Text

Proposed Rev D to Improved Ts,Incorporates New ITS 3.6.3.2, Containment Atmospheric Dilution Sys
	ML20217J917
Person / Time
Site:	Brunswick
Issue date:	04/24/1998
From:	; CAROLINA POWER & LIGHT CO.
To:	;
Shared Package
ML20217J878	List: BSEP-98-0095, Suppl Application for Amends to Licenses DPR-62 & DPR-71, Converting Current TS to Improved Ts,As Contained in Rev 1 of NUREG-1433; ML20217J917;
References
	NUDOCS 9804300348
	Download: ML20217J917 (114)
	v • d • e

l TSC 96TSB02 REVISION D

'O IaSERT aa0 REa0 VAL iaSTRoCTI0a5 The following instructions are provided for use in updating the BNP ITS submittal (TSC 96TSB02). To facilitate the update process, the instructions have been divided by BNP ITS submittal volume number and associated divider tabs. To facilitate incorporation of the Revision D package into the ITS j submittal, colored pages have been inserted between the material for each tab section. After incorporation of the Revision D pages into the BNP ITS submittal, the colored pages should be discarded.

VOLUNE 1 - SPLIT REPORT / RELOCATION MATRIX TAB - SPLIT REPORT REMOVE PAGE(S) INSERT PAGE(S)

SUMMARY

DISPOSITION MATRIX

SUMMARY

DISPOSITION MATRIX FOR BNP page 9 FOR BNP page 9 APPENDIX A pages 20 and 21 APPENDIX A pages 20 and 21 TAB - RELOCATED MATRIX REMOVE PAGE(S) INSERT PAGE(S) l RELOCATED ITEMS MATRIX RELOCATED ITEMS MATRIX page 12 of 19 thru page 19 page 12 of 19 thru page 19 of 19 of 19 I i

VOLUME 9 - SECTION 3.6 TAB - SECTION 3.6 I TAB - U1 ITS REMOVE PAGE(S) INSERT PAGE(S) 3.6-27 thru 3.6-34 3.6-27 thru 3.6-36 00 4

$0 i

Page 1 of 4 J

r TSC 96TSB02 REVISION D INSERT AND REMOVAL INSTRUCTIONS VOLUME 9 - SECTION 3.6 (continued)

TAB - SECTION 3.6 TAB - U1 ITS BASES REMOVE PAGE(S) INSERT PAGE(S)

B 3.6-60 thru 8 3.6-79 B 3.6-60 thru 8 3.6-85 TAB - U2 ITS REMOVE PAGE(S) INSERT PAGE(S) 3.6-27 thru 3.6-34 3.6-27 thru 3.6-36 TAB - U2 ITS BASES REMOVE PAGE(S) INSERT PAGE(S)

B 3.6-60 thru B 3.6-79 B 3.6-60 thru B 3.6-85 TAB - CTS / DOCS REMOVE PAGE(S) INSERT PAGE(S)

New Pages: Spec. 3.6.3.2 Markup pages 1 of 2 and 2 of 2 <

behind ITS 3.6.3.1 Discussion of Change (DOC) page 2 New Pages: ITS 3.6.3.2 DOC page 1 thru page 5 behind Spec. 3.6.3.2 Markup page 2 of 2 Current Spec. 3/4.6.6.2 Markup ----- '

pages I of 2 and 2 of 2 CTS 3/4.6.6.2 DOC page 1 thru -----

page 3 Page 2 of 4 J

s TSC 96TS802 REVISION D INSERT AND REMOVAL INSTRUCTIONS VOLUNE 10 - SECTION 3.6 TA8 - SECTION 3.6 TA8 - ISTS/JFDs REMOVE PAGE(S) INSERT PAGE(S)

Markup page 3.6-45 and Markup Markup page 3.6-45 and Markup page 3.6-46 page 3.6-46 Justification for Deviation (JFD) JFD Section 3.6 pages 6 and 7 Section 3.6 pages 6 and 7 TA8 - ISTS BASES /JFDs REMOVE PAGE(S) INSERT PAGE(S)

