (s) 2: 22,650 gal per required DG.

l 1

C. One or more DGs with C.1 Restore stored fuel 7 days j stored fuel oil total oil total particulates not particulates to

within limit. within limit.

D. Required Action and D.1 Declare associated DG Immediately associated Completion inoperable.

Time Condition A, B, or C not met.

OB One or more DGs with diesel fuel oil not within limits for reasons other than l Condition A, B, or C.

l

[

Brunswick Unit 1 3.8-21 Amendment No. I i

l

Diesel Fuel Oil 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 For each required DG, verify: 31 days

a. The associated day fuel oil storage tank contains a: 22,650 gal; and

b. The main fuel oil storage tank

contains 2: 20,850 gal per required DG.

SR 3.8.3.2 Verify fuel oil properties of stored fuel In accordance oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Oil Fuel Oil Testing Program. Testing Program SR 3.8.3.3 Check for and remove accumulated water from 31 days each day fuel oil tank and the main fuel oil storage tank.

Brunswick Unit 1 3.8-22 Amendment No. I

DC Sources--Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources--Operating LCO 3.8.4 The following DC electrical power subsystems shall be OPERABLE:

a. Unit 1 Division I and Division II DC electrical power subsystems; and

b. Unit 2 Division I and Division II DC electrical power subsystems.

APPLICABILITY: H0 DES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION fCOMPLETIONTIME A. One DC electrical A.1 --------NOTE---------

power subsystem Enter applicable inoperable. - Conditions and Required Actions of LC0 3.8.7,

" Distribution Sys tems --Operating , "

when Condition A results in de-energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem.

Restore DC electrical 7 days power subsystem to OPERABLE status.

(continued)

Brunswick Unit 1 3.8-23 Amendment No. I L

l 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 AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 0_B Two or more DC electrical power subsystems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is 2130 V 7 days on float charge.

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

08 Verify battery connection resistance is s 23.0 ohms for inter-cell connections and s 82.8 pohms for inter-rack connections.

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

(continued)

Brunswick Unit 1 3.8-24 Amendment No. I

DC Sources--Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery 18 months cell to cell and terminal connections are coated with anti-corrosion material. j SR 3.8.4.5 '/erify each required battery charger 24 months supplies 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 . I SR 3.8.4.6 -------------------NOTES-------------------

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 24 months supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

i (continued) 1 I

j Brunswick Unit 1 3.8-25 Amendment No. l l

t DC Sources--Operating '

3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l

SR 3.8.4.7 -------------------NOTES-------------------

1. This Surveillance shall not be .

performed in MODE 1 or 2 for the i Unit 1 DC electrical power subsystems.

However, credit may be taken for l

unplanned events that satisfy this SR.

2. A single test at the spccified '

Frequency will satisfy this Surveillance for both units.

l l

Verify battery capacity is 2: 80% of the 60 months ;

manufacturer's Ling when subjected to a i performance distnarge test or a modified AND performance discharge test.

12 months when battery shows degradation or has reached 85%

of the expected life with capacity

< 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity 2: 100% of manufacturer's rating I

i i

l Brunswick Unit 1 3.8-26 Amendment No. l

DC Sources-Shutdown l 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown ;

l LC0 3.8.5 The following DC electrical power subsystems shall be OPERABLE:

l

a. The Unit 1 DC electrical power subsystems needed to support the DC electrical power distribution subsystem (s) required by LCO 3.8.8, " Distribution i Systems-Shutdown;" and

b. The Unit 2 DC electrical power subsystem needed to support the DC electrical power distribution subsystem (s) required by LC0 3.8.8, " Distribution Systems-Shutdown."

I APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS

_____...........-NOTE-------------------------------------

LC0 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately DC electrical power required feature (s) I subsystems inoperable. inoperable. l OE A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

Brunswick Unit 1 3.8-27 Amendment No. I

\

l DC Sources--Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I A. (continued) A.2.2 Suspend movement of Immediately 1 irradiated fuel !

l assemblies in the secondary l l containment. I i

AND l A.2.3 Initiate action to Immediately I suspend operations with a potential for draining the reactor vessel. l l

AND A.2.4 Initiate action to Immediately restore required DC electrical power j subsystems to l OPERABLE status. 1 I

r

[

! Brunswick Unit 1 3.8-28 Amendment No. I

DC Sources--Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

)

SR 3.8.5.1 -------------------NOTE--------------------

Unless required to be performed by Unit 2 ,

Specification 3.8.4, the following SRs are l not required to be performed: SR_3.8.4.6 l and SR 3.8.4.7.

l For DC electrical power subsystems required In accordance l to be OPERABLE the following SRs are with applicable i applicable: SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, SR 3.8.4.4, SR 3.8.4.5, SR 3.8.4.6, and SR 3.8.4.7.

i Brunswick Unit 1 3.8-29 Amendment No. I

I Battery Cell Parameters )

3.8.6 )

i l

3.8 ELECTRICAL POWER SYSTEMS i 3.8.6 Battery Cell Parameters LC0 3.8.6 Battery cell parameters for the Unit 1 Division I and II batteries and the Unit 2 Division I and II batteries shall be within the limits of Table 3.8.6-1.

AND Battery cell average electrolyte temperature for the Unit 1 Division 1 and II batteries and the Unit 2 Division I and II batteries shall be within required limits.

1 APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS

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

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more batteries A.1 Verify pilot cells I hour i with one or more electrolyte level and battery cell float voltage meet parameters not within Table 3.8.6-1 Category A or B Category C limits, limits.

AND A.2 Verify battery cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months parameters meet Table 3.8.6-1 AND Category C limits.

Once per 7 days thereafter AND (continued)

Brunswick Unit 1 3.8-30 Amendment No. I 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 Immediately associated Completion battery inoperable.

Time of Condition A not met.

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

M 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 7 days Table 3.8.6-1 Category A limits.

I (continued)

Brunswick Unit 1 3.8-31 Amendment No. l l

l

Battery Cell Parameters 3.8.6 l

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet 92 days Table 3.8.6-1 Category B limits.

SR 3.8.6.3 Verify average electrolyte temperature of 92 days representative cells is a 60*F.

l l

l l Brunswick Unit 1 3.8-32 Amendment No. I i

Battery Cell Parameters l 3.8.6 l

l Table 3.8.6-1 (page 1 of 1) l Battery Cell Parameter Requirements l CATEGORY A: CATEGORY B: CATEGORY C:

l LIMITS FOR EACH LIMITS FOR EACH LIMITS FOR DESIGNATED PILOT CONNECTED CELL EACH CONNECTED '

PARAMETER CELL CELL Electrolyte > Minimum level > Minimum level Above top of Level indication mark, and indication mark, plates, and not

! s i inch above and s 1 inch above overflowing :

maximum level maximum level !

indication mark (a) indication mark (a) )

1 l l Float Voltage 2 2.13 V 2 2.13 V 2 2.07 V Specifi 2 1.200 2 1.195 Not more than l Gravity (b)(c) 0.020 below l AND average of all l connected cells

! Average of all connected cells AND 2 1.205 Average of all connected cells 2 1.195 I~ (a) It is acceptable for the electrolyte level to temporarily increase above l the specified maximum level during and following equalizing charges provided it is not overflowing.

(b) Corrected for electrolyte temperature and level. However, level correction is not required when on float charge and battery charging current is < 2 amps.

(c) A battery charging current of < 2 amps when on float charge is acceptable for meeting specific gravity limits following a battery l recharge, for a maximum of 7 days. When charging current is used to

! satisfy specific gravity requirements, specific gravity of each

, connected cell shall be measured prior to expiration of the 7 day

[ allowance.

Brunswick Unit 1 3.8-33 Amendment No. I l

Distribution Systems-0perating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS l

l 3.8.7 Distribution Systems--Operating 1

LC0 3.8.7 Division I and Division II AC and DC electrical power distribution subsystems shall be OPERABLE.

l l APPLICABILITY: MODES 1, 2, and 3.

l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

l A. One AC electrical A.1 Restore affected load 7 days power distribution group bus (es) to subsystem inoperable OPERABLE status. ANQ for planned maintenance due to 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from l either inoperable load discovery of group E3 bus (es) or failure to meet inoperable load group the LC0 E4 bus (es).

B. One or more AC B.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystems to AND subsystems inoperable OPERABLE status, for reasons other than 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months frcm Condition A. discovery of l

failure to meet LC0 l

(continued) i Brunswick Unit 1 3.8-34 Amendment No. I L

1 I

Distribution Systems-0perating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC C.1 Declare required Immediately l )

electrical power feature (s), supported i distribution by the inoperable DC subsystems inoperable electrical power due to loss of normal distribution l DC source. subsystem, inoperable.

l AND j

l L C.2 Initiate action to Irriediately I i

transfer DC electrical power distribution subsystem to its l alternate DC source.

l l AND C.3 Declare required Upon completion I feature (s) supported of transfer of

by the inoperable DC the required l electrical power feature's DC l distribution electrical power

! subsystem OPERABLE. distribution subsystem to its l OPERABLE alternate DC l source AND C.4 Restore DC electrical 7 days l power distribution subsystem to OPERABLE AND L status.

, 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet the LC0 (continued) i Brunswick Unit 1 3.8-35 Amendment No. l g w y m.- - , - ,-

m - m %

I

(

Distribution Systems-0perating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC D.1 Restore DC electrical 7 days l l

electrical power power distribution

! distribution subsystems to AND l subsystems inoperable OPERABLE status.

l- for reasons other than 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from I Condition C. discovery of failure to meet LC0 l

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I ;

associated Completion i Time of Condition A, AND B, C, or D not met.

l E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two or more electrical F.1 Enter LC0 3.0.3. Immediately I power distribution subsystems inoperable that result in a loss

! of function.

l l

l h

Brunswick Unit 1 3.8-36 Amendment No. I

l 1

l Distribution Systems--Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l

SR 3.8.7.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems.

l l

SR 3.8.7.2 Verify no combination of more than two 7 days power conversion modules (consisting of either two lighting inverters or one 1

l lighting inverter and one plant uninterruptible power supply unit) are i aligned to Division II bus B. l l

l 1

l l

l Brunswick Unit 1 3.8-37 Amendment No. I

Distribution Systems-Shutdown l

3.8.8

.3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Distribution Systems-Shutdown 1

{ LC0 3.8.8 The necessary portions of the AC and DC electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

i i

APPLICABILITY: MODES 4 and 5, l

During movement of irradiated fuel assemblies in the j

' secondary containment. 1 l

I ACTIONS '

................................-----NOTE----------------------------.-------. l LC0 3.0.3 is not applicable. '

l ...............................................................................

CONDITION REQUIRED ACTION COMPLETION TIME i i

A. One or more required A.1 Declare associated Immediately AC or DC electrical supported required power distribution feature (s) i subsystems inoperable. inoperable.

i OR

~

1

! A.2.1 Suspend CORE Immediately ALTERATIONS.

AND

' A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND (continued) l t

Brunswick Unit 1 3.8-38 Amendment No. I i

l Distribution Systems-Shutdown 3.8.8 l

t ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

A. (continued) A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor j vessel.

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

END l A.2.5 Declare associated Immediately I

required shutdown 4 cooling subsystem (s) I inoperable and not in operation.

l

! SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l

SR 3.8.8.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems.

i Brunswick Unit 1 3.8-39 Amendment No. I I

AC Sources-Operating B 3.8.1 BASES ACTIONS B.1

! (continued)

Required Action B.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with two offsite circuits inoperable due to one l Unit 2 B0P circuit path to the downstream 4.16 kV emergency bus being inoperable and the DG associated with the downstream 4.16 kV emergency bus inoperable. Condition B is

, intended to be used for planned maintenance on the Unit 2 i B0P buses and the associated 4.16 kV emergency bus (in order l to perform maintenance on the 4.16 kV emergency bus, the

! associated DG must be rendered inoperable). Redundant l

required features failures consist of inoperable features that are associated with an emergency bus redundant to the emergency bus with inoperable offsite circuits and DG.

l Required Action B.1 reduces the vulnerability to a loss of function.

l l The immediate Completion Time for Required Action B.1 is l intended to ensure that all redundant required features are

~

OPERABLE, or required features ACTIONS entered, prior to entering Condition B. This Completion Time also allows for I an exception to the normal " time zero" for beginning the ,

allowed outage time " clock". In this Required Action, the Completion Time only begins on discovery that both:

a. Twa Unit 2 offsite circuits are inoperable due to one I inoperable Unit 2 B0P circuit path to the downstream 4.16 kV emergency bus and the DG associated with the downstream 4.16 kV emergency bus is inoperable; and

b. A redundant required feature is inoperable.

I If, at any time during the existence of this Condition, a ,

redundant required feature subsequently becomes inoperable, I this Completion Time begins to be tracked.

B.2 l The Unit 2 B0P buses 2C and 2D can each be supplied from the l

two Unit 2 offsite circuits (SAT and UAT). In turn, offsite power is supplied from each B0P bus to its downstream l 4.16 kV emergency bus via a single circuit. Hence, an intentional outage of a B0P bus or the circuit path to its associated emergency bus (master / slave breakers and i

(continued) l l Brunswick Unit 1 B 3.8-6 Revision No. I

AC Sources-0perating i

B 3.8.1 BASES ACTIONS H.,1 (continued) interconnecting cables) results in the loss of availability l

of both offsite circuits to the downstream emergency bus.

The phrase " balance of plant circuit path to the downstream l 4.16 kV emergency bus" as stated in Condition B refers to the B0P bus and its associated circuit path (master / slave l breakers and interconnecting cables) to the downstream l 4.16 kV emergency bus.

l

! To ensure highly reliable power sources remain with one Unit 2 balance of plant circuit path to the downstream 4.16 kV emergency bus inoperable and the DG associated with l

the downstream 4.16 kV emergency bus inoperable, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure of SR 3.8.1.1 acceptance criteria does not result in the

! Required Action not met. However, if a second circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition E, for two or more offsite circuits inoperable, is entered.

B.3 This Required Action provides a 7 day time period to perform planned maintenance on one of these B0P buses and the circuit path to its associated 4.16 kV emergency bus when Unit 2 is in MODE 4 or 5. During the planned maintenance of the B0P bus, the associated emergency bus and the associated DG, if a condition is discovered on these buses or the DG requiring corrective maintenance, this maintenance may be performed within the 7 day time period of Required Action B.3. (If Unit 2 is in MODE 1, 2, or 3, then the Unit 2 ACTIONS of Specification 3.8.1, "AC Sources-Operating," require entry into LC0 3.0.3 for this condition.) The 7 day Completion Time takes into account i

the capacity and capability of the remaining AC sources and a reasonable time frame for performance of planned

[ maintenance. This is acceptable because maintenance on each B0P bus and the circuit path to its associated emergency bus will increase the reliability of the offsite circuits to the downstream 4.16 kV emergency buses. It should be noted that while in this condition each of the remaining three 4.16 kV (continued) l I

Brunswick Unit 1 B 3.8-7 Revision No. l l

-. - .. - - . --- .- _ - - - . . - ~ . - - - . . -

l AC Sources-0perating B 3.8.1 i

BASES l

ACTIONS M -(continued)

I emergency buses will-have their standby emergency source and two sources of offsite power OPERABLE. If one or both sources of offsite power are lost to an additional 4.16 kV emergency bus then Condition E is entered.

The second Completion Time for Required Action B.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet LC0 3.8.1.a or b. If Condition B is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LC0 may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation could lead to a total of 10' days from initial failure of the LC0 to restoration of the B0P circuit path to the downstream 4.16 kV emergency bus and DG associated with the affected 4.16 kV emergency bus. At this time, a second offsite circuit could again become inoperable, the BOP circuit path to the downstream 4.16 kV emergency bus and DG associated with the affected 4.16 kV emergency bus restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 13 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LCO 3.8.1.a or b. This limit is considered reasonable for situations in which condition B and Condition C or D are entered concurrently. The "AND" connector between the 7 day and 10 day Completion Time means that both Completion Times apply simultaneously, and the more restrictive must be met.

As in Required Action B.1, the second Completion Time allows for an exception to the normal " time zero" for beginning the allowed outage time " clock". This exception results in establishing the " time zero" at the time that LC0 3.8.1.a or b was initially not met, instead of the time that Condition B was entered.