Markup page B 3.6-B9 Markup page B 3.6-89 Os Markup pages B 3.6-91 and Markup pages B 3.6-91 and B 3.6-92 B 3.6-92 New page: Insert B 3.6.3.2-1 behind Markup page B 3.6-92 Markup page B 3.6-93 Markup page B 3.6-93 New page: Insert B 3.6.3.2-2 behind Markup page B 3.6-93 Markup pages B 3.6-94 thru Markup pages B 3.6-94 thru 8 3.6-96 B 3.6-96 New page: Insert B 3.6.3.2-3 behind Markup page B 3.6-96 1

l Page 3 of 4

i TSC 96TS802 REVISION D O* INSERT AND REMOVAL INSTRUCTIONS VOLUNE 10 - SECTION 3.6 (continued)

TAB - SECTION 3.6 ,

TA8 - NSHEs REMOVE PAGE(S) INSERT PAGE(S)

Generic No Significant Hazards Generic No Significant Hazards Evaluation pages 6 and 7 Evaluation pages 6 and 7 i I

New Pages: ITS Section 3.6.3.2 L.1 CHANGE page 1 and 2 (behind ITS Section 3.6.3.1 L.1 CHANGE page 2)

New Page: ITS Section 3.6.3.2 ,

L.2 CHANGE page 3 (behind ITS l Section 3.6.3.2 L.1 CHANGE I page 2) i l

l l

(}

i

!3 v

Page 4 of 4

1 ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/L1 CENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS - REVISION D i

REVISION D L

- 0 y d e ne r e t

ne e n

. f S a is i

e e

s e

o d e

g y y r o

i f

o dr ep r u s n x a .

s m

t l a

e i o m d ug sot t c a e i O

i s

e sn itn e

nd en v n t h r n v rym e n t p i e

c e u a.

i si da n ar orn i yl q i

m i

w , t R e

u u t ai cd rb e a e es q ss tda ce ay aa s dlr re e

in e

ent ron dt np n s eao l s n eco e o i ntf sb n s oy nl oe c ioe ea peC ee cc e,c n ti o

c c e ib te os y nd a e o str e br ea "u

o e n ar r ,r is h

t i

t oeh chT lv e re elP i so a t r p

. I S

h t

eh pt ken eii e

st et e r n et h t t eA . vt U e o etr on ss s n hCs a L t s e rnp de ie g e wOl 1 C i n rr be ls c Le f erm i

X E

m o c

eu meg re be t n t v yo

/

i ks es ti ae i o. aaet r N

l A ee ufn ufe ie st tt se m cA h C tg on go I

O t

o B D

rr bp cil adl

-n fo.

er o nO ne ei t eL hiv. ts S

U s v eha fct se s

g cwid as L n i t

at tt erc o n ts oe io t ya uose Cu x slon c C

N i o

i m ue cw i nusd hetmr md c

o og n dopa lli ds I t l ay d sl teo le i ni ei efxt ad c vr teu sr t A rw it en R n o d tro sei ei B uo e i Al O u t r upc tev ms D sl mvwa l F f et b it n if nl ilom eu e

n o dim rva et mee tf a eo lol pf e n o S ir f ves y I

5 r i t ei hl . oih l g. o sebi Tr A

t t c c y ce ttt t ah is t ie ns ts i osy 7f o

3 o n ag, ng ht l ot ti ws se ntnt o

s u nti eot eno im oa nv o ii 9.1 f o isg -

r rtn e mit rr wi l le ll il oe idmr teag 11 t s sie ltm iue n oe t atee ee e

o e sst oin ess od fr ce rert dg p v eyn omi tna in nv tt n i a l

o rti po pia lt nee ta o a ne ui nuni uP n v pnt n n cye l

rt os fs eto G io o

o. csit ,

P uen ooo.

N i n s e itcy y br en pe td ml notn yA a ep opae r B sA o sC i lCn Am s s d yi t

rso ait omr re tx c rm ox et se y stn ti s eO t lOi eerr ds ri pi nini ad n R rL a eLa rmag n yr ee os Sw e ea o O g A o l w t yen pume sit oto pt - o gtct ue yann gp l n i w8 sI cei sn Tf Dl t F SD rho wsrn Dtc S a pi enr eo Sop Dc Gf Ae xhoo ep c

a So Cb 0tcc RA i X f I i R /N u c DO o e T EI I p

A NRRS S M IEOU ATFL 3 3 3 3 3 3 3 3 2 l

C - - 3- a TI - - - -

N s s s s s s c OI ER N s s s s O RC I e e e e e e e e e e i

n .

Y Y Y Y Y Y Y Y Y Y h c 9 -

T e I T S E R l O S a P u S WIU 3 3 6 5 1 2 3 2 1 d E 1 i I NW 2 1 1 1 4 4 4 3 3 3 v D T S

6 6 6 6 i

d 6 6 6 6 6 3 n Y 3 3 3 3 3 3 3 3 3 3 i

R e A

I h

t N

U s

r r o

e n S k e at i o f e u t m s r c e e e s B a t s

e v l

o s a v s y B l m g S

) e a t n I

e d V c i y c n h e e t u d t i l o n

n V l i t o i n

i i o

r i

u r

g a

m t r me t u i t

n t

a e B e o n o s t l d

E L

T o g c ni l

o sa r o

t I

n A

t u C y S

i D

e s

s s I ( h C

t c

e e u T l o

I t t t r t r c S o n e

e n n e e n e

e ne e n s s t

n h h o m MC E e i o R

- r mm e m

r p m s t p

s i

t t e

i d

T t m s t l l l o a o a s e S o in s o e a e m er m r y r Y o e o t t t t t t S a S P a f e p r P n n n A T A n t o o o e r s T n o

n i o l g n C c C t s t c e e N

c e S o y y y n a n e

n zy s E i M s R i

ss r r r e G o y _

y -

m m C l N s l sr a a as r y r a t

e I e r a ml e ee d d n n n A r p T m a t w rk pe n n o o drne ei @

op t n i

t e e g A e N

O g i c y r e r ee tr c c e e cs ee o n at n o

y x

s a t y

C S P V D St S S SD C S C 0 G e f

a s

t e

S b O T TE NB Em Ri RW R

2 2 3 4 4 1 2 4 5 5 1 2 5 6 6 1 2 6

3 6

4 6

i l

e c

p p -

a

. U 6 6 6 6 6 6 6 6 6 6 6 6 6 C e .

4 4 4 4 4 4 4 4 4 4 4 4 4 h _

/ / / / / / / / / / / / / T 3 3 3 3 3 3 3 3 3 3 3 3 3

CTS 3/4.6.6.2 CONTAINMENT ATMOSPHERE DILUTION SYSTEM Not used.

.O a, l

l I

O 20 Revision 0

...J

CTS 3/4.6.6.2 CONTAINMENT ATMOSPHERE DILUTION SYSTEM (continued)

Not used.

b O

O 21 Revision 0

h g A O "

v u

l o5

)

0 1

lo5

)

0 1

9 l o5

)

0 1

l o5

)

0 1

l o5

)

0 1

i o5

)

0 1

lo5

)

0 1

9 l 1

)

0

)

0 1

n r r 5 r r r r r 5 o5 r lo r 5, o t n5 t

n5 0 t n5 t n5 t

n5 t

n5 t n5 0 t

n5 t

n5 C o( o( 5 o( o( o( o( o( 5 o( o(

e g

Cm a Cma R Cma Cma Cma Cma Cma R Cma Cma s

eg r s eg r F sr sr s eg r s eg r n s F sr C eg eg egr C s

eg r eg h

a s aro so ar 0 s aro so ar so ar s aro s aro 0 so ar s aro C BP BP 1 BP BP BP BP BP 1 BP BP n

i o

t a

c L

o l

a r R R s s A s s s s s s s e

n e e S e e e e e A e e e s s s s s s s S s s a a F a a a a a F a a G B B U B B B B B U B B n

p o n

) u is o 9 k s it 1 c e la .