C.1 To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies j (continued) i Brunswick Unit 1 B 3.8-8 Revision No. l l

l

AC Sources-Operating B 3.8.1 BASES ACTIONS C.1 (continued) 1

" perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition E, for two or more offsite l l circuits inoperable, is entered.

1 C.2

-Required Action C.2, which only applies if one 4.16 kV emergency bus cannot be powered from an offsite source, is intended to provide assurance that an event with a t coincident single failure of the associated DG does not j L result in a complete loss of safety function of critical !

l systems. These features (e.g., system, subsystem, division, !

i component, or device) are designed with redundant safety I related 4.16 kV emergency buses. Redundant required feature i failures consist of inoperable features associated with an emergency bus redundant to the emergency bus that has no ,

offsite power. l The Completion Time for Required Action C.2 is intended to l ,

allow time for the operator to evaluate and repair any l discovered inoperabilities. This Completion Time also allows an exception to the normal " time zero" for beginning

! the allowed outage time " clock." In this Required Action I l the Completion Time only begins on discovery that both:

a. A 4.16 kV emergency bus has no offsite power supplying its loads; and

,- b. A redundant required feature on another emergency bus L is inoperable.

! If, at any time during the existence of this Condition (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering no offsite power to one 4.16 kV emergency bus of the onsite Class IE Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with any other i

(continuqdl '

p i

Brunswick Unit 1 B 3.8-9 Revision No. l

AC Sources-0perating B 3.8.1 BASES I

ACTIONS M (continued) l emergency bus that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

l M i According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition C for a period that should not exceed I 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the l

potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuits and DGs are adequate to supply electrical

power to the onsite Class IE Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

l The second Completion Time for Required Action C.3 l l establishes a limit on the maximum time allowed for any l combination of required AC power sources to be inoperable

during any single contiguous occurrence of failing to meet LC0 3.8.1.a or b. If Condition C is entered while, for I instance, a DG is inoperable, and that DG is subsequently returned OPERABLE, the LC0 may already have been not met for

(continued)

Brunswick Unit 1 8 3.8-10 Revision No. l

. _ _ . _ , _ . . _ _ __ ._ ~ _ _ _ _ _ . . - _ . . . _ _ _ _ _ _ _ _ _ . . _ . _

AC Sources-0perating B 3.8.1 BASES ACTIONS C.3 (continued) l up to 7 days. This situation could lead to a total of 10 days, since initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 7 days (for a total of 17 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LC0 3.8.1.a or b. This limit is considered reasonable for situations in which Conditions C and D are entered concurrently. The "AND" l connector between the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

As in Required Action C.2, the Completion Time allows for an l

, exception to the normal " time zero" for beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the time LCO 3.8.1.a or b was initially not met, instead of at the time that Condition C was entered. I D.1 1 To ensure a highly reliable power source remains with one DG inoperable, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure to meet l SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered.

Dt2 Required Action D.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed to be powered from redundant safety related 4.16 kV emergency buses (i.e., single division systems are not included). Redundant required feature failures consist of inoperable features associated with an emergency bus

redundant to the emergency bus that has an inoperable DG.

{ (continued)

Brunswick Unit 1 B 3.8-11 Revision No. l l

1. AC Sources-0perating l B 3.8.1 BASES i ACTIONS D_Jt (continued) l l

l The Cocpletion Time is intended to allow the operator time l to evaluate and repair any discovered inoperabilities. This i

Completion Time also allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

In this Required Action the Completion Time only begins on discovery that both:

a. An inoperable DG exists; and

b. A redundant required feature on another emergency bus

! is inoperable.

If, at any time during the existence of this Condition (one

! DG inoperable), a required redundant feature subsequently becomes inoperable, this Completion Time begins to be l tracked.

l Discovering one DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DGs results in l starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

(continued) i l

Brunswick Unit 1 B 3.8-12 Revision No. l

AC Sources-0perating B 3.8.1 BASES ACTIONS D.3.1 and 0.3.2 (continued)

Required Action D.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DGs,~SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), they are declared inoperable upon discovery, and Condition G or I of LC0 3.8.1 is entered, as applicable. I Once the failure is repaired, and the common cause failure no longer exists, Required Action D.3.1 is satisfied. If I the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those DGs.

In the event the inoperable DG is restored to OPERABLE status prior to completing either D.3.1 or D.3.2 (i.e., the I inoperable DG has been restored to OPERABLE status but it has not yet been determined if the cause'of the inoperability is common to the other OPERABLE DGs), the CP&L Corrective Action Program (CAP) will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer required under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition D. I According to Generic Letter 84-15 (Ref. 10), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time to confirm that the OPERABLE DGs are not affected by the same problem as the inoperable DG.

D.4 l The 4.16 kV emergency bus design is sufficient to allow operation to continue in Condition D for a period that should not exceed 7 days. In Condition D, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

(continued)

Brunswick Unit 1 B 3.8-13 Revision No. I

l AC Sources-0perating I B 3.8.1 BASES 1 l

l ACTIONS M (continued)

The second Completion Time for Required Action D.4 l establishes a limit on the maximum time allowed for any l combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet '

LC0 3.8.1.a or b. If Condition D is entered while, for I instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LC0 may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation could lead to a total of 10 days, since initial failure of the LCO, to restore the DG. At this time, an offsite circuit could ,

again become inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 13 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LCO 3.8.1.a or b. This limit is considered reasonable for situations in which Conditions C and D are entered concurrently. The I

, "AND" connector between the 7 day and 10 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met.

As in Required Action D.2, the Completion Time allows for an I exception to the normal " time zero" for beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the time that LC0 3.8.1.a or b was initially not met, instead of the time tnat Condition D was entered. I E.1 and E.2 Required Action E.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with inoperability of two or more offsite circuits. Required Action E.1 reduces the vulnerability to I a loss of function. The Completion Time for taking these actions is reduc ~ed to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed with one 4.16 kV emergency bus without offsite power (Required Action C.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is I that Regulatory Guide 1.93 (Ref. 9) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE. While this Action allows more than two circuits (continued)

{

Brunswick Unit 1 B 3.8-14 Revision No. I i

-yr

AC Sources-Operating B 3.8.1 BASES l 1

ACTIONS E.1 and E.2 (continued) I to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes I only two circuits are required by the LCO, and a loss of l those two circuits results in a total loss of offsite power to the Class IE Electrical Power Distribution System. Thus, with the BNP electrical design, a loss of the four offsite circuits results in the same condition assumed in Regulatory '

Guide 1.93 (Ref. 9). When a concurrent redundant required l feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is_ appropriate. These features are designed with redundant safety related 4.16 kV emergency buses, (i.e., single division systems are not included in the list). Redundant required feature failures consist of any of these features that are inoperable because any inoperability is on an emergency bus redundant to an emergency bus with inoperable offsite circuits.

The Com)letion Time for Required Action E.1 is intended to I allow tie operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for

! beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both:

a. Two or more offsite circuits are inoperable; and

b. A redundant required feature is inoperable.

If, at any time during the existence of this condition (any combination of two or more Unit 1 and 2 offsite circuits inoperable), a redundant required feature subsequently L becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition E for a period that should not exceed l 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system may not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

(continued) 1 4

s Brunswick Unit 1 B 3.8-15 Revision No. l l

N_. - - - - --

AC Sources--Operating B 3.8.1 l

BASES ACTIONS E.1 and E.2 (continued) l Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable. However, two factors tend to decrease the severity of this degradation level:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure; and

b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With two or more of the offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of all but one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting '

its design criteria.

According to Regulatory Guide 1.93 (Ref. 9), with the available offsite AC sources two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If all offsite sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted operation may continue. If all but one offsite source is restored l within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance with Condition A or C, as applicable. I F.1 and F.2 I Pursuant to LC0 3.0.6, the Distribution System--Operating ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition F are modified by a Note I i

(continued) l i

i I

Brunswick Unit 1 B 3.8-16 Revision No. I i

1

AC Sources-0perating B 3.8.1 BASES ACTIONS F.1 and F.2 (continued) to indicate that when Condition F is entered with no AC source to any 4.16 kV emergency bus, ACTIONS for LC0 3.8.7,

" Distribution Systems-Operating," must be immediately entered. This allows Condition F to provide requirements I for the loss of an offsite circuit and one DG without regard to whether an emergency bus is de-energized. LC0 3.8.7 provides the appropriate restrictions for a de-energized emergency bus.

According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition F for a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In Condition F, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition E (loss of two or more I offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

S.d l With two or more DGs inoperable and an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdo n and to minimize the risk associated with this level of degradation.

(continued)

Brunswick Unit 1 B 3.8-17 Revision No. I

AC Sources-Operating B 3.8.1 BASES ACTIONS G.1 (continued) l According to Regulatory Guide 1.93 (Ref. 9), with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . While this Action allows more than two DGs to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two DGs are required by the LC0, and a loss of those two DGs results in a total loss of onsite power to the Class IE Electrical Power Distribution System.

Thus, with the BNP electrical design, a loss of the four DGs results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9).

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

I.1 Condition I corresponds tc a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system may cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is requi ./ by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features, especially those that have a standby function, in accordance with UFSAR Sections 8.2 and 8.3 (Ref. 2). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for (continued)

Brunswick Unit 1 B 3.8-18 Revision No. l

l AC Sources-0perating B 3.8.1 BASES SURVEILLANCE demonstrating the OPERABILITY of the DGs are consistent with l REQUIREMENTS the recommendations of Safety Guide 9 (Ref. 5), Regulatory i (continued) Guide 1.9 (Ref.11), and Regulatory Guide 1.137 (Ref.12),

as addressed in the UFSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable. The minimum steady state output voltage of 3750 V is derived from the recommendations found in Safety Guide 9 (Ref. 5) and bounds the minimum steady state output voltage criteria of 3621 V associated with the 4.16 kV emergency buses analyzed in the AC Auxiliary Electrical Distribution System Study. This value (3621 V) allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 3600 V. It also allows for voltage drops to l motors and other equipment down through the 480 V level l where minimum operating voltage is also usually specified as 90% of name plate rating. The specified maximum steady l state output voltage of 4300 V ensures the maximum operating i voltage at the safety related 480 V substations is no more i than the maximum rated steady state voltage criteria for the l 480 V motor control centers. The maximum steady state output voltage was determined taking into consideration the l voltage drop between the DGs and the 4.16 kV emergency buses and a 5% voltage boost at the 480 V substation transformers.

l This maximum steady state output voltage also ensures that l for a lightly loaded distribution system, the voltage at the l l

terminals of 4000 V motors is no more than the maximum rated i steady state operating voltage. The specified minimum and l maximum frequeacies of the DG are 58.8 Hz and 61.2 Hz, l

respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Safety Guide 9 (Ref. 5). i l

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC

electrical power supply to the onsite distribution network l and availability of offsite AC electrical power. The

! breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that

, appropriate independence of offsite circuits is maintained.

! The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it

} and because its status is displayed in the control room.

(continued) s i

j Brunswick Unit 1 B 3.8-19 Revision No. I 4

}

AC Sources-0perating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 REQUIREMENTS (continued) These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.

-To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note (Note 1 for SR 3.8.1.2 and SR 3.8.1.7) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period.

For the purposes of this testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained.

In order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2 of SR 3.8.1'.2.

SR 3.8.1.7 requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The minimum voltage and frequency stated in the SR are those necessary to ensure the DG can accept DBA loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not dampaned by load application. This period may be extended beyond the 10 second acceptance criteria and could be cause for failing the SR. In lieu of a time constraint in the SR, BNP will monitor and trend the actual time to

, reach steady state operation as a means of ensuring there is l no voltage regulator or governor degradation which could cause a DG to become inoperable. The 10 second start l requirement supports and is conservative with respect to the assumptions in the design basis LOCA analysis of UFSAR, Section 6.3 (Ref. 6). The 10 second start requirement is (continued)

Brunswick Unit 1 B 3.8-20 Revision No. l

AC Sources-0perating B 3.8.1 BASES SURVEILLANCE. SR 3.8.1.2 and SR 3.8.1.7 (continued)

REQUIREMENTS not applicable to SR 3.8.1.2 (see Note 2 of SR 3.8.1.2),

when'a modified start procedure as described above is used.

If a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies.

To minimize testing of the DGs, Note 3 to SR 3.8.1.2 and Note 2 to SR 3.8.1.7 allow a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one l- unit.

I The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref.11). The.184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 10). These Frequencies provide adequate assurance.of DG OPERABILITY, while minimizing degradation resulting from testing.

~

SR 3.8.1.3 l This Surveillance verifies that the DGs are capable of I

synchronizing and accepting a load approximately equivalent to the continuous rating of the DGs. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the l offsite source.

Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design

, rating of the machine, while 1.0 is the generator design limitation which if exceeded could lead to generator instability while in parallel with the offsite circuit. The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY.

l The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 11).

(continued)

Brunswick Unit 1 B 3.8-21 Revision No. l

I l-AC Sources-0perating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.3 (continued)

REQUIREMENTS Note 1 modifies this Surveillance to indicate that diesel

' engine runs for this Surveillance may include gradual loading so that mechanical stress and wear on the diesel engine are minimized.

Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients outside the range normally used during the performance of this Surveillance do not invalidate the test.

Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbttions.

Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

To minimize testing of the DGs, Note 5 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.4 This SR provides verification that the level of fuel oil in the engine mounted tank is slightly below the level at which the backup fuel oil transfer pump automatically starts. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil fo'r approximately 30 minutes of DG operation at rated load. This SR may be satisfied by verifying the absence of the associated low level alarm.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are l provided and facility operators would be aware of any large

! uses of fuel oil during this period.

l l (continued) i l

Brunswick Unit 1 B 3.8-22 Revis'on No. I

l I

AC Sources--Operating B 3.8.1 i

BASES SURVEILLANCE SR 3.8.1.5 REQUIREMENTS (continued) Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the engine mounted tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling.

In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, l rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data

regarding the watertight integrity of the fuel oil system.

The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 12). This SR is for preventive

, maintenance. The presence of water does not necessarily j represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.

Removal of accumulated water may be accomplished by draining i a portion of fuel oil from the engine mounted fuel oil tank l

to the day fuel oil storage tank and draining any accumulated water from the day fuel oil storage tank in accordance with SR 3.8.3.3. The draining evolution will continue until accumulated water is verified to be removed from the engine mounted fuel oil tank.

SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for fuel transfer systems are OPERABLE.

(continued) i i

?

1 i

Brunswick Unit 1 B 3.8-23 Revision No. l f

- . . - . . _ . - . , w , 4

l l

AC Sources-0perating B 3.8.1 l

BASES l

i l

i SURVEILLANCE SR 3.8.1.6 (continued)

REQUIREMENTS The Frequency for this SR is consistent with the Frequency for testing the DGs in SR 3.8.1.3. DG operation for i SR 3.8.1.3 is normally long enough that fuel oil level in the engine mounted tank will be reduced to the point where the fuel oil transfer pump automatically starts to restore fuel oil level in the engine mounted tank. I SR 3.8.1.8 Transfer of each 4.16 kV emergency bus power supply from the normal circuit to the preferred offsite circuit and from the preferred offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the offsite circuit distribution network to power the shutdown loads. In lieu of actually initiating an automatic circuit transfer, testing that adequately shows the capability of the transfer is acceptable. The automatic transfer testing may include any series of sequential, overlapping, or total steps so that the entire transfer sequence is verified. The 24 month Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed on the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by three Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of SR 3.8.1.8.a. verification of automatic transfer capability of the unit power supply from the normal circuit to the preferred offsite circuit, could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. Note 1 is not applicable to SR 3.8.1.8.b, verification of manual transfer of the unit power supply from the preferred offsite circuit to the alternate offsite circuit, since this evolution does not cause perturbations of the electrical distribution systems.

. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, j both units' offsite circuits are required to be OPERABLE to l

l (continued)

Brunswick Unit 1 B 3.8-24 Revision No. I

AC Sources-Operating i

l B 3.8.1 l i l BASES l i

SURVEILLANCE SR 3. 8.1J (continued) l- supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the consequences '

of a potential perturbation to the electrical distribution i

' systems during the performance of this Surveillance, while at the same time avoiding the need for a shutdown of both units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for the Unit 1 offsite circuits when Unit 1 is in MODE 1 or 2. During the performance of this Surveillance with Unit I not in MODE 1 l or 2 and with Unit 2 in MODE 1, 2, or 3; the applicable t

ACTIONS of the Unit 1 and Unit 2 Technical Specifications must be entered if a Unit 1 offsite circuit is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. As stated in Note 2, automatic transfer capability to the SAT is not required to be met when the associated 4.16 kV emergency buses are powered from the preferred offsite circuit. This is acceptable since the automatic transfer capability function has been satisfied in this condition.

To minimize testing, Note 3 allows a single test (instead of

, two tests, one for each unit)'to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on a single unit. If an offsite circuit fails one of the Surveillances, the offsite circuit should be considered inoperable for both units. '

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG capability to reject the largest single load without tripping. The largest single load for each DG is a core spray pump (1250 hp). This Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated core spray i pump while paralleled to offsite power, or while j solely supplying the bus; or (continued) l Brunswick Unit 1 B 3.8-25 Revision No. I

AC Sources-0perating B 3.8.1 l l

i

! BASES SURVEILLANCE SR 3.8.1.9 (continued) l l REQUIREMENTS l b. Tripping its associated core spray pump with the DG l t

solely supplying the bus. 1 The load reje tion test is acceptable if the increase in diesel speed does not exceed the overspeed trip setpoint.

The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref.11).

This SR is modified by three Notes. The reason for Note 1 l is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need to shutdown both units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for DG 1 and DG 2 when Unit 1 is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit I not in MODE 1, 2, or 3 and with Unit 2 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if DG 1 or DG 2 is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factor s 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. To minimize testing of the DGs, Note 3 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on l both units, unless the cause of the failure can be directly related to only one unit.

(continued)

L Brunswick Unit 1 B 3.8-26 Revision No. l

AC Sources-Operating i

B 3.8.1 ,

\

BASES SURVEILLANCE SR 3.8.1.10 l REQUIREMENTS .

(continued) Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.12,.this Surveillance demonstrates that DG l non-critical protective functions (e.g., high jacket water temperature) are bypassed on an ECCS initiation test signal I

and critical protective functions (engine overspeed, I generator differential overcurrent, low lubricating oil l

pressure, reverse power, loss of field, and phase overcurrent-voltage restrained) trip the DG to avert substantial damage to the rn: unit. The non-critical trips l' are bypassed during DBAs ai- ovide an alarm on an abnormal engine condition. This alt < rovides the operator with sufficient time to react ap,n ,,riately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to l

perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability l standpoint.

l The SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either

unit. If the DG fails one of these Surveills.r.ces, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.11 Brunswick Nuclea'r Plant performs a 60 minute run greater than or equal to the continuous rating (3500 kW) which bounds the maximum expected post-accident DG loading. The DG starts for this Surveillance can be performed either from (continued)

Brunswick Unit 1 B 3.8-27 Revision No. I

l AC Sources-0perating B 3.8.1 r

l BASES SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS standby or hot conditions. The provisions for prelube and l warmup, discussed in the Bases for SR 3.8.1.2, and for l gradual loading, discussed in the Bases for SR 3.8.1.3, are applicable to this SR.

In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must_ be performed using a power factor

s; 0.9. This power factor is chosen to be representative of i the actual design basis inductive loading that the DG could i

experience. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY.

The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This Surveillance has been modified by two Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. To minimize testing of the Dos, Note 2 allows a t single test (instead of two tests, one for each unit) to

! satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

l SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.13, demonstration of the test mode override feature ensures that the DG availability under accident conditions is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS' initiation (continued) i i

Brunswick Unit 1 B 3.8-28 Revision No. I

. . , - . = - . . _ - - .

AC Sources-0perating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 (continued)

REQUIREMENTS signal is received during operation in the test mode.

Ready-to-load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.4(6).

In lieu of actually returning the DG to ready-to-load status, testing that adequately shows the capability of the DG to perform this function is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire sequence is verified.

The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, l one for each unit) to satisfy the requirements for both '

units. This is allowed since the main purpose of the l Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one mit.

SR 3.8.1.13 Under accident conditions loads are sequentially connected to the bus by the automatic load sequence time delay relays.

The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated.

Reference 4 provides a summary of the automatic loading of ESF buses.

l l (continued)

Brunswick Unit 1 B 3.8-29 Revision No. l l

l l

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.13 (continued)

REQUIREMENTS The Frequency of 24 months is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs, and associated load sequence relays, are required to be OPERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce potential consequences associated with removing a l required offsite circuit from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to perform this Surveillance, the l

i Note only precludes satisfying this Surveillance ~ Requirement for the load sequence relays associated with DG 1 and DG 2 when Unit 1 is in MODE 1, 2, or 3. During the performance ;

of this Surveillance with Unit I not in MODE 1, 2, or 3 and '

with Unit 2 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit 1 and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 1, or. DG 2 is rendered inoperable by the performance of this Surveillance.

Credit may be taken for unplanned events that satisfy this 1 SR.

SR 3.8.1.11 l

In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to L

ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

i This Surveillance demonstrates DG operation during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. -This test verifies all actions 4

encountered from the event, including shedding of the (continued)

Brunswick Unit 1 B 3.8-30 Revision No. I i

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AC Sources-Operating 8 3.8.1 l

BASES SURVEILLANCE SR 3.8.1.14-(continued)

REQUIREMENTS nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The'10.5 second time period, which is allowed for the DG t~

auto-start and connect to its respective emergency bus, is conservatively derived from requirements of the accident analysis for responding to a design basis large break LOCA.

The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil

being continuously circulated and temperature maintained l consistent with procedural guidance. The reason for Note 2

! is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical

(continued)

I Brunswick Unit 1 B 3.8-31 Revision No. 1

I AC Sources-0perating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to >

mitigate DBAs and transients) between BNP Units 1 and 2, all I four DGs are required to be OPERABLE to supply power to i these systems when either one or both units are in MODE 1, l 2, or 3. In order to reduce the potential consequences associated with removing a required offsite circuit from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical distribution systems during the performance of this i

Surveillance, and reduce challenges to safety systems, while j at the same time avoiding the need to shutdown both units to j perform this Surveillance, Note 2 only precludes satisfying 1 l this Surveillance Requirement for DG 1 and DG 2 when Unit 1 l l

is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit I not in MODE 1, 2, or 3 and with Unit 2 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit 1 and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 1, DG 2, or other supported Technical Specification equipment is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR.

j REFERENCES 1. UFSAR, Section 8.3.1.2.

2. UFSAR, Sections 8.2 and 8.3.

3. NRC Diagnostic Evaluation Team Report for Brunswick i Steam Electric Plant dated August 2, 1989, from l J.M. Taylor (NRC) to S.H. Smith, Jr. (CP&L).

! 4. UFSAR, Table 8.3.1-6.

5. Safety Guide 9.

6. UFSAR, Chapter 6.

7. UFSAR, Chapter 15.

8. 10 CFR 50.36(c)(2)(ii).

, 9. Regulatory Guide 1.93, December 1974.

10. Generic Letter 84-15.

(continued)

Brunswick Unit 1 B 3.8-32 Revision No. I

AC Sources-0perating B 3.8.1 BASES REFERENCES 11. Regulatory Guide 1.9, July 1993, Revision 3.

-(continued)

12. Regulatory Guide 1.137, January 1978.

13. IEEE Standard 308.

l l'

i i

i l Brunswick Unit 1 B 3.8-33 Revision No. l l

l l

Distribution Systems-0perating B 3.8.7 8 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Distribution Systems-Operating BASES BACKGROUND The onsite Class 1E AC and DC electrical power distribution system is divided into redundant and independent AC and DC electrical power distribution subsystems.

The Class 1E AC electrical distribution system is divided into four load groups. Each load group consists of a primary emergency bus, its downstream secondary emergency bus, 120 VAC vital bus, and transformers and interconnecting cables. The buses associated with each of the four load groups are defined as follows:

Load group El consists of 4.16 kV bus El, 480 V bus ES, and 120 VAC vital bus 1ES.

Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus 1E6.

Load group E3 consists of 4.16 kV bus E3, 480 V bus E7, and 120 VAC vital bus 2E7.

Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8.

The El and E2 load groups are supplied from Unit 1 balance of plant (B0P) buses and primarily serve Unit 1 loads. The E3 and E4 load groups are supplied from Unit 2 B0P buses and ,

primarily serve Unit 2 loads. In some instances loads i associated with one unit are actually supplied from the I opposite unit's load group buses.

Each primary emergency bus (4.16 kV emergency bus) has access to two offsite sources of power via a common circuit path from its associated upstream B0P bus (master / slave breakers and interconnecting cables). In addition, each 4.16 kV emergency bus can be provided power from an onsite

diesel generator (DG) source. The upstream B0P bus i associated with each 4.16 kV emergency bus is normally connected to the main generator output via the unit auxiliary transformer. During a loss of the normal power source to the 4.16 kV BOP bus, the preferred source supply breaker attempts to close. If all offsite sources are (continued)

Brunswick Unit 1 B 3.8-71 Revision No. l

Distribution Systems-Operating B 3.8.7 l r BASES BACKGROUND unavailable, the affected 4.16 kV. emergency bus is isolated (continued) from its associated upstream 4.16 kV B0P bus and the onsite l

emergency DG will supply power to the 4.16 kV emergency bus.

Control power for each 4.16 kV emergency bus is supplied from a Class IE battery with manual transfer capability to another Class 1E battery. Additional descriptions of this

system may be found in the Bases for Specification 3.8.1, t "AC Sources-Operating," and the Bases for Specification 3.8.4, "DC Sources-Operating".

The secondary plant distribution system includes 480 VAC emergency buses E5, E6, E7, and E8 and associated motor control centers (MCCs), transformers, and interconnecting cables. Secondary emergency buses ES, E6, E7, and E8 are

, supplied from primary emergency buses El, E2, E3, and E4, respectively. Control power for each 480 VAC emergency bus is supplied from a Class .1E battery with manual transfer j capability to another Class IE battery. Additional

! descriptions of this system may be found in the Bases for Specification 3.8.4, "DC Sources-Operating".

The 120 VAC vital buses 1ES, IE6, 2E7, and 2E8 are arranged in four load groups and are powered from secondary emergency buses ES, E6, E7, and E8, respectively, i There are two independent 125/250 VDC electrical power

[ distribution subsystems.

The list of required distribution buses is presentod in Table B 3.8.7-1.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient. analyses in the UFSAR, Chapter 6 (Ref.1) and Chapter'15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC and DC electrical power ;

distribution systems are designed to provide sufficient i capacity, capability, redundancy, and reliability to ensure the availability of neces,ary power to ESF systems so that

l. the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more l detail in the Bases for Section 3.2, " Power Distribution Limits"; Section 3.5, " Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System"; and Section 3.6, " Containment Systems."

(continued) l 2

l Brunswick Unit 1 B 3.8-72 Revision No. I 1

--,-r- n n

, - -n, ,e m - -~. e --. .-,,,e . ee-m-w- -r .e

l Distribution Systems-0perating B 3.8.7 i

BASES APPLICABLE The OPERABILITY of the AC and DC electrical power l SAFETY ANALYSES distribution subsystems is consistent with the initial (continued) assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes

, maintaining distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power; and

b. A worst case single failure.

The AC and DC electrical power distribution system satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

l LC0 The required electrical power distribution subsystems listed

. in Table B 3.8.7-1 ensure .the availability of AC and DC L

electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (A00) or a postulated DBA. The Unit 1 AC and DC electrical power distribution subsystems are required to be OPERABLE. In addition, since some components required by Unit I receive power through Unit 2 DC electrical power distribution subsystems (e.g.,

, control power for two of the four 4.16 kV emergency buses, l two of the four 480 VAC emergency buses, and for two of the DGs, and two of four engineered safeguard system (ESS) panels), the Unit 2 DC electrical power distribution subsystems needed to support the required equipment must l also be OPERABLE. As stated in Table B 3.8.7-1, each '

division of the AC and DC electrical power distribution systems is a subsystem.

Maintaining the Division I and II AC and DC electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated.

Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

!. The AC electrical power distribution subsystems require the associated buses and electrical circuits to be energized to their proper' voltages. The DC electrical power distribution subsystems require the associated buses to be energized to their proper voltage from either the associated batteries or

! chargers.

(continuedl i

Brunswick Unit 1 B 3.8-73 Revision No. I

i Distribution Systems-Operating B 3.8.7 BASES LC0 Based on the number of safety significant electrical loads (continued) associated with each bus listed in Table B 3.8.7-1, if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LLO 3.8.7 is required. Other buses, such as MCCs and distribution panels, which help comprise the AC and DC distribution systems are not listed in Table B 3.8.7-1. The loss of electrical loads associated with these buses may not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in i Table B 3.8.7-1 (e.g., a breaker supplying a single MCC !

fails open), the individual loads on the bus must be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., loss of a 4.16 kV l emergency bus, which results in de-energization of all buses l powered from the 4.16 kV emergency bus), then although the individual loads are still considered inoperable, the Conditions and Required Actions of the LC0 for the individual loads are not required to be entered, since LC0 3.0.6 allows this exception (i.e., the loads are inoperable due to the inoperability of a support system governed by a Technical Specification; the 4.16 kV emergency bus).

In addition, tie breakers and transfer switches between redundant safety related AC and DC power distribution subsystems, if they exist, must be open. This includes control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, which could cause the failure of a redundant subsystem and a loss of essential safety function (s). If any tie breakers are closed or transfer switches aligned to the alternate supply, the affected redundant electrical power distribution subsystems

, are considered inoperable. This applies to the onsite, safety related, redundant electrical power distribution subsystems. It does not, however, preclude redundant l Class IE 4.16 kV emergency buses from being powered from the j same offsite circuit.

(continued)

Brunswick Unit 1 B 3.8-74 Revision No. I l

l Distribution Systems-0perating l B 3.8.7 l

BASES (continued) l APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and

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

Electrical power distribution subsystem requirements for MODES 4 and 5 and other conditions in which AC and DC electrical power distribution subsystems are required are covered in the Bases for LC0 3.8.8, " Distribution Systems-Shutdown. "

ACTIONS A.1 With one AC electrical power distribution subsystem inoperable due to either inoperable load group E3 bus (es) or inoperable load group E4 bus (es), the remaining AC electrical power distribution load groups are capable of supporting the minimum safety functions necessary to shut down the operating reactor and maintain both reactors in a safe condition, assuming no single failure in the remaining AC electrical power distribution load groups, when Unit 2 is in MODE 4 or 5. (If Unit 2 is in MODE 1, 2, or 3, then the Unit 2 ACTIONS of Specification 3.8.7, " Distribution Systems-0perating," require restoration of the associated AC electrical power distribution subsystem within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of the inoperability.) The overall reliability is reduced in Condition A, because a single failure in a remaining load group could result in the minimum required ESF functions not being supported. As a result, Required Action A.1 limits the time period to perform planned maintenance on a Unit 2 load group to 7 days. This is acceptable based on the following:

a. The other unit's load group buses are not as critical to the operating unit (fewer operating unit loads) as the operating unit's load group buses.

b. Performing maintenance on these components will increase the reliability of the Class IE AC Electrical Power Distribution System.

l l (continued)

Brunswick Unit 1 B 3.8-75 Revision No. I

Distribution Systems-Operating B 3.8.7 l BASES ACTIONS M (continued)

c. The 7 day Con.pletion Time provides a reasonable time frame for performance of planned maintenance.

During the planned maintenance of the load group buses, if a l

condition is discovered on these buses requiring corrective maintenance, this maintenance may be performed within the 7 day Completion Time of Required Action A.1.

l The Class 1E AC Electrical Power Distribution System is divided into four load groups. Each load group consists of I a primary emergent.y bus, its downstream secondary emergency bus,120 VAC vital bus, and transformers and interconnecting '

l cables. The buses associated with each of the four load j I groups are defined as follows: i l

Load group El consists of 4.16 kV bus El, 480 V j bus E5, and 120 VAC vital bus 1E5.

l l

Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus 1E6. I l Load group E3 consists of 4.16 kV bus E3, 480 V bus E7, and 120 VAC vital bus 2E7.

Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8. j The second Completion Time for Required Action A.1 l establishes a limit on the maximum time allowed for any l combination of required distribution subsystems to be l

inoperable during any single contiguous occurrence of failing to meet the LC0. If Condition A is entered while, for instance, an AC bus in a load group in a different ;

division is inoperable and subsequently returned OPERABLE, l this LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months l (since initial failure to meet the LCO) to restore the AC Electrical Power Distribution System. At this time an AC bus in a load group in a different division could again become inoperable, and the load group removed under Condition A could be restored OPERABLE. This could continue indefinitely.

(continued) i Brunswick Unit 1 B 3.8-76 Revision No. I t.

Distribution Systems-0perating j

B 3.8.7 l t l l

BASES ACTIONS A.1 (continued)

This Completion Time allows for an exception to the normal l

" time zero" for beginning the allowed outage time " clock".

This results in establishing the " time zero" at the time this LC0 was initially not met, instead of at the time Condition A was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time is an acceptable limitation on this potential to fail to meet the LC0 indefinitely.

If while in Condition A, emergency buses associated with another load group become inoperable (e.g., buses in load groups E3 and E4 are concurrently inoperable), Condition B and F must be entered, as appropriate.

B.1 l With one or more required AC buses or distribution panels in one division inoperable for reasons other than Condition A, I the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining AC electrical power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Condition B worst scenario is one division without AC l power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit and restoring power to the affected division. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

(continued)

Brunswick Unit 1 B 3.8-77 Revision No. I

Distribution Systc;ms-Operating B 3.8.7 BASES l ACTIONS S_.1 (continued) l

a. .The potential for decreased safety if the unit operators attention is diverted from the evaluations 3 and actions necessary to restore power to the affected '

division to the actions associated with taking the i unit to shutdown within this time limit. i

b. The low potential for an event in conjunction with a single failure of a redundant component in the i division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.11, " Safety Function Determination Program (SFDP).")

The second Completion-Time for Required Action 8.1 l establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be

, inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, I :

for instance, a DC bus is inoperable and subsequently '

returned OPERABLE, this LC0 may already have been not met for up to 7 days. '_This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months , since initial failure to meet the 1 LCO, to restore the AC electrical power distribution system.

At this time a DC bus could again become inoperable, and the AC electrical power distribution system could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

This results in establishing the " time zero" at the time this LCO was initially not met, instead of at the time Condition B was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time -is an I acceptable limitation on this potential to fail to meet the !

L LC0 indefinitely.

C.I. C.2. C.3 and C.4 l With one or more DC electrical power distribution subsystems inoperable due to loss of normal DC source, the remaining DC

electrical power distribution subsystem (s) are capable of

! supporting the minimum safety functions necessary to shutdown the reactor and maintain it in a safe shutdown condition, provided safety function is not lost and assuming no single failure. However, the overall reliability is l

l (continued) i Brunswick Unit 1 B 3.8-78 Revision No. l l

Distribution Systems-Operating B 3.8.7 t

BASES l

ACTIONS C.l. C.2. C.3 and C.4 (continued) l l

reduced because a single failure in the DC electrical power distribution system could result in a loss of two of four AC electrical load groups and the minimum required ESF functions not being supported. Therefore, action must be immediately initiated to transfer the DC electrical power

! distribution system to its alternate source and the affected supported equipment immediately declared inoperable. Upon completion of the transfer of the affected supported equipment's DC electrical power distribution subsystem to its OPERABLE alternate DC source, the affected supported equipment may be declared OPERABLE again. The ESS logic cabinets transfer automatically upon loss of the normal source. For an ESS logic cabinet, verification that the automatic transfer has occurred and alternate power is available to the ESS logic cabinet will satisfy Required Action C.2. By allowance of the option to declare affected I supported equipment inoperable with associated DC electrical power distribution subsystems inoperable due to loss of normal DC source, more conservative restrictions are implemented in accordance with the affected system LCOs' ACTIONS. When any control power transfer switch associated with the 4.16 kV and 480 V emergency buses or any transfer switch associated with the ESS and DG panels is transferred to the alternate source, a single failure in the DC system could render two of four AC electrical load groups inoperable. Therefore, to prevent indefinite operation in this degraded condition, power from the normal DC source must be restored in 7 days.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention.

Required Actions C.1 and C.2 should be completed as quickly I as possible. The 7 day Completion Time of Required Action C.4 is considered to be acceptable due to the low I potential for an event in conjunction with a single failure of a redundant component and is consistent with the allowed Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-Operating."

The second Completion Time for Required Action C.4 I establishes a limit on the maximum time allowed for any

combination of required electrical power distribution

! subsystems to be inoperable during any single contiguous i occurrence of failing to meet the LCO. If Condition C is l L

! (continued) l Brunswick Unit 1 B 3.8-79 Revision No. l l

Distribution Systems-0perating 8 3.8.7 BASES ACTIONS C.I. C.2. C.3 and C.4 (continued) I entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months , since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and the DC. electrical power distribution system could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

This allowance results in establishing the " time zero" at the time the LC0 was initially not met, instead of at the time Condition C was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time I is an acceptable limitation on this potential of failing to meet the LC0 indefinitely.

D.d I With one DC electrical power distribution subsystem inoperable for reasons other than Condition C, the remaining l DC electrical power distribution subsystem is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC electrical power distribution subsystem must be restored to OPERABLE status within 7 days by powering the bus from the associated batteries or chargers.

Cor.dition D represents one division without adequate DC l power, potentially with both the battery (s) significantly degraded and the associated charger (s) nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division.

(continued)

Brunswick Unit 1 8 3.8-80 Revision No. I h

. . . . . . __ - . _ . . _ . _.._____..__.____._...._.___.__.m._

i Distribution Systems-0perating l B 3.8.7 BASES E

ACTIONS Q.d (continued) l The 7 day Completion Time is consistent with the allowed Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-Operating". Taking exception to LC0 3.0.2 for.

components without adequate DC power, which would have Required Action Completion Times shorter than 7 days, is acceptable because of:

L a. The potential for decreased safety when requiring a l

change in plant conditions (i.e., reauiring a i shutdown) while not allowing stable operations tc ;

, continue; l b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required l Actions for components without DC power, while not j providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division;

c. The low potential for an event in conjunction with a single failure of e redundant component.

The ser.ond Completion Time for Required Action D.1 I establishes a limit on the maximum time allowed for any l' combination of required electrical power distribution

subsystems to be inoperable during any single contiguous l occurrence of failing to meet the 1CO. If Condition D is I

' entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months , since initial failure to meet the LCO, to restore the DC electrical power l distribution system. At this time, an AC bus could again

become inoperable, and the DC electrical power distribution

! system could be restored OPERABLE. This could continue j indefinitely.

This Completion Time allows for an exception to the normal

, " time zero" for beginning the allowed outage time " clock."

This allowance results in establishing the " time zero" at the time the LC0 was initially not met, instead of at the time Condition D was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time I is an acceptable limitation on this potential of failing to meet the LC0 indefinitely.

1 (continued) f Brunswick Unit 1 B 3.8-81 Revision No. l l

1. . - . - _

Distribution Systems-Operating B 3,0.7 4

BASES ACTIONS E.1 and E.2 l (continued)

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

F.1 Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the plant is in a condition outside the accident ana bsis. Therefore, no additional time is justified for continued operation.

LC0 3.0.3 must be entered immediately to commence a controlled shutdown.

SUP.VEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. This includes verifying that distribution bus tie breakers are open and control power transfer switches associated with the 4.16 kV and 480 Y emergency buses and transfer switches associated with the ESS and DG panels are aligned to their normal DC sources. The correct breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained, and power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. This may be performed by verification of absence of low voltage alarms or by verifying a load powered from the bus is operating. The (continued)

Brunswick Unit 1 B 3.8-82 Revision No. I

Distribution Systems-0perating ;

B 3.8.7 BASES SURVEILLANCE SR 3.8.7.1 (continued)

REQUIREMENTS I 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

SR 3.8.7.2 This Surveillance verifies that no combination of more than two power conversion modules (consisting of either two lighting inverters or one lighting inverter and one plant uninterruptible power supply unit) are aligned to Division II (bus B). Two power conversion modules aligned to Division II (bus B) was an initial assumption in the DC battery load study. Limiting two power conversion modules to be aligned to Division 11 ensures the associated batteries will supply DC power to safety related equipment during a design basis event. The 7 day Frequency takes into account the redundant capability of the DC electrical power distribution subsystems and indications available in the control room to alert the operator of power conversion module misalignment.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

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

Brunswick Unit 1 B 3.8-83 Revision No. I

. - .. - - . ~ . - ..-. -. .- - - ~ . - . . - . . - - . . - . . - ~

1 i

Distribution Systems--Operating .

B 3.8.7 !

l Table B 3.8.7-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems TYPE VOLTAGE DIVISION I(a) DIVISION II(a) l AC emergency 4160 V Emergency Buses Emergency Buses buses El, E3 E2, E4 i 1

480 V Emergency Buses Emergency Buses l ES, E7 E6, E8 >

L AC vital buses 120 V Distribution Distribution l Panels Panels IES, 2E7 1E6, 2E8 i l

?

DC buses 250 V Switchboard 1A Switchboard 1B 125 V ESS logic ESS logic Cabinets Cabinets H58, H60 H59, H61 125 V PG Panels DG Panels DG-1, DG-3 DG-2, DG-4 DC control 125 V 4.16 kV Switchgear 4.16 kV Switchgear power buses El, E3 E2, E4 125 V ~480 V 480 V i

Switchgear Switchgear !

ES, E7 E6, E8 i

(a) Each division of the AC and DC electrical power distribution systems is a subsystem.

Brunswick Unit 1 B 3.8-84 Revision No. I

.-. . .. ... -. . - - - - _= _ . _ . - . . - - . .

l ENCLOSURE 4 l

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 , l DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 l ADDITIONAL INFORMATION REGARDING BALANCE OF PLANT / EMERGENCY BUS ALLOWABLE OUTAGE TIME EXTENSION (NRC TAC NOS. M97243 AND M97244) i UNIT 2 ITS SECTION 3.8 AND BASES i

l l

l

AC Sources--Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources--Operating LC0 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two Unit 2 qualified circuits between the offsite transmission network and the onsite Class IE AC

Electrical Power Distribution System;

b. Four diesel generators (DGs); and

c. Two Unit 1 qualified circuits between the offsite l transmission network and the onsite Class IE AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ---

NOTE--------- A.1 Restore Unit 1 45 days Only applicable when offsite circuit to Unit 1 is in H0DE 4 OPERABLE status.

or 5.

l One Unit 1 offsite circuit inoperable.

(continued) l l

Brunswick Unit 2 3.8-1 Amendment No. I

l AC Sources-0perating 3.8.1 ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME l l B. Two Unit 1 offsite B.1 Declare required Immediately from circuits inoperable feature (s) with no discovery of ;

due to one Unit 1 offsite power Condition B l balance of plant available inoperable concurrent with l circuit path to the when the redundant inoperability of l downstream 4.16 kV required feature (s) redundant I emergency bus are inoperable. required l inoperable for planned feature (s) maintenance.

AND AND DG cssociated with the B.2 Perform SR 3.8.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months affected downstream for OPERABLE offsite 4.16 kV emergency bus circuit (s). AND inoperable for planned maintenance. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 1 i

AND l

B.3 Restore both Unit 1 7 days offsite circuits and DG to OPERABLE AND status.

10 days from discovery of failure to meet LC0 3.8.1.a or b C. One offsite circuit C.1 Perform SR 3.8.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable for reasons for OPERABLE offsite other than Condition A circuit (s). AND or B.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter l AND (continued)

Brunswick Unit 2 3.8-2 Amendment No. I

._ . .. .. . - - - _ . . . .. - . - . ~ . - . . - . . ~ . . . . - -. - . . . . - . . . . . . . . .

AC Sources-0perating i l- 3.8.1 l l

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature (s) with no discovery of no l offsite power offsite power to available inoperable one 4.16 kV .

when the redundant emergency bus !

required feature (s) concurrent with are inoperable. inoperability of redundant required !

feature (s)

MP.

! C.3 Restore offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE l status. AND 10 days from

, discovery of L failure to meet l LC0 3.8.1.a or b D. One DG inoperable for D.1 Perform SR 3.8.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reasons other than for OPERABLE offsite

! Condition B. circuit (s). AND i

j Once per

! 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months l thereafter AND D.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature (s), supported discovery of by the inoperable DG, Condition D inoperable when the concurrent with redundant required inoperability of feature (s) are redundant l inoperable. required feature (s)

AND (continued) l Brunswick Unit 2 3.8-3 Amendment No. l l

AC Sources--Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l

l D. (continued) D.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months l DG(s) are not ;

inoperable due to 1 common cause failure. 1 og D.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE DG(s). !

AND 0.4 Restore DG to 7 days OPERABLE status.

AND 10 days from d i s t'- a, f faiiure to meet LC0 3.8.1.a or b E. Two or more offsite E.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable feature (s) inoperable discovery of for reasons other than when the redundant Condition E Condition B. required feature (s) concurrent with are inoperable. inoperability of redundant required feature (s)

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

(continued)

Brunswick Unit 2 3.8-4 Amendment No. I

l AC Sources-0perating 3.8.1 ACTIONS (continued)

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

inoperable for reasons Enter applicable Conditions other than and Required Actions of Condition B. LC0 3.8.7, " Distribution Systems--Operating," when AND Condition F is entered with no AC power source'to any One DG inoperable for 4.16 kV emergency bus.

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

Condition B.

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

OR i

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

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

H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, AND B, C, D, E, F or G not met. H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued) l l

Brunswick Unit 2 3.8-5 Amendment No. l l

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AC Sources-0perating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I. One or more offsite- I.1. Enter LCO 3.0.3. Immediately circuits and two or more DGs inoperable.

98 Two or more offsite circuits and one DG inoperable for reasons other than '

Condition B.

SURVEILLANCE-REQUIREMENTS SURVEILLANCE FREQUENCY i

SR 3.8.1.1 Verify correct breaker alignment and 7 days l indicated power availability for each offsite circuit.

l (continued)

L l r !

i- i

i

- Brunswick Unit 2 3.8-6 Amendment No. l l~

e

t AC Sources-_0perating 3.8.1 i

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l

l SR 3.8.1.2 -------------------NOTES-------------------

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

2. A modified DG start involving idling l and gradual acceleration to f

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.

j 3. A single test at the specified i

Frequency will satisfy this Surveillance for both units.

Verify each DG starts from standby 31 days conditions and achieves steady state

, voltage 2: 3750 V and s 4300 V and frequency l 2: 58.8 Hz and s 61.2 Hz.

(continued) l l

l l

i l l l 1

I Brunswick Unit 2 3.8-7 Amendment No. l l

l

_ _ . . . . . - _ _ _ _ _ . . ~ . _. _ _ - - _ . .

AC Sources--Operating 3.8.1 l

l I

SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------NOTES-------------------

1. DG loadings may include gradual loading.

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

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

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 31 days and operates for a 60 minutes at a load 2: 2800 kW and s 3500 kW.

SR 3.8.1.4 Verify each engine mounted tank contains 31 days 2: 150 gal of fuel oil.

SR 3.8.1.5 Check for and remove accumulated water from 31 days each engine mounted tank.

SR 3.8.1.6 Verify the fuel oil transfer system 31 days operates to transfer fuel oil from the day fuel oil storage tank to the engine mounted tank.

l (continued) i l

Brunswick Unit 2 3.8-8 Amendment No. I

- _. -. . = . . - .. . -- .. _ - . . . . - . -

AC Sources--Operating l 3.8.1 i

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7 -------------------NOTES-------------------

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

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

l Verify each DG starts from standby 184 days j condition and achieves, in s 10 seconds, l voltage a: 3750 V and frequency 2: 58.8 Hz, and after steady state conditions are reached, maintains voltage 2: 3750 V and s 4300 V and frequency 2: 58.8 Hz and s 61.2 Hz.

l (continued) i l

l

! Brunswick Unit 2 3.8-9 Amendment No. I

1 AC Sources--Operating 3.8.1 !

)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.8 -------------------NOTES-------------------

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.