f a r p o n o B .

s o p n 2 n e . u s s

o i t

it a

s s- e e it n 1 g e o c c i n ic e or c t n n i e f i

r g

it n g la la f

e m e .

a la n v p N l in l

ie l

ie d ia _

(

e ie d v vr y t e -

X ht v l r it n m I r u iu u . . u r o -

R f s b s Y Y s g e C it .

T o r g T T g t y n O A n g o n I

L I

L n n o o Y n t i I I I r

a it M i T c m B B im t d a S

t p I L im a e

r o A A r n n lo n i

r I r o r R R o e o g M

E c B A f f f

r e E E f

r e m c e

is is s

e r

e o p P P p n S f

o e T R p O O ia I

D D E P r n ors r

o o r t n c e c

d o ie f m m f o it n m .

E O f t ck s e e s C a a e T

A e d e pea d t

s t

s d m m t

s ht o r o y y o y o r y C ht sb n h s s ht r a

t u o s O o e i t

e o o e d a f

r o L t l m t t n e t E

R g m au uu m g g m o h c

p g i

n e sc e i n n e c e a e n t ht i vav ht t it ht e h it la la a S t a e f o

f ore f

o e le f f f

o f le r r r o o . o r lsm. ls lsb s s ls ls ls ger ls ls ie ia l l inp at t s t ima t a iat iat iat iat ia t lcm iat ia t

ey e eh e e e e e ya e e DS D Dc D D D D D CD D D 1 21 2 3 d d n n

a. a. b. b. c. b. a 1 2 a 1 S b. 1 1 1 1 2 1

b. c. b. b. s. a. c.

T 2 2222 2 2 1 1 2 2 2 2 1 2 2 C 1 4 4444 4 4 44 2 6 6 6 55 5 6 3

6 6666.d6 4444a4 n 6 4

66 44 6

3 6

3 6.d 4a4 n6 0 65 6 6 1 44 4 3 S 5 5 5 6 3 2 2 1 2 2 3 T

I 1 1 1 2 1 3 1 2 2. 1 3. 1 3. 2 4. 1 4. 1 4. 2 4. 1 O 6.

3L A 6.

3L A 6. A 3L 6.

3L A 6.

3L A

g O l t

s o

r l o5

)

0 1

l o5

)

0 1

l o5

)

0 1

9 5

l o5

)

0 1

l o5

)

0 1

9 l o5

)

0 1

l o5

)

0 1

9 l 1 o5

)

0

)

1 n t r r r r r 5 r r 5 r -

o n5 t

n5 t n5 0 t n5 t n5 0 t n5 t n5 0 t

n5 5 C o( o( o( 5 o( o( 5 o( o( 5 o( 5 e Cma C ri Cma R Cma Cma R Cma Cma R Cma (

g s s ii.

egr s F egr s F M egr s egr s eg r sr n F s a e s v C C eg C egr C h so ar a-.o saro 0 saro s od ar n0 s aro so ar 0 s ar o D C BP Br BP 1 BP BPa1 BP BP 1 BP O n

i o

t a

c L

o l

a r R e s s s A s s s s s M n e s

e s

e s S e e M e e M e C .

e a a a F s sd s s s D n

- G B B B U B a anR a a R a o

_ bat B B T B O it t

a t n n e e m Y m

) e T le 9 m t s I s

. g p

1 t a y L t n f e s I

B n ri on e m o t r b A e f i

lb i

_ 3 u R s m s r m o S _

1 s

a s E e e r de n T e g t". P . c i ot f o

I g y nl e o O5

) n u q htd e t a

a e a b md

. . l e e r R md l

p t

_ ( d n

t a u i w o e an ie v

r e mo

,f a

r A X a ec l t r d y S r f s u ds F

_ I R

t s t c Y p Y y4 Y s o ed t U

T e st i

T m T sS T g m voh i v

A n aa I I oE I l

ot i

t P gm L u L L n n c

.O

. M S

i t

o p

m m.