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

the preferred offsite circuit.

l

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

'l l

l Verify: 24 months

a. Automatic transfer capability of the unit power supply from the normal

circuit to the preferred offsite

! circuit; and

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

(continued) i i

Brunswick Unit 2 3.8-10 Amendment No. I

- - . _ . - . . _ _ - . . _ . . - -. , - - - . _ _ . . . - - . . - - ~ _ . ..

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.9 ------

NOTES-------------------

l 1. T. o

Surveillance shall not be performed in MODE 1, 2, or 3 for DG 3 and DG 4. However, credit may be l 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 s 0.9.

?

3. A single test at the specified

, Frequency will satisfy this Surveillance for both units.

l Verify each DG rejects a load greater than 24 months or equal to its associated core spray pump without tripping, i

(continued) l l'

l l

i t

Brunswick Unit 2 3.8-11 Amendment No. l l

l AC Sources--Operating )

3.8.1 l l SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l

SR 3.8.1.10 --------------------NOTE-------------------

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

Verify each DG's automatic trips are 24 months bypassed on an actual or simulated ECCS initiation signal except:

a. Engine overspeed;

b. Generator differential overcurrent; i

c. Low lube oil pressure;

)

d. Reverse power;

e. Loss of field; and

f. Phase overcurrent (voltage restrained).

l (continued) l l

l i

l Brunswick Unit 2 3.8-12 Amendment No. I

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 1

l SR 3.8.1.11 -------------------NOTES-------------------

l. 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 24 months s 0.9 operates for 2: 60 minutes loaded to a 3500 kW and s 3850 kW.

SR 3.8.1.12 -------------------NOTE--------------------

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

l

! Verify an actual or simulated ECCS 24 months initiation signal is capable of overriding the test mode feature to return each DG to ready-to-load operation.

(continued) i l

t 4

Brunswick Unit 2 3.8 13 Amendment No. l l

l t

1 AC Sources-0perating i 3.8.1 ]

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l

SR 3.8.1.13 -------------------NOTE-------------------- l This Surveillance shall not be performed in l MODE 1, 2, or 3 for the load sequence !

relays associated with DG 3 and DG 4. ,

However, credit maybe taken for unplanned j events that satisfy this SR. ;

Verify interval between each sequenced load 24 months l block is within i 10% of design interval I for each load sequence relay.

(continued)

Brunswick Unit 2 3.8-14 Amendment No. l

AC Sources--Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) I 1

SURVEILLANCE FREQUENCY SR 3.8.1.14 -------------------NOTES------------------- i

1. All DG starts may be preceded by an I 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 24 months offsite power signal in conjunction with an l actual or simulated ECCS initiation signal: )

a. De-energization of emergency buses;

b. Load shedding from emergency buses; and l 4

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in s; 10.5 seconds,

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

3. maintains steady state voltage 2: 3750 V and s 4300 V, maintains steady state frequency 4.

2: 58.8 Hz and s; 61.2 Hz, and l 5. supplies permanently connected and l l auto-connected emergency loads for 2: 5 minutes.

r d

Brunswick Unit 2 3.8-15 Amendment No. I l

l l

AC Sources-Shutdown 3.8.2 l 3.8 ELECTRICAL POWER SYSTEMS i

3.8.2 AC Sources-Shutdown l

LC0 3.8.2 The following AC electrical power sources shall be OPERABLE:

i

! a. One Unit 2 qualified circuit between the offsite 1 transmission network and the onsite Class 1E AC electrical power distribution subsystem (s) required by LC0 3.8.8, " Distribution Systems-Shutdown";

b. Two diesel generators (DGs) capable of supplying onsite Class IE AC electrical power distribution subsystem (s) required by LCO 3.8.8; and

c. One Unit 1 qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem (s) needed to support the Unit 1 equipment required to be OPERABLE by LC0 3.7.3, " Control Room Emergency Ventilation (CREV)

System," LC0 3.7.4, " Control Room Air Conditioning (AC)

System," and LCO 3.8.5, "DC Sources-Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the i secondary containment.

l ll l- Brunswick Unit 2 3.8-16 Amendment No. I f

AC Sources-Shutdown 3.8.2 i ACTIONS

............___......................N0TE-----------------------------------.-

LCO 3.0.3 is not applicable. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required ------------NOTE-------------

offsite circuits Enter applicable Condition inoperable, and Required Actions of LC0 3.8.8, with one or more l

required 4.16 kV emergency buses de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature (s),

with no offsite power available, inoperable.

OR A.2.1 Suspend CORE Immediately I ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND A.2.3 Initiate action to Immediately suspend operations with a potential for L draining the reactor t

vessel (0PDRVs).

l AND (continued) l Brunswick Unit 2 3.8-17 Amendment No. I

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.4 Initiate action to Immediately restore required offsite power circuit to OPERABLE status, B. One required DG B.1 Declare affected Immediately inoperable. required feature (s) with no DG available inoperable.

OB B.2.1 Suspend CORE Immediately ALTERATIONS.

AND B.2.2 Saspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND B.2.3 Initiate action to Immediately suspend OPDRVs.

AND B.2.4 Initiate action to Immediately restore required DG to OPERABLE status.

(continued)

Brunswick Unit 2 3.8-18 Amendment No. I

l AC Sources-Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two required DGs C.1 Suspend CORE Immediately inoperable. ALTERATIONS. ;

l i

m ;

i C.2 Suspend movement of Immediately l irradiated fuel i assemblies in l l

secondary l containment.

M C.3 Initiate action to Immediately suspend OPDRVs.

AND C.4 Initiate action to Immediately restore required DGs to OPERABLE status, i

l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -------------------NOTE--------------------

Unless required to be performed by Unit 1 Specification 3.8.1, the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.14.

For AC sources required to be OPERABLE, the In accordance SRs of Specification 3.8.1, except with applicable SR 3.8.1.8 and SR 3.8.1.12, are applicable. SRs 1

Brunswick Unit 2 3.8-19 Amendment No. l

Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS l l

3.8.3 Diesel Fuel Oil I LC0 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS l

_____________..._____..--------NOTE-------------------------------------

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.I Restore required day 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months DGs with fuel oil fuel oil storage tank level in the level to within associated day fuel limit.

oil storage tank (s)

< 22,650 gal per required DG and 2: 17,000 gal per required DG, AND Fuel oil level in the main fuel oil storage tank 2: 20,850 gal per required DG, (continued) i i

l Brunswick Unit 2 3.8-20 Amendment No. I

Diesel Fuel Oil 3.8.3 l

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Restore main fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months DGs with fuel oil storage tank level to level in the main fuel within limit.

oil storage tank l < 20,850 gal per required DG and 2: 13,900 gal per required DG.

A!!Q Fuel oil level in the l required day fuel oil i storage tank (s) 2: 22,650 gal per l required DG. !

l l

C. One or more DGs with C.1 Restore stored fuel 7 days stored fuel oil total oil total particulates not particulates to within limit. within limit.

D. Required Action and 0.1 Declare associated DG Immediately associated Completion inoperable.

Time Condition A, B, or C not met.

OR One or more DGs with i diesel fuel oil not within limits for reasons other than Condition A, B, or C.

l

(. Brunswick Unit 2 3.8-21 Amendment No. l l

i Diesel Fuel Oil 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 For each required DG, verify: 31 days

a. The associated day fuel oil storage tank contains 2: 22,650 gal; and

b. The main fuel oil storage tank contains 2: 20,850 gal per required DG.

SR 3.8.3.2 Verify fuel oil properties of stored fuel In accordance oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Oil Fuel Oil Testing Program. Testing Program SR 3.8.3.3 Check for and remove accumulated water from 31 days each day fuel oil tank and the main fuel oil storage tank.

i Brunswick Unit 2 3.8-22 Amendment No. I I

DC Sources--Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources--Operating I

LCO 3.8.4 The following DC electrical power subsystems shall be OPERABLE:

a. Unit 2 Division I and Division II DC electrical power subsystems; and

b. Unit 1 Division I and Division II DC electrical power subsystems, i APPLICABILITY: MODES I, 2, and 3. l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One DC electrical A.I --------NOTE--------- I power subsystem Enter applicable inoperable. Conditions and Required Actions of LC0 3.8.7,

" Distribution Sys tems --Operati ng ,"

when Condition A results in de-energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem.

Restore DC electrical 7 days power subsystem to OPERABLE status.

(continued)

Brunswick Unit 2 3.8-23 Amendment No. I

l DC Sources-0perating 3.8.4 i

l ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I l

l 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

! assc::iated Completion Time of Condition A AND not met. i 1

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months M

i

, Two or more DC l electrical power subsystems inoperable.

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

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

M Verify battery connection resistance is s 23.0 pohms for inter-cell connections and s 82.8 pohms for inter-rack connections.

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

l (continued)

Brunswick Unit 2 3.8-24 Amendment No. I

DC Sources--Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery 18 months cell to cell and terminal connections are coated with anti-corrosion material.

SR 3.8.4.5 Verify each required battery charger 24 months supplies at 250 amps at 2: 135 V for a: 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SR 3.8.4.6 -----

NOTES-------------------

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 ie adequate to 24 months supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

(continued)

Brunswick Unit 2 3.8 25 Amendment No. l

_ ___a

DC Sources-0perating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE ' FREQUENCY

-SR 3.8.4.7 -------------------NOTES-------------------

1. This Surveillance shall not be performed in MODE 1 or 2 for the i Unit 2 DC electrical power subsystems.

However, credit may be taken for i unplanned events that satisfy this SR.

I 2. A single test at the specified I l Frequency will satisfy this !

Surveillance for both units. 1 l

Verify battery capacity is 2: 80% of the 60 months manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation or has reached 85%

of the expected l life with

! capacity l < 100% of l manufacturer's l rating l

AND 24 months when battery has i reached 85% of l the expected life with capacity l

i 2 100% of l manufacturer's

! rating l

l l

1 i

Brunswick Unit 2 3.8-26 Amendment No. I

l l

DC Sources--Shutdown l 3.8.5 3.8 ELECTRICAL POWER SYSTEMS l 3.8.5 DC Sources--Shutdown l

LC0 3.8.5 The following DC electrical power subsystems shall be OPERABLE:

l

a. The Unit 2 DC electrical power subsystems needed to support the DC electrical power distribution ;

subsystem (s) required by LC0 3.8.8, " Distribution Systems--Shutdown;" and

b. The Unit 1 DC electrical power subsystem needed to

support the DC electrical power distribution subsystem (s) required by LC0 3.8.8, " Distribution i

Sys tems --Shutdown . " !

l l

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the I secondary containment.

ACTIONS l

____..___... _____________.._________ NOTE-------------------------------------

LC0 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately DC electrical power required feature (s) subsystems inoperable. inoperable.

OB i A.2.I Suspend CORE Immediately ALTERATIONS.

1 AND l (continued)

Brunswick Unit 2 3.8-27 Amendment No. I l

I

DC Sources--Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION CDMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the l secondary containment.

! AND 1

l A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

AND A.2.4 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

l-l l

l l

\.

l l

i l

4 Brunswick Unit 2 3.8-28 Amendment No. I i

DC Sources--Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 -------------------NOTE--------------------

Unless required to be performed by Unit 1 Specification 3.8.4, the following SRs are not required to be performed: SR 3.8.4.6 and SR 3.8.4.7.

For DC electrical power subsystems required- In accordance to be OPERABLE the following SRs are with applicable applicable: SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, 3 SR 3.8.4.4, SR 3.8.4.5, SR 3.8.4.6, and SR 3.8.4.7.

l-l t

l i

Brunswick Unit 2 3.8-29 Amendment No. I i

! Battery Cell Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Cell Parameters LC0 3.6.6 Battery cell parameters for the Unit 2 Division I and II batteries and the Unit 1 Division I and II batteries shall be within the limits of Table 3.8.6-1. ,

i .ANQ Battery cell average electrolyte temperature for the Unit 2 Division 1 and II betteries and the Unit 1 Division I and II batteries shall be within required limits.

APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

l ACTIONS

.____.......__________.....___..-----NOTE-------------------------------------

Separate Condition entry is allowed for each battery.

l l CONDITION REQUIRED ACTION COMPLETION TIME A. One or more batteries A.1 Verify pilot cells I hour with one or more electrolyte level and battery cell float voltage meet i

parameters not within Table 3.8.6-1 l Category A or B Category C limits.

limits.

AND A.2 Verify battery cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months parameters meet Table 3.8.6-1 AND i Category C limits.

I Once per 7 days thereafter l AND l

l (continued) i 1 i

Brunswick Unit 2 3.8-30 Amendment No. I l

=~ _ -.

l t

Battery Cell Parameters 3.8.6 i

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ,

i l

A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B liinits of ;

Table 3.8.6-1. '

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

Time of Condition A not met. '

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

QB 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 7 days Table 3.8.6-1 Category A limits.

(continued) i l Brunswick Unit 2 3.8-31 Amendment No. I

Battery Cell Parameters 3.8.6 i

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY l

SR 3.8.6.2 Verify battery cell parameters meet 92 days Table 3.8.6-1 Category B limits.

SR 3.8.6.3 Verify average electrolyte temperature of 92 days representative cells is 2 60*F.

l 1

i r

1 I

l i

l l

l Brunswick Unit 2 3.8-32 Amendment No. l

Batter,v Cell Parameters 3.8.6 Table 3.8.6-1 (page 1 of 1)

Battery Cell Parameter Requirements CATEGORY A: CATEGORY B: CATEGORY C:

LIMITS FOR EACH LIMITS FOR EACH LIMITS FOR DESIGNATED PILOT CONNECTED CELL EACH LONNECTED PARAMETER CELL CELL Electrolyte > Minimum level > Minimum level Above top of Level indication mark, and indication mark, plates, and not s i inch above and s i inch above overflowing maximum level maximum level indication mark (a) indication mark (a)

Float Voltage a: 2.13 V 2 2.13 V 2: 2.07 V 2: 1.200 a: 1.195 Not more than Specifig Gravitytb )(c) 0.020 below AND average of all connected cells Average of all connected cells AND a: 1.205 Average of all connected cells 2: 1.195 (a) It is acceptable for the electrolyte level to temporarily increase above the specified maximum level during and following equalizing charges provided it is not overflowing.

(b) Corrected for electrolyte temperature and level. However, level correction is not required when on float charge and battery charging current is < 2 amps.

(c) A battery charging current of < 2 amps when on float charge is acceptable for meeting specific gravity limits following a battery recharge, for a maximum of 7 days. When charging current is used to satisfy specific gravity requirements, specific gravity of each connected cell shall be measured prior to expiration of the 7 day allowance.

Brunswick Unit 2 3.8-33 Amendment No. I

g

! Distribution Systems--Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems--Operating i

LCO 3.8.7 Division I and Division II AC and DC electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One AC electrical A.1 Restore affected load 7 days power distribution group bus (es) to subsystem inoperable OPERABLE status. AND for planned maintenance due to 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from l either inoperable load discovery of I group El bus (es) or failure to meet inoperable load group the LC0 E2 bus (es).

B. One or more AC- B.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution '

distribution subsystems to AND subsystems inoperable OPERABLE status.

for reasons other than 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from Condition A. discovery of failure to meet LCO (continued) i' i

I e

Brunswick Unit 2 3.8-34 Amendment No. l l

- . - . . - . - - . . ~ . . . - - . - . . . , - . . -

I.

Distribution Systems-0perating 3.8.7 ;

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME l

C. One or more DC C.1 Declare required Immediately I electrical power feature (s), supported distribution by the inoperable DC ,

i subsystems inoperable electrical power !

!- due to loss of normal distribution l l

DC source, subsystem, ;

inoperable. l l AND I i

C.2 Initiate action to Immediately I transfer DC

{'

electrical power distribution subsystem to its l alternate DC source.

AND l C.3 Declare required Upon completion I feature (s) supported of transfer of by the inoperable DC the required electrical power feature's DC l distribution electrical power subsystem OPERABLE. distribution '

subsystem to its OPERABLE alternate DC source AND C.4 Restore DC electrical 7 days l power distribution subsystem to OPERABLE AND l status.