r e oc yo bt u I

B A

R W p I B

A R

t D gO nM I

B A

imr o

t o

i c

e im ve n

yd id a

o N

B e

i r d a S it R .

a ht M c fr n ea n E R E la , E f r t o ind t

vae r r E s e

l pi l t an P H

P e . P e p r e r o

T I

D r e s "o O R O r i

e. O r p it ceu

,r hs e t n

ov s( ac c t o

D f osr e n i f r m g m nS m on cu r .

oden E u e f k e ss e e n e ioE e s o idla c

_ T d cta t

s i t

t s tD c

t s m aisl i t

n A og n e y s

s e y AO y d o s r e a n o oc e C hn ah t s s ht e rvh r e

d M O t t i

o o o d m n ear m rht r o ng e n ht ue f e

g ss oa L t t t i me a r E

ep oi g f g an g m e n he rea t y

s m f

R r w n s n sit n e n ho e i t t a i

b n he i i t pe t a n t a nr t ht n nt c t

m c e ee a o i

f gn et d f

oet f o an d

. l e

r m le r mpo ler f

o l

h die nn i mt e t

_ ssy sl l e s s e e- c sma ea a r

i u

r ls r n ils ls r r o e u es l

V

_ l l i l u

i i

as i

ta v t i

a q ia iuo qn a ia E ion taf e qs p

r tb t t e ur t t e u Ds o e e e e e e R e erh ea o Ds N D R D Ri n D D C Dpw Rg c n

i e

1 b

_ d o R d n n t a2 1 s

_ S a. a. 2 b. a2 77 7 t T -

1 1 6 1 1 2 2 2 n C a. d. 22 2 e 6 6 6 1 1 1 1 2 22 7 1 1 1 m 6 6 4 7 7 7 7 7 77 4 1 1 1 e

/ / ir 4 4 3 3 4 3 3 3 44 3 34 4 u q

e r

1 2 1 2 2 2 d 1

1 1

t e

S A A A A A A A A a T 3 3 L L L L L L R L L c o

I

4. 2 4. 3 e n

1 1 2 2 3 3 3 5 5 l e

O 6. A 3L

6. A 3L N o 7 3

7 3

7

'.s 3 7 7 3 3 7 R

g g - b'

\A

/ h O l t

s o

r 9 l o5

)

0 1

9 9

9 9 l o5

)

0 1

9 l 1

)

0 lo5

)

0 1

9 9 n

o 5

t r 5 5 5 5 t

r 5 t

o5 r

t r 5 5 -

0 n5 0 0 0 0 n5 0 n5 n5 0 0 C 5 o( 5 5 5 5 o( 5 o( o( 5 5 e

g R Cma R R R R Cma R Cma Cma R R F s F F F egr F s F eg r s F egr s F n

a C C C C C C eg r C C h 0 s o ar 0 0 0 0 so ar 0 so ar so ar 0 0 _

C 1 BP 1 1 1 1 BP 1 BP BP 1 1 n

i o

t a

c o

L l

a r R s R R R R e A e A s e A s e

s e A A n S s M M M S s S s s S S n e F a R R R F a F a a F F o G U B T T T U B U B D U U it t

a n

s r le e

)

e r o b e m f

9 u ah e 1 d n pt lp e o af f

o n c

o it a

co im e

c o r r

o r dn S 4 it p f u eo T 1 a a d t i lp c h G s at I e

g o if it D d a ic e trsple t a

a t ic w e vr nm R

(

p n e p e sr ht lo e o o A _

X s i

o t . S cn 'er g d

e s mc er S

F I

R d c n la a d tu n t Y

d de t U T a a o c r it c e T e lo it o c r n s ef P O A n g a in a a I

L n ba o in c h cf t n I e oyr N M ht i c cu s o B ic B .

S it p i m if c

e an c- n A t e e r, na ly l i

r w e n T o R e r t et M c n f c .

p o i m la t ig E h ga h t

E s o r n eo S it n s u u s e P t rb o T e pi a

c o Gth n a d O d a t I

D it it l it Di w a n h d n a a e ct e i

D r rd f a m a i

E e o no ic ic n t ht m m yia e T p f n e ce ec h r e

t t e s r c c A o dc h p im a pn it o s s d e o n e o c e S t s a w f y y a . tt s . e C n ht fe T l n ndr s . e s s lot s ast s r

e .

a o O a e a s c i

d e u o o Cet b a e f oon L r n C la t t gst e _

E c m a o i

n t co t a v g g D e t r .

R i e s aciat n n ec inie y f

o hien t c

h c c r t i

c s o e d it it ht rv i r gic iunvr b _

e e u n o n einnd a t a s d s c t

f n t

o T o n fo le l f e qige er s e io oe r S mde a: e os s

s lsm P r

b e d eem r r lsH ic f

r ls ls r

sy r lsh r a y

t a

r u ip d b e iamu po id ic l

icr o ta rv c ai t u o u la qec e ia ia ia et ae e t r tt p

r is eq o n e e eu p t

e t

e t t ea ef a o D De Rpr r e l

F S S Ds S D D Db Dob c in e

d d b n n 1 4 6 1 2 o o 1 1

n n o it it A 1

d. a. d. a a d. d. t S c c R L R 2 2 2 2 2 s T a. b. a. b. t n

C A A 3 5 6 1 1

1 1 1 33 3 3 e 9 9 7 7 7 1 1 e 1 1 1 22 2 2 m e

9 3

4

/

3 4

/

3 4

/

3 8

4 8.

4N ot 8 4

88 88 8 8 iu r _

33 33 4 4 q e

r 1 2 1 2 3 4 1 3 4 d e

t S A A A A A A A A A a T L L L L L L L L L c I

7 7 e e e 1 1 1 1 4 4 4 lo n n n e O 7 3

7 3 N o

N o

N o 8 3

8 3 3 8 8 3 3 8 8 3

8 3

R

k g O l t

s o

r l o5

)

0 1

l o5

)

0 1

lo5

)

0 1

l o5

)

0 1

9 5

9 l o5

)

0 1

n r r r r 5 r o t n5 t n5 t n5 t n5 0 0 0 0 0 t n5 C o( o( o( o( 5 5 5 5 5 o(

e g

Cma Cma Cma Cma R R R R R Cma n sr eg s eg r s egr segr F F F F F s r a C C C C C eg h saro saro so ar saro 0 0 0 0 0 s aro C BP BP BP BP 1 1 1 1 1 BP n

i o

t a

c L

o l

a r R e s s s s A s n e e e e S M M M M e .

e a s s a

s a

s a s n F R P R R a o G B B B B U T T T T B it t

a n

l y

r e _

r l m

) e n f uo e 9 w o r l p

1 o t i no f p u e n

. i tl aa a m 5

o Y

. f o

b i

r ht f

d n it o mr ep ei c n

i S

t o a a r h T T n s s o c 1 I o i c la I

e g

L I i d Y s

, i f c dde t a

B t a r T o r i c i n oet a A e I e r st R p

R ic w L

I t

c p h nn i A

(

E f

i r o B e S c e loeu r c S X P e p A t e

T t nl e i

F I

R v R n l a U T

O g l

a E d o ic l

o odt h A n d n icr P t i

t n o cnf yo o P O

l n O a . a h P N M o a i

i e n c c f c B i

m g l o fi e ner tT t

p n r Y e es e S i g o n s it a ice T g a v b ht e

M E

r c

s i

s f

r e CL I iy f

r o c p Y r o oge am e p DB I

n t fi S T t t o _

disnm e

u g. ic T d e la I L S t n

I D r o d A v e l a I _

D m nR f s mn p c B l e e ude s

i E

T t e

s f

s aE P

oro dt a uit cs S

l i

h n A R F u uni diol f

i e

c n

A y d C O ce a c E e C s o A ol at c e P t

n ot a au r h hu s i

n T e hcq e O t o t e ond t em mr ao h c s O p t ef i f e -

L E m t a muc t n t s S mirl y r -

R g

e gn mg c cs ec r

T e o io -

e v el a y he&

t m

a ht .