176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet the LC0 l

t

( (continued) i Brunswick Unit 2 3.8-35 Amendment No. I l

c

_ . . . _ m . . . . _ > _ _ . _ _ _ . . . _ _ _ . . . _ _ _ _ _ . _ . _ . . _ . _ . _ _ . . _ . . . . . _ _ _ . _

Distribution Systems-Operating 3.8.7 ,

ACTIONS (cnntinued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC D.1 Restore DC electrical 7 days l electrical power power distribution distribution subsystems to AND subsystems inoperable OPERABLE status, for reasons other than 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from l Condition C. discovery of failure to meet LC0 E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I associated Completion Time of Condition A, AND B, C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two or more electrical F.1 Enter LC0 3.0.3. Immediately l 1 power distribution subsystems inoperable that result in a loss of function.

(

I I

i i

1 Brunswick Unit 2 3.8-36 Amendment No. I l

l

_. _ _ _ _ . . _ _ _ . , . . ~ __ _ . __ . _ _ _ -_ __ __ _ . _ . -

Distribution Systems--Operating 3.8.7 '

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems.

SR 3.8.7.2 Verify no combination of more than two 7 days l power conversion modules (consisting of !

either two lighting inverters or one lighting inverter and one plant uninterruptible power supply unit) are aligned to Division II bus B.

i l

l l

l l'

l f Brunswick Unit 2 3.8-37 Amendment No. l l

o Distr ,ution Systems--Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Distribution Systems--Shutdown LCO 3.8.8 The necessary portions of the AC and DC electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS

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

LC0 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC or DC electrical supported required power distribution feature (s) subsystems inoperable. inoperable.

08 A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 2 3.8-38 Amendment No. I

- . _ . _ - . . _ . . . . . . - . - - . . _ . - . - . - _ = . . . .

Distribution Systems-Shutdown

3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations i with a potential for '

draining the reactor vessel. l l

AND l

l A.2.4 Initiate actions to Immediately restore required AC and DC electrical power distribution subsystems to ,

OPERABLE status. ;

AND I A.2.5 Declare associated Immediately l required shutdown l cooling subsystem (s) '

inoperable and not in operation.

I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

, SR 3.8.8.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems.

l i

Brunswick Unit 2 3.8-39 Amendment No. I

AC Sources-0perating B 3.8.1 BASES ACTIONS B.1 (continued)

Required Action B.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with two offsite circuits inoperable due to one Unit 1 B0P circuit path to the downstream 4.16 kV emergency bus being inoperable and the DG associated with the downstream 4.16 kV emergency bus inoperable. Condition B is intended to be used for planned maintenance on the Unit 1 B0P buses and the associated 4.16 kV emergency bus (in order to perform maintenance on the 4.16 kV emergency bus, the associated DG must be rendered inoperable). Redundant required features failures consist of inoperable features i that are associated with an emergency bus redundant to the emergency bus with inoperable offsite circuits and DG.

1 Required Action B.1 reduces the vulnerability to a loss of l function. i The immediate Completion Time for Required Action B.1 is intended to ensure that all redundant required features are OPERABLE, or required features ACTIONS entered, prior to entering Condition B. This Completion Time also allows for an exception to the normai " time zero" for beginning the allowed outage time " clock". In this Required Action, the Completion Time only begins on discovery that both: I

a. Two Unit 1 offsite circuits are inoperable due to one inoperable Unit 1 B0P circuit path to the downstream ,

4.16 kV emergency bus and the DG associated with the I downstream 4.16 kV emergency bus is inoperable; and l

b. A redundant required feature is inoperable.

If, at any time during the existence of this Condition, a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

B.2 The Unit 1 B0P buses 1C and ID can each be supplied from the two Unit 1 offsite circuits (SAT and UAT). In turn, offsite power is supplied from each B0P bus to its downstream 4.16 kV emergency bus via a single circuit. Hence, an l intentional outage of a B0P bus or the circuit path to its associated emergency bus (master / slave breakers and (continued) l Brunswick Unit 2 B 3.8-6 Revision No. l l

i AC Sources-0perating B 3.8.1 BASES ACTIONS M (continued) interconnecting cables) results in the loss of availability i of both offsite circuits to the downstream emergency bus.

The phrase " balance of 4.16 kV emergency bus" as plant statedcircuit path to B in Condition therefers downstream to i the B0P bus and its associated circuit path (master / slave breakers and interconnecting cables) to the downstream 4.16 kV emergency bus.

To ensure highly reliable power sources remain with one Unit 1 balance of plant circuit path to the downstream 4.16 kV emergency bus inoperable and the DG associated with the downstream 4.16 kV emergency bus inoperable, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure of SR 3.8.1.1 acceptance criteria does not result in the Required Action not met. However, if a second circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition E, for two or more offsite circuits inoperable, is entered.

M l This Required Action provides a 7 day time period to perform l planned maintenance on one of these B0P buses and the 1 circuit path to'its associated 4.16 kV emergency bus when l

! Unit 1 is in MODE-4 or 5. During the planned maintenance of the B0P bus, the associated emergency bus and the associated DG, if a condition is discovered on these buses or the DG requiring corrective maintenance, this maintenance nay be performed within the 7 day time period of Required Action B.3. (If Unit 1 is in MODE 1, 2, or 3, then the i Unit 1 ACTIONS of Specification 3.8.1, "AC Sources-Operating," require entry into LC0 3.0.3 for this condition.) The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources and a reasonable time frame for performance of planned maintenance. This is acceptable because maintenance on each B0P bus and the circuit path to its associated emergency bus will increase the reliability of the offsite circuits to the downstream 4.16 kV emergency buses. It should be noted that while in this condition each of the remaining three 4.16 kV l (continued)

Brunswick Unit 2 B 3.8-7 Revision No. l

AC Sources-Operating ,

8 3.8.1 BASES i i

ACTIONS R.J (continued).

emergency buses will have their standby emergency source and two sources of offsite power OPERABLE. If one or both ;

sources of offsite power are lost to an additional 4.16 kV emergency bus then Condition E is entered.

The second Completion Time for Required Action B.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet LC0 3.8.1.a or b. If Condition B is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation could lead to a total of 10 days from initial failure of the LC0 to restoration of the 80P circuit path to the downstream 4.16 kV emergency bus and DG associated with the affected ;

4.16 kV emergency bus. At this. time, a second offsite '

circuit could again become inoperable, the B0P circuit path ,

to the downstream 4.16 kV emergency bus and DG associated 1 with the affected 4.16 kV emergency bus restored OPERABLE, !

and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 13 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a i specified condition after discovery of failure to meet LC0 3.8.1.a or b. This limit is. considered reasonable for situations in which condition B and Condition C or D are entered concurrently. The "AND" connector between the 7 day and 10 day Completion Time means that both Completion Times l apply simultaneously, and the more restrictive must be met.

1 As in Required Action B.1, the second Completion Time allows i for an exception to the normal " time zero" for beginning the allowed outage time " clock". This exception results in establishing the " time zero" at the time that LCO 3.8.1.a or l

. b was initially not met, instead of the time that j Condition B was entered.

l C.1 To ensure a highly reliable power source remains with one

,. offsite circuit inoperable, it is necessary to verify the i L availability of the remaining offsite circuits on a more

( frequent basis. Since the Required Action only specifies t

l (continued)

L Brunswick Unit 2 B 3.8-8 Revision No. I

_ .~- , _ . . _ _

. . .-_ .- _ _ ~ - - - . . _ - . . - . . . ..- -

AC Sources-0perating l B 3.8.1 i BASES l

ACTIONS C.1 (continued) l

" perform," a failure of SR 3.8.1.1 acceptance criteria does !

not result in a Required Action not met. However, if a i second circuit fails SR 3.8.1.1, the second offsite circuit )

is inoperable, and Condition E, for two or more offsite I circuits inoperable, is entered.

C.2 Required Action C.2, which only applies if or e 4.16 kV emergency bus cannot be powered from an offsite source, is intended to provide assurance that an event with a coincident single failure of the associated DG does not result in a complete loss of safety function of critical systems. These features (e.g., system, subsystem, division, component, or device) are designed with redundant safety related 4.16 kV emergency buses. Redundant required feature failures consist of inoperable features associated with an emergency bus redundant to the emergency bus that has no offsite power.

The Completion Time for Required Action C.2 is intended to I allow time for the operator to evaluate and repair any discovered inoperabilities. This Completion Time also allows an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action the Completion Time only begins on discovery that both:

a. A 4.16 kV emergency bus has no offsite power supplying its loads; and

b. A redundant required feature on another emergency bus is inoperable.

If, at any time during the existence of this Condition (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time would

begin to be tracked.

L Discovering no offsite power to one 4.16 kV emergency bus of

, the onsite Class 1E Power Distribution System coincident

! with one or more inoperable required support or supported features, or both, that are associated with any other i

(continued) 3 I

Brunswick Unit 2 B 3.8-9 Revision No. l l

l

AC Sources-0perating B 3.8.1 BASES l

ACTIONS C.2 (continued) I emergency bus that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing l time for restoration before the unit is subjected to l transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class 1E l Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

l C.3 l l

l According to Regulatory Guide 1.93 (Ref. 9), operation may

! continue in Condition C for a period that should not exceed I

! 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the i reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class IE Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period, l The second Completion Time for Required Action C.3 l i establishes a limit on the maximum time allowed for any l combination of required AC power sources to be inoperable l during any single contiguous occurrence of failing to meet LC0 3.8.1.a or b. If Condition C is entered while, for 1 instance, a DG is inoperable, and that DG is subsequently returned OPERABLE, the LC0 may already have been not met for (continued) l Brunswick Unit 2 8 3.8-10 Revision No. I

AC Sources-Operating B 3.8.1 BASES ACTIONS C.3 (continued) I up to 7 days. This situation could lead to a total of 10 days, since initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 7 days (for a total of 17 days) allowed prior to complete I restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LC0 3.8.1.a or b. This limit is considered reasonable for situations in which Conditions C and D are entered concurrently. The "AND" I connector between the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

As in Required Action C.2, the Completion Time allows for an I exception to the normal " time zero" for beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the time LCO 3.8.1.a or b was initially not met, instead of at the time that Condition C was entered. I D1 1 ;

To ensure a highly reliable power source remains with one DG j inoperable, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure to meet SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered.

D.2 Required Action D.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed to be powered from redundant safety related 4.16 kV

! emergency buses (i.e., single division systems are not included). Redundant required feature failures consist of l inoperable features associated with an emergency bus redundant to the emergency bus that has an inoperable DG.

(continued)

Brunswick Unit 2 B 3.8-11 Revision No. I

AC Sources-Operating B 3.8.1 BASES ACTIONS M (continued) l The Completion Time is intended to allow the ' operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

la this Required Action the Completion Time only begins on discovery that both:

o An inoperable DG exists; and

b. A redundant required feature on another emergency bus is inoperable.

If, at any time during the existence of this Condition (one DG inoperable), a required redundant feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering one DG inoperable coincident with one or more inoperable required support or-supported features, or both, that are associated with the OPERABLE DGs results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining.0PERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E i

Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

(continued)

Brunswick Unit 2 B 3.8-12 Revision No. I

AC Sources-Operating B 3.8.1 BASES ACTIONS D.3.1 and 0.3.2 (continued)

Required Action D.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), they are declared inoperable upon discovery, and l

Condition G or I of LC0 3.8.1 is entered, as applicable. I Once the failure is repaired, and the common cause failure no longer exists, Required Action D.3.1 is satisfied. If I the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those DGs.

In the event the inoperable DG is restored to OPERABLE status prior to completing either D.3.1 or D.3.2 (i.e., the I inoperable DG has been restored to OPERABLE status but it has not yet been determined if the cause of the inoperability is common to the other OPERABLE DGs), the CP&L i Corrective Action Program (CAP) will continue to evaluate

! the common cause possibility. This continued evaluation, however, is no longer required under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition D. I According to Generic Letter 84-15 (Ref. 10), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a ,

reasonable time to confirm that the OPERABLE DGs are not 1 affected by the same problem as the inoperable DG.

l

! D.4 l l

The 4.16 kV emergency bus design is sufficient to allow operation to continue in Condition D for a period that ,

should not exceed 7 days. In Condition D, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class IE Distribution System.

The 7 day Completion Time takes into account the capa:ity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA becurring during this period.

(continued) l Brunswick Unit 2 B 3.8-13 Revision No. I I

l'

, _ _ _ . _ _ _ . _ _ _ _ . _ _ _ . ~ _ _ _ . _ _ . _ . _ _ . _ _ . _ _ _ _ _ _ . _ _ _ . _

AC Sources-Operating B 3.8.1 1 i

BASES ACTIONS Q,4_ (continued)

The second Completion Time for Required Action D.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet LC0 3.8.1.a or b. If Condition D is entered while, for I instance,-an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LC0 may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation could lead to a total of 10 days, since initial failure of the LCO, to restore the DG. At this. time, an offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 13 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LCO 3.8.1.a or b. This limit is considered. reasonable for situations in which conditions C and D are entered concurrently. The l "AHQ" connector between the 7 day and 10 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met.

As in Required Action D.2, the Completion Time allows for an I exception to the normal " time zero" for beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the time that LCO 3.8.1.a or b was initially not met, instead of the time that Condition D was entered. l l

1 E.1 and E.2 Required Action E.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with inoperability of two or more offsite circuits. Required Action E.1 reduces the vulnerability to I a loss of function. The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed with one 4.16 kV emergency bus without offsite power (Required I Action C.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is I i that Regulatory Guide 1.93 (Ref. 9) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two offsite circuits inoperable, based upon

the assumption that two complete safety divisions are l OPERABLE. While'this Action allows more than two circuits l

[ (continued) l I

Brunswick Unit 2 B 3.8-14 Revision No. I

AC Sources-0perating B 3.8.1 BASES ACTIONS E.1 and E.2 (continued) I to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two circuits are required by the LCO, and a loss of those two circuits results in a total loss of offsite power to the Class 1E Electrical Power Distribution System. Thus, with the BNP electrical design, a loss of the four offsite circuits results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9). When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are designed with redundant safety related 4.16 kV emergency buses, (i.e., single division systems are not included in the list). Redundant required feature failures consist of any of these features that are inoperable because any inoperability is on an emergency bus redundant to an emergency bus with inoperable offsite circuits.

The Completion Time for Required Action E.1 is intended to I allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both:

a. Two or more offsite circuits are inoperable; and

b. A redundant required feature is inoperable.

If, at any time during the existence of this Condition (any combination of two or more Unit I and 2 offsite circuits inoperable), a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 9), operation may l continue in Condition E for a period that should not exceed l

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite l electrical power system may not have the capability to l

effect a safe shutdown and to mitigate the effects of an i accident; however, the onsite AC sources have not been '

l degraded. This level of degradation generally corresponds j to a total loss of the immediately accessible offsite power l sources.

t (continued)

I v .

l Brunswick Unit 2 8 3.8-15 Revision No. 1 ,

1

. _ . . .. _ _ _ . _ _ _ ._ -_ _ . - . _ _ _ _ _ . . . _ . . ~. _ _ _ _ . _ _ _ . _ _

AC Sources--Operating l

B 3.8.1 BASES i

l j ACTIONS E.1 and E.2 (continued) 1 I f Because of the normally high availability of the offsite i

sources, this level of degradation may appear to be more l severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable. However, two factors tend to decrease the severity of this degradation level:

a. The configuration of the redundant AC electrical power

, system that remains available is not susceptible to a j single bus or switching failure; and

b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With two or more of the offsite circuits inoperable, '

sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of all but one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

According to Regulatory Guide 1.93 (Ref. 9), with the available offsite AC sources two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If all offsite sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted operation

, may continue. If all but one offsite source is restored l within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance

l. with Condition A or C, as applicable. 1 F.1 and F.2 I Pursuant to LC0 3.0.6, the Distribution System--Operating ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore,

the Required Actions of Condition F are modified by a Note l (continued)

\

Brunswick Unit 2 B 3.8-16 Revision No. l 4 _

l AC Sources-0perating B 3.8.1 i

f BASES l

ACTIONS F.1 and F.2 (continued) to indicate that when Condition F is entered with no AC source to any 4.16 kV emergency bus, ACTIONS for LC0 3.8.7,

" Distribution Systems-0perating," must be immediately l

entered. This allows Condition F to provide requirements I for the loss of an offsite circuit and one DG without regard to whether an emergency bus is de-energized. LC0 3.8.7 provides the appropriate restrictions for a de-energized emergency bus.

According to Regulatory Guide 1.93 (Ref. 9), operation may I continue in Condition F for a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In Condition F, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition E (loss of two or more I offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the l low probability of a DBA occurring during this period.

G.1 l With two or more DGs inoperable and an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

l (continued) s l Brunswick Unit 2 B 3.8-17 Revision No. 1 i

AC Sources-0perating B 3.8.1 BASES ACTIONS G.1 (continued) l According to Regulatory Guide 1.93 (Ref. 9), with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . While this Action allows more than two DGs to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two DGs are required by the LCO, and a loss of those two DGs results in a total loss of onsite power to the Class 1E Electrical Power Distribution System.

Thus, with the BNP electrical design, a loss of the four DGs results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9).

H.1 and H.2 l If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LC0 does not apply. To achieve this status, the unit must be l brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

I.1 Condition I corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system may cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LC0 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features, especially those that have a standby function, in accordance with UFSAR Sections 8.2 and 8.3 (Ref. 2). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for (continued)

Brunswick Unit 2 B 3.8-18 Revision No. I

AC Sources-0perating B 3.8.1 BASES SURVEI!. LANCE demonstrating the OPERABILITY of the DGs are consistent with REQUIREMENTS. the recommendations of Safety Guide 9 (Ref. 5), Regulatory (continued) Guide 1.9 (Ref.11), and Regulatory Guide 1.137 (Ref.12),

as addressed in the UFSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable. The minimum steady state output voltage of 3750 V is derived from the recommendations found in Safety Guide 9 (Ref. 5) and bounds the minimum steady state output voltage criteria of 3621 V associated with the 4.16 kV emergency buses analyzed in the AC Auxiliary Electrical Distribution System Study. This value (3621 V) allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 3600 V. It also allows for voltage drops to motors and other equipment down through the 480 V level where minimum operating voltage is also usually specified as 90% of name plate rating. The specified maximum steady state output voltage of 4300 V ensures the maximum operating voltage at the safety related 480 V substations is no more than the maximum rated steady state voltage criteria for t b 480 V motor control centers. The maximum steady state output voltage was determined taking into consideration the voltage drop between the DGs and the 4.16 kV emergency buses and a 5% voltage boost at the 480 V substation transformers.

This maximum steady state output voltage also ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated steady state operating voltage. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Safety Guide 9 (Ref 5).

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained.

The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.

(continued)

Brunswick Unit 2 B 3.8-19 Revision No. I

L l

AC Sources-0perating B 3.8.1 l

l BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 REQUIREMENTS (continued) These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.

To minimize the wear on mov;ng parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note (Note 1 for SR 3.8.1.2 and SR 3.8.1.7) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period.

For the purposes of this testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained.

In order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2 of SR 3.8.1.2.

SR 3.8.1.7 requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The minimum voltage and frequency stated in the SR are those necessary to ensure the DG can accept DBA loading while maintaining acceptable voltage and frequency levels. Stable operation at the ncminal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not dampened by load application. This period may be extended beyond the 10 second acceptance criteria and could be cause for failing the SR. In lieu of a time constraint in the SR, BNP will monitor and trend the actual time to reach steady state operation as a means of ensuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 10 second start requirement supports and is conservative with respect to the assumptions in the design basis LOCA analysis of UFSAR, Section 6.3 (Ref. 6). The 10 second start requirement is (continued) l Brunswick Unit 2 B 3.8-20 Revision No. I

AC Sources-0perating B 3.8.1 1

BASES '

SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 (continued)

REQUIREMENTS not applicable to SR 3.8.1.2 (see Note 2 of SR 3.8.1.2),

when a modified start procedure as described above is used.

If a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies.

To minimize testing of the DGs, Note 3 to SR 3.8.1.2 and l Note 2 to SR 3.8.1.7 allow a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by perfonning the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

The 31 day frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref.11). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 10). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradaticn resulting from testing.

SR 3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing and accepting a load approximately equivalent to the continuous rating of the DGs. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is the generator design limitation which if exceeded could lead to generator instability while in parallel with the offsite circuit. The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY.

The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref.11).

(continued)

Brunswick Unit 2 B 3.8-21 Revision No. l l

AC Sources-0perating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.3 (continued)

REQUIREMENTS Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading so that mechanical stress and wear on the diesel engine are minimized.

Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients outside the range normally used during the performance of this Surveillance do not invalidate the test.

Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.

Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

To minimize testing of the DGs, Note 5 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.4 This SR provides verification that the level of fuel oil in the engine mounted tank is slightly below the level at which the backup fuel oil transfer pump automatically starts. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for approximately 30 minutes of DG operation at rated load. This SR may be satisfied by verifying the absence of the associated low level alarm.

The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators would be aware of any large l

uses of fuel oil during this period.

(continued) l Brunswick Unit 2 B 3.8-22 Revision No. I

( l l

AC Sources-0perating B 3.8.1 l '

BASES I l

i SURVEILLANCE SR 3.8.1.5 REQUIREMENTS l

(continued) Microbiological fouling is a major cause of fuel oil !

l degradation. There are numerous bacteria that can grow in !

! fuel oil and cause fouling, but all must have a water l environment in order to survive. Removal of water from the I engine mounted tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling.

In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system.

The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 12). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.

Removal of accumulated water may be accomplished by draining a portion of fuel oil from the engine mounted fuel oil tank l to the day fuel oil storage tank and. draining any I accumulated water from the day fuel oil storage tank in l accordance with SR 3.8.3.3. The draining evolution will continue until accumulated water is verified to be removed from the engine mounted fuel oil tank.

l l

SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for fuel transfer systems are OPERABLE.

(continued) l Brunswick Unit 2 B 3.8-23 Revision No. I i

i AC Sources-0perating B 3.8.1 l

BASES SURVEILLANCE SR 3.8.1.6 (continued)

REQUIREMENTS The Frequency for this SR is consistent with the Frequency i for testing the DGs in SR 3.8.1.3. DG operation for

! SR 3.8.1.3 is normally long enough that fuel oil level in the engine mounted tank will be reduced to the point where the fuel oil transfer pump automatically starts to restore fuel oil level in the engine mounted tank.

SR 3.8.1.8 Transfer of each 4.16 kV emergency bus power supply from the normal circuit to the preferred offsite circuit and from the preferred offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the offsite circuit distribution network to power the shutdown loads. In lieu of actually initiating an automatic circuit transfer, i testing that adequately shows the capability of the transfer '

is acceptable. The automatic transfer testing may include any series of sequential, overlapping, or total steps so that the entire transfer sequence is verified. The 24 month Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance, and is intended to be i consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed on the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by three Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of SR 3.8.1.8.a, verification of automatic transfer capability of the unit power supply from the normal circuit to the preferred offsite circuit, could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. Note 1 is not applicable to SR 3.8.1.8.b, verification of manual transfer of the unit power supply from the preferred offsite circuit to the alternate offsite circuit, since this evolution does not cause perturbations of the electrical distribution systems.

Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, both units' offsite circuits are required to be OPERABLE to (continued) l i

l Brunswick Unit 2 B 3.8-24 Revision No. I

- - ~ ,

I l

AC Sources-0perating B 3.8.1 BASES l

l l SURVEILLANCE SR 3.8.1.8 (continued)

REQUIREMENTS supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need for a shutdown of both units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for the Unit 2 offsite circuits when Unit 2 is in MODE 1 or 2. During the performance of this Surveillance with Unit 2 not in MODE 1 or 2 and with Unit 1 in MODE 1, 2, or 3; .the applicable ACTIONS of the Unit 1 and Unit 2 Technical Specifications must be entered if a Unit 2 offsite circuit is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. As stated in Note 2, automatic transfer capability to the SAT is not required to be met when the associated 4.16 kV l

emergency buses are powered from the preferred offsite circuit. This is acceptable since the automatic transfer capability function has been satisfied in this condition.

To minimize testing, Note 3 allows a single test (instead of i two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on a single unit. If an offsite circuit fails one of the Surve111ances, the offsite circuit should be considered inoperable for both units.

SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG capability to reject the largest single load without tripping. The largest single load for each DG is a core spray pump (1250 hp). This Surveillance may be accomplished by: I

a. Tripping the DG output breaker with the DG carrying )

greater than or equal to its associated core spray I pump while paralleled to offsite power, or while i solely supplying the bus; or (continued) l Brunswick-Unit 2 B 3.8-25 Revision No. l

1' l AC Sources-0perating

[ B 3.8.1 l

l BASES SURVEILLANCE SR 3.8.1.9 (continued)

REQUIREMENTS

!~ b. Tripping its associated core spray pump with the DG l solely supplying the bus.

The load rejection test is-acceptable if the increase in l diesel speed does not exceed the overspeed trip setpoint.

l The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref.11).

This SR is modified by three Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERABLE

to supply power to these systems when either one or both l units are in MODE 1, 2, or 3. In order to reduce the consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need to shutdown both units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for DG 3 and DG 4 when Unit 2 is in MODE 1, 2, or 3. During the ,

performance of this Surveillance with Unit 2 not in MODE 1, '

2, or 3 and with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit 1 and Unit 2 Technical Specifications must be entered if DG 3 or DG 4 is rendered inoperable by i the performance of this Surveillance. Credit may be taken ;

l for unplanned events that satisfy this SR. In order to '

ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factor s 0.9. This power ,

l factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. To minimize testing of the DGs, Note 3 allows a single test '

(instead of two tests, one for each unit) to satisfy the l requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surve111ances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly

, related to only one unit.

(continued)

Brunswick Unit 2 B 3.8-26 Revision No. l l

L . _ _ _ , _ _ __ _ _ _ __

i AC Sources-0perating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 REQUIREMENTS l (continued) Consistent with Regulatory Guide 1.9 (Ref.11), paragraph l C.2.2.12, this Surveillance demonstrates that DG

)

non-critical protective functions (e.g., high jacket water temperature) are bypassed on an ECCS initiation test signal and critical protective functions (engine overspeed,

' generator differential overcurrent, low lubricating oil pressure, reverse power, loss of field, and phase overcurrent-voltage restrained) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. .This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG, The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

SR 3.8.1.11 Brunswick Nuclear Plant performs a 60 minute run greater than or equal to the continuous rating (3500 kW) which bounds the maximum expected post-accident DG loading. The DG starts for this Surveillance can be performed either from (continued) l Brunswick Unit 2 B 3.8-27 Revision No. I

AC Sources-0perating l

B 3.8.1

\

BASES l

l SURVEILLANCE SR 3.8.1.11 (continued)

REQUIREMENTS standby or hot conditions. The provisions for prelube and warmup, discussed in the Bases for SR 3.8.1.2, and for gradual loading, discussed in the Bases for SR 3.8.1.3, are applicable to this SR.

In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor

s 0.9. This power factor is chosen to be representative of the actual design basis inducti n loading that the DG could experience. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY.

The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This Surveillance has been modified by two Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. To minimize testing of the DGs, Note 2 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

I SR 3.8.1.12 l Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.13, demonstration of the test mode override feature ensures that the DG availability under accident conditions i

is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation (continued)

Brunswick Unit 2 B 3.8-28 Revision No. I

AC Sources-0perating B 3.8.1 i

BASES l

l SURVEILLANCE SR 3.8.1.12 (continued)

REQUIREMENTS l

signal is received during operation in the test mode.

Ready-to-load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

These provisions for automatic switchover are required by IEEE-308 (Ref.13), paragraph 6.2.4(6).

In lieu of actually returning the DG to ready-to-load status, testing that adequately shows the capability of the DG to perform this function is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire sequence is verified.

The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. 11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.

1 SR 3.8.1.13 l Under accident conditions loads are sequentially connected to the bus by the automatic load sequence time delay relays. !

The sequencing logic controls the permissive and starting !

signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated.

Reference 4 provides a summary of the automatic loading of ESF buses.

(continued)

Brunswick Unit 2 B 3.8-29 Revision No. I

AC Sources-Operating 1 B 3.8.1 1 BASES SURVEILLANCE SR 3.8.1.13 (continued)

REQUIREMENTS The Frequency of 24 months is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs, and associated load sequence relays, are required to be OPERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce potential consequences associated with removing a required offsite circuit from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to perform this Surveillance, the Note only precludes satisfying this Surveillance Requirement for the load sequence relays associated with DG 3 and DG 4 when Unit 2 is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit 2 not in MODE 1, 2, or 3 and with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit 1 and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 3, or DG 4 is rendered inoperable by the performance of this Surveillance.

Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.14 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

This Surveillance demonstrates DG operation during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. This test verifies all actions encountered from the event, including shedding of the (continued)

Brunswick Unit 2 8 3.8-30 Revision No. 1

. AC Sources-0perating l B 3.8.1 BASET.

SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates l the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

The 10.5 second time period, which is allowed for the DG to auto-start and connect to its respective emergency bus, is conservatively derived from requirements of the accident analysis for responding to a design basis large break LOCA.

The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are not capable of being operated at full flow, or RHR systems performing c decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with procedural guidance. The reason for Note 2 l is that performing the Surveillance would remove a required I- offsite circuit from service, perturb the electrical (continued)

L Brunswick Unit 2 B 3.8-31 Revision No. l y --& 4 cr- r e - e

l AC Sources-Operating l B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the potential consequences associated with removing a required offsite circuit from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to perform this Surveillance, Note 2 only precludes satisfying this Surveillance Requirement for DG 3 and DG 4 when Unit 2 is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit 2 not in MODE 1, 2, or 3 and with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 3, DG 4, or other supported Technical Specification equipment is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR.

1 REFERENCES 1. UFSAR, Section 8.3.1.2.

2. UFSAR, Sections 8.2 and 8.3.

3. NRC Diagnostic Evaluation Team Report for Brunswick l

Steam Electric Plant dated August 2, 1989, from J.M. Taylor (NRC) to S.H. Smith, Jr. (CP&L).

! 4. UFSAR, Table 8.3.1-6.

l 5. Safety Guide 9.

I

6. UFSAR, Chapter 6.

7. UFSAR, Chapter 15.

8. 10 CFR 50.36(c)(2)(ii).

9. Regulatory Guide 1.93, December 1974.

10. Generic Letter 84-15.

(continued) l Brunswick Unit 2 B 3.8-32 Revision No. I l-

' AC Sources-0perating B 3.8.1 BASES i

REFERENCES 11. Regulatory Guide 1.9, July 1993, Revision 3.

(continued)

12. Regulatory Guide 1.137, January 1978.

13. IEEE Standard 308, I

l l

e i

Brunswick Unit 2 8 3.8-33 Revision No. 1

1 Distribution Systems-0perating B 3.8.7 l

l B 3.8 ELECTRICAL POWER SYSTEMS l

B 3.8.7 Distribution Systems-0perating BASES BACKGROUND The onsite Class 1E AC and DC electrical power distribution system is divided into redundant and independent AC and DC electrical power distribution subsystems.

The Class 1E AC electrical distribution system is divided into four load groups. Each load group consists of a primary emergency bus, its downstream secondary emergency bus,120 VAC vital bus, and transformers and interconnecting cables. The buses associated with each of the four load groups are defined as follows:

Load group El consists of 4.16 kV bus El, 480 V bus E5, and 120 VAC vital bus 1E5.

Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus 1E6.

Load group E3 consists of 4.16 kV bus E3, 480 V bus E7, and 120 VAC vital bus 2E7.

Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8.

The El and E2 load groups are supplied from Unit 1 balance of plant (B0P) buses and primarily serve Unit I loads. The E3 and E4 load groups are supplied from Unit 2 B0P buses and primarily serve Unit 2 loads. In some instances loads associated with one unit are actually supplied from the opposite unit's load group buses.

Each primary emergency. bus (4.16 kV emergency bus) has access to two offsite sources of power via a common circuit path from its associated upstream B0P bus (master / slave breakers and interconnecting cables). In addition, each 4.16.kV emergency bus can be provided power from an onsite diesel generator (0G) source. The upstream B0P bus associated with each 4.16 kV emergency bus is normally connected to the main generator output via the unit auxiliary transformer. During a loss of the normal power source to the 4.16 kV B0P bus, the preferred source supply breaker attempts to close. If all offsite sources are (continued)

Brunswick Unit 2 B 3.8-71 Revision No. l

Distribution Systems-Operating 1 B 3.8.7 i

l BASES i

l 1

BACKGROUND unavailable, the affected 4.16 kV emergency bus is isolated !