ti a s td de t

e it a H l.

e n h yi cn vio t b

d l y l e od c d f (b h e e

r f t ol i ed r

f o or r e im i n n at r a o de c t r T u a TsT a _

sm slo tou i l .

s sb y set . r l

i l

ia l ie l

r s m e e ;. lit r . f

) o -

a ai l at ir at n s a c m n n m are ef t p r

t t a ev teys t n oe o a a D

e Da Ds Dc e o Cp r D

e C C r

CS r p esh a Dios nt t o c

i n -

d e -

b n d n 1 o -

a d a 1 t

, ,1 1 n A 1 1 S ,1 11 1 b a2 L R R R 2 s _

T , , a. a. b. t n

C 1 1 3344 4. ns 3 24 5 55 4 5 6 7 1

e 222222 2. iob 22 3 33 9 9 9 9 le e m e

888888 8. ct d n 88 1 1 1 4

/

4

/

4

/

4

/

bt ao ir u

343434 3Aa 33 4 44 3 3 3 3 TN q e

r 1

2 d 1 1 1 1 A t e

S A A A A C L a T L L L L L 2 c _

I 7 7 8 5 5 e e s e o .

n n n n 0 le .

O 8 8 8 9 9 o o o o R _

1 3 3 3 3 3 N N N N 3 #

O l s

o r l o5

)

0 1

)

0 1

)

0 1

9 ) ) ) ) ) ) ) )

so5 t

n r v5 5 1 1 1 1 1 1 1 1 b

o t n5 i5 n5 0 5 5 5 5 5 5 5 5 C o( u(

i o( 5 5 5 5 5 5 5 5 5 e

g Cma Cma Cma R

( ( ( ( ( ( ( (

n s eg r sr eg sr eg F

C M M M M M M M M a so saro s C C C C C C C C h ar arod n0 D D D D D D D D C BP BP BPa1 O O O O O O O O n

i o

t a

c o

L l

a r

e s e

s e

M M M M M M M M n s s sd M C C C C C C C C n e a a anR D D D D D D D D o G B B bat O O O O O O O O it t

a n

e d n n m

)

9 n o i s e a i l p

1 e c4 t

a d e

rc f g g n m o

i i l i n n vS o c 6

i i rE i

c u S SeD it 1 m m a i: n T r

a r

a O ic p o la I

e t S id la t g

e is is nM a

f i

c l a c ic a p d d l ,

e n a R i

n n R

( r o

r o

P .

p o ic h h c A ei e. S it n n n

d c S X f f h( a h o o n . e T

e F I

R s e

s e t S

l a ic c i ano T U T r r f E c f e it a

t a

u u oD i

n c i

T c

,i m m P O A M

S i

i n

o t

p d

e c

o d

e c

o YO TL M I

h T

c e S e

p m e

t s

T.

c c

e p

T.

c e

p i

i T

mt u a.

t r ;.

Tn S

t e

s y

S t

e s

y N

B e

M r r r I g la y in ht E

c s

p p Bn n c S S S ,p t n

t n

T e d d Ai t o i n l a

l a 3S e e o -

I D e e Ra it a h t

n c c 3l m m t

n d d Er e r c e 1 a D

i i n n Pp t e in n - c t a

t a e E e e Oo n T m h h ei nn e e c T n m - e t a c c ih r r n

A e r c s e e T T fo on m m n t e T T dc e C o o o n r loe e t e

r O c c s n C e u

T t s s e ,T t s

s u f e

L e e tnin e n s 1 e a r s 3r m l

E r r e t f

f t

s e a h y R e e n E a lu G 1 o w x . _

dao n.