(Continued) from its associated upstream 4.16 kV B0P bus and the onsite l emergency DG will supply power to the 4.16 kV emergency bus.

Control power for each 4.16 kV emergency bus is supplied from a Class 1E battery with manual transfer capability to another Class lE battery. Additional descriptions of this system may be found in the Bases for Specification 3.8.1, "AC Sources-Operating," and the Bases for Specification 3.8.4, "DC Sources-0perating".

The secondary plant distribution system includes 480 VAC l emergency buses E5, E6, E7, and E8 and associated motor control centers (MCCs), transformers, and interconnecting cabl es. Secondary emergency buses E5, E6, E7, and E8 are supplied from primary emergency buses El, E2, E3, and E4, respectively. Control power for each 480 VAC emergency bus is supplied from a Class " 'attery with manual transfer capability to another Clast ;E battery. Additional descriptions of this system may be found in the Bases for ;

t Specification 3.8.4, "DC Sources-Operating".

The 120 VAC vital buses IES, IE6, 2E7, and 2E8 are arranged i in four load groups and are powered from secondary emergency I buses E5, E6, E7, and E8, respectively.

There are two independent 125/250 VDC actrical power distribution subsystems.

The list of required distribution buses is presented in Table B 3.8.7-1.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC and DC electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, " Power Distribution Limits"; Section 3.5, " Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System"; and Section 3.6, " Containment Systems."

(continued)

Brunswick Unit 2 B 3.8-72 Revision No. I i

l l

Distribution Systems-0perating B 3.8.7 BASES

. APPLICABLE The OPERABILITY of the AC and DC electrical power

! SAFETY ANALYSES distribution subsystems is consistent with the initial i (continued) assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power; and

b. A worst case single failure.

The AC and DC electrical power distribution system satisfies l Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

LC0 The required electrical power distribution subsystems listed in Table B 3.8.7-1 ensure the availability of AC and DC 4 electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (A00) or a postulated DBA. The Unit 2 AC and DC electrical power distribution subsystems are required to be OPERABLE. In addition, since some components required by Unit 2 receive power through Unit 1 DC electrical power distribution subsystems (e.g.,

control power for two of the four 4.16 kV emergency buses, two of the four 480 VAC emergency buses, and for two of the DGs, and two of four engineered safeguard system (ESS) panels), the Unit 1 DC electrical power distribution subsystems needed to support the required equipment must also be OPERABLE. As stated in Table B 3.8.7-1, each division of the AC and DC electrical power distribution systems is a subsystem.

Maintaining the Division I and II AC and DC electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated.

Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

The AC electrical power distribution subsystems require the associated buses and electrical circuits to be energized to their proper voltages. The DC electrical power distribution subsystems require the associated buses to be energized to their proper voltage from either the associated batteries or chargers.

(continued) l Brunswick Unit 2 B 3.8-73 Revision No. I

t Distribution Systems-0perating B 3.8.7 BASES LC0 Based on the number of safety significant electrical loads (continued) associated with each bus listed in Table B 3.8.7-1, if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LC0 3.8.7 is required. Other buses, such as MCCs and distribution panels, which help comprise l the AC and DC distribution systems are not listed in Table B 3.8.7-1. The loss of electrical loads associated with these buses may not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., a breaker supplying a single MCC fails open), the individual loads on the bus must be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., loss of a 4.16 kV emergency bus, which results in de-energization of all buses powered from the 4.16 kV emergency bus), then although the individual loads are still considered inoperable, the Conditions and Required Actions of the LC0 for the individual loads are not required to be entered, since ;

LC0 3.0.6 allows this exception (i.e., the loads are I inoperable due to the inoperability of a support system I governed by a Technical Specification; the 4.16 kV emergency '

bus).

In addition, tie breakers and transfer switches between I redundant safety related AC and DC power distribution subsystems, if they exist, must be open. This includes control power transfer switches associated with the 4.16 kV '

and 480 V emergency buses and transfer switches associated with the ESS and DG panels. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, which could cause the failure of a redundant subsystem and a loss of essential safety function (s). If any tie breakers are closed or transfer switches aligned to the alternate supply, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related, redundant electrical power distribution subsystems. It does not, however, preclude redundant Class IE 4.16 kV emergency buses from being powered from the same offsite circuit.

(continued) f Brunswick Unit 2 B 3.8-74 Revision No. I

Distribution Systems-Operating B 3.8.7 BASES (continued)

APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or honormal transients; and

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

Electrical power distribution subsystem requirements for MODES 4 and 5 and other conditions in which AC and DC electrical power distribution subsystems are required are covered in the Bases for LC0 3.8.8, " Distribution Systems-Shutdown. "

ACTIONS A.1 With one AC electrical power distribution subsystem inoperable due to either inoperable load group El bus (es),

l or inoperable load group E2 bus (es), the remaining AC electrical power distribution load groups are capable of supporting the minimum safety functions necessary to shut down the operating reactor and maintain both reactors in a safe condition, assuming no single failure in the remaining AC electrical power distribution load groups, when Unit 1 is in MODE 4 or 5. (If Unit 1 is in MODE 1, 2, or 3, then the Unit 1 ACTIONS of Specification 3.8.7, " Distribution Systems-0perating," require restoration of the associated AC electrical power distribution subsystem within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of

, the inoperability.)- The overall reliability is reduced in L Condition A, because a single failure in a remaining load group could result in the minimum required ESF functions not l being supported. As a result, Required Action A.1 limits the time period to perform planned maintenance on a Unit I load group to 7 days. This is acceptable based on the following:

i a. The other unit's load group buses are not as critical to the operating unit (fewer operating unit loads) as the operating unit's load group buses.

b. Performing maintenance on these components will increase the reliability of the Class lE AC Electrical

, Power Distribution System.

l- (continued)

! Brunswick Unit 2 B 3.8-75 Revision No. l l

i Distribution Systems--Operating B 3.8.7 BASES l

j ACTIONS A.1 (continued)

c. The 7 day Completion Time provides a reasonable time frame for performance of planned maintenance.

( During the planned maintenance of the load group buses, if a condition is discovered on these buses requiring corrective maintenance, this maintenance may be performed within the 7 day Completion Time of Required Action A.I.

i The Class 1E AC Electrical Power Distribution System is divided into four load groups. Each load group consists of a primary emergency bus, its downstream secondary emergency bus,120 VAC vital bus, and transformers and interconnecting cables. The buses associated with each of the four load groups are defined as follows:

Load group El consists of 4.16 kV bus El, 480 V bus E5, and 120 VAC vital bus IES.

Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus lE6.

Load group E3 consists of 4.16 kV bus E3, 480 V !

bus E7, and 120 VAC vital bus 2E7. l Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8.

The second Completion Time for Required Action A.1 l establishes a limit on the maximum time allowed for any '

combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, an AC bus in a load group in a different i division is inoperable and subsequently returned OPERABLE, this LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months (since initial failure to meet the LC0) to restore the AC Electrical Power Distribution System. At this time an AC bus in a load group in a different division could again become inoperable, and the load group removed under Condition A could be restored OPERABLE. This could continue indefinitely.

l (continued) l Brunswick Unit 2 B 3.8-76 Revision No. I

l Distribution Systems-Operating B 3.8.7 BASES ACTIONS A.1 (continued)

This Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock".

This results in establishing the " time zero" at the time this LC0 was initially not met, instead of at the time i Condition A was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time is an i acceptable limitation on this potential to fail to meet the LC0 indefinitely.

l If while in Condition A, emergency buses associated with another load group become inoperable (e.g., buses in load groups El and E2 are concurrently inoperable), Condition B and F must be entered, as appropriate. .

B.1 l With one or more required AC buses or distribution panels in one division inoperable for reasons other than Condition A, I the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining AC electrical power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Condition B worst scenario is one division without AC l power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit and restoring power to the affected division. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

(continued) l' i

l l

Brunswick Unit 2 B 3.8-77 Revision No. I

Distribution Systems-Operating B 3.8.7 l 1 BASES ACTIONS Bd (continued) l l a. The potential for decreased safety if the unit

! operators' attention is diverted from the evaluations and actions necessary to restore power.to the affected division to the actions associated with taking the unit to shutdown within this time limit,

b. The low potential for an event in conjunction with a single failure of a redundant component in the ;

division with AC power. (The redundant component is !

verified OPERABLE in accordance with Specification 5.5.11, " Safety function Determination Program (SFDP).")

The second Completion Time for Required Action B.1 l establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be !

inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, I i for instance, a DC bus is inoperable and subsequently returned OPERABLE, this LC0 may already have been not met for up to 7 days. This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months , since initial failure to meet the LCO, to restore the AC electrical power distribution system.

At this time a DC bus could again become inoperable, and the AC electrical power distribution system could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

'This results in establishing the " time zero" at the time this LC0 was initially not met, instead of at the time Condition B was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time is an I acceptable _ limitation on this potential to fail to meet the LC0 indefinitely.

C.I. C.2. C.3 and C.4 l With one or more DC electrical power distribution subsystems inoperable due to loss of normal DC source, the remaining DC electrical power distribution subsystem (s) are capable of supporting the minimum safety functions necessary to

~

shutdown the reactor and maintain it in a safe shutdown condition, provided safety-function is not lost and assuming no single failure. However, the overall reliability is

, (continued)

I Brunswick Unit 2 B 3.8-78 Revision No. l

f Distribution Systems-0perating B 3.8.7 l

BASES l

l ACTIONS C.I. C.2. C.3 and C.4 (continued) l l reduced because a single failure in the DC electrical power distribution system could result in a loss of two of four AC electrical load groups and the minimum required ESF

, functions not being supported. Therefore, action must be

! immediately initiated to transfer the DC electrical power distribution system to its alternate source and the affected supported equipment immediately declared inoperable. Upon completion of the transfer of the affected supported equipment's DC electrical power distribution subsystem to its OPERABLE alternate DC source, the affected supported equipment may be declared OPERABLE again. The ESS logic cabinets transfer automatically upon loss of the normal source. For an ESS logic cabinet, verification that the automatic transfer has occurred and alternate power is available to the ESS logic cabinet will satisfy Required Action C.2. By allowance of the option to declare affected I supported equipment inoperable with associated DC electrical power distribution subsystems inoperable due to loss of normal DC source, more conservative restrictions are ,

implemented in accordance with the affected system LCOs' !

ACTIONS. When any control power transfer switch associated with the 4.16 kV and 480 V emergency buses or any transfer switch associated with the ESS and DG panels is transferred to the~ alternate source, a single failure in the DC system could render two of four AC electrical load groups inoperable. Therefore, to prevent indefinite operation in this degraded condition, power from the normal DC source must be restored in 7 days.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention.

Required Actions C.1 and C.2 should be completed as quickly l l as possible. The 7 day Completion Time of Required l Action C.4 is considered to be acceptable due to the low I potential for an event in conjunction with a single failure of a redundant component and is consistent with the allowed Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-Operating."

The second Completion Time for Required Action C.4 I establishes a limit on the maximum time allowed for any combination of required electrical power distribution l subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is I (continued)

Brunswick Unit 2 B 3.8-79 Revision No. I

Distribution Systems-0perating B 3.8.7 BASES 1

1 ACTIONS C.1. C.2. C.3 and C.4 (continued) I entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months , since initial failure to

! meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

This allowance results in establishing the " time zero" at the time the LC0 was initially not met, instead of at the time Condition C was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time I is an acceptable limitation on this potential of failing to l meet the LCO indefinitely.

l D.1 l With one DC electrical power distribution subsystem inoperable for reasons other than Condition C, the remaining I DC electrical power distribution subsystem is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC electrical power distribution subsystem must be restored to OPERABLE status within 7 days by powering the bus from the associated batteries or chargers.

Condition D represents one division without adequate DC l power, potentially with both the battery (s) significantly degraded and the associated charger (s) nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of

, power to the remaining divisions, and restoring power to the

, affected division.

l l (continued)

Brunswick Unit 2 B 3.8-80 Revision No. I

l

! Distribution Systems-Operating B 3.8.7 l l BASES ACTIONS D.1 (continued) l The 7 day Completion Time is consistent with the allowed Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-0perating". Taking exception to LC0 3.0.2 for i

components without adequate DC power, which would have l Required Action Completion Times shorter than 7 days, is acceptable because of:

a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue;

b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division; l

, c. The low potential for an event in conjunction with a single failure of a redundant component.

The second Completion Time for Required Action D.1 l establishes a limit on the maximum time allowed for any combination of required electrical power distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition D is I entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months , since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal

" time zero" for beginning the allowed outage time " clock."

This allowance results in establishing the " time zero" at i the time the LC0 was initially not met, instead of at the l l

time Condition D was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Completion Time 1 I is an acceptable limitation on this potential of failing to meet the LC0 indefinitely.

(continued)

Brunswick Unit 2 B 3.8-81 Revision No. l l l

l /

Distribution Systems-0perating B 3.8.7 BASES l

ACTIONS E.1 and E.2 l

! (continued)

If the inoperable electrical power distribution subsystem (s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1 Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no ,

additional time is justified for continued operation. '

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. This includes verifying that distribution bus tie breakers are open and control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switchi.s associated with the ESS and DG panels are aligned to their normal DC sources. The correct breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained, and power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. This may be performed by verification of absence of low voltage alarms or by verifying a load powered from the bus is operating. The (continued) l l l

l !

Brunswick Unit 2 B 3.8-82 Revision No. I

_]

l 1

Distribution Systems-Operating B 3.8.7 BASES SURVEILLANCE SR 3.8.7.1 (continued)

REQUIREMENTS 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

l SR 3.8.7.2 This Surveillance verifies that no combination of more than two power conversion modules (consisting of either two .

lighting inverters or one lighting inverter and one plant uninterruptible power supply unit) are aligned to Division II (bus B). Two power conversion modules aligned to Division II (bus B) was an initial assumption in the DC i battery load study. Limiting two power conversion modules to be aligned to Division 11 ensures the associated batteries will supply DC power to safety related equipment during a design basis event. The 7 day Frequency takes into account the redundant capability of the DC electrical power distribution subsystems and indications available in the l

control room to alert the operator of power conversion module misalignment.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

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

4 l

i l

I !

1 Brunswick Unit 2 B 3.8-83 Revision No. I

/

Distribution Systems-0perating B 3.8.7 Table B 3.8.7-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems TYPE VOLTAGE DIVISION I(a) DIVISION II(a)

AC emergency 4160 V Emergency Buses Emergency Buses buses El, E3 E2, E4 480 V Emergency Buses Emergency Buses ES, E7 E6, E8 AC vital buses 120 V Distribution Distribution Panels Panels IES, 2E7 IE6, 2E8 DC buses 250 V Switchboard 2A Switchboard 2B 125 V ESS logic ESS logic Cabinets Cabinets H58, H60 H59, H61 125 V DG Panels DG Panels DG-1, DG-3 DG-2, DG-4 D control 125 V 4.16 kV Switchgear 4.16 kV Switchgear pwer buses El, E3 E2, E4 ,

125 V 480 V 480 V Switchgear Switchgear E5, E7 E6, E8 (a) Each division of the AC and DC electrical power distribution systems is a subsystem.

Brunswick Unit 2 B 3.8-84 Revision No. I

v t e Letter Sequence Other
TAC:M97243, (Open) TAC:M97244, (Open)
Initiation Request, Request Acceptance... Administration Questions Answers Results Approval... Other: BSEP-98-0131, Requests Correction to Amends 203 & 233 Issued on 980605 to Bsep,Units 1 & 2 Re Conversion from Current TS to Improved Ts.Corrected TS Page 3.3-56,encl, BSEP-98-0172, Forwards Addl Info Re Balance of Plant/Emergency Bus AOT Extension,Discussion of Changes to ITS 3.8.1,L.15 & 3.8.7, L.2 and Units 1 & 2 ITS Section 3.8 & Bases, ML20148U296, ML20153D879, ML20217E832
MONTHYEAR1998-04-21 [Table View]

ML20153D879

Text

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