htds. htds. m et e m e f e F E n b _

ni to lu d w f le d r s i u d E ne Ri e .

f o or f o or i

uy qs f

f E

q R

a s b

o it da t

su ac i oa t a

u afic i t so l slo er d L

d o N lolu o f i r o

ei c l l l r e e s ic i r at ir at i u e i u e e it ic p s s s ne heta .

t n t n o

st r e r Dc eo Dc e o TW5 ) i L

q D i L

q G

a D

o oa DP GS ap VS ep o c -

i n -

e 1 b

d. d. A t o

1 1 L 1 2 3 1 2 3 4 5 S s T 0 0 5 1 1 1 2 2 2 2 2 t n

1 1 C 0 1 1 1 1 1 1 1 1 e -

9 9 1 1 1 1 1 1 '. 1 1 m _

4 4 4 41 41 41 41 41 41 41 41 e r

/ / / / / / / / / / / i 3 3 3 3R 3R 3R 3R 3R 3R 3R 3R u q

e r

1 1 d

A A t e

L L a -

S c T 4 5 o I

0 0 e e e e e e e e e le _

n n n n n n n n n O 1 3 3 1

N o

N o R

b -

O l t

s o

r )

1 9 )

1

)

1

)

1

)

1 9 9 9 9 9 9 9 9 9 n 5 5 5 5 5 5 5 5 5 5 o 5 0 5 5 5 5 0 0 0 0 0 0 0 0 0 C 5

(

5 5

(

5

(

5

(

5

(

5 5 5 5 5 5 5 5 5 e

g R R R R R R R R R R n M F C

M M M M F F F F F F F F F a C C C C C C C C C C C C C C h D 0 D D D D 0 0 0 0 0 0 0 0 0 C O 1 O O O O 1 1 1 1 1 1 1 1 1 n

o it a _

c -

o L

la R R R R R R R R R R r

e M A M M M M A A A A A A A A A n C S C C C C S S S S S S S S S e D F D D D D F F F F F F F F F G O U O O O O U U U U U U U U U _

n

) o s 9 la it e 1

n ic a d e f o n i c n h lt _

o f y ar o t it _

it h i _

a c c r ,t n n se ca 7 n e e a s o 1 o ic T p d i

d n it e it n

. f i S n r ue e o .

g a o c u sR is s a ic e m a

l a o s t

r it o p

t n

p f it a

p r c b e e e s la e

( i c ic S g i n e rh u .

ic _

X e f la o h pt in c s e f m e

p ic c P r n. c it s d d e la u ic r o

I .

R T

S e p

i n g it T e d nan a b c

, la e p iuq t

s n n ,. v n O n a l

h s A n o

a S c ic m a s tn a k e e M ic l e ir o f a e e r e c y t n

r m

i n a T ic in it S

t p h c ic )

it n e r

g n o tum t a

r e

d n

lp a w e

e r

n o a n i i M r c e 0 o p z r ai h w e . f n r c iu d ks h r t q E s T c 9 M S P n et o i o e T e e 1 o pn s t u c k t t r

I D g T

l a la n mo e p lca g f

i o

l in T ic it eC a nr r n h e _

D g e R t n n is l a y ic f o s s E r t A e r u t y t g is le it a n _

T h A P u s a P m c e

a p

p o

nr ga le u lo eu f e

r le m

u ic e _

R n p im o it u r C r W o T m s f r neh t a ls m l r

O o e F

C r s o w ei r c o iat r i

n o _

L g v i

v u C o dP . i f e t e ia t E n n s ,

m ic t

rh p t im a R it 0 E n y l se e e et e r it n

c a (

4 n e

r o e nh et p e. m ci nw m e

d e e p

e o e lao C t ht ot s sr f u t e h o

a it f y o t V id s cit e r f a soS f o f d d c n

ot e f f a o i

gac s o o r ocr n e o o l

l R D loi U b u en t o a t ia e

oi f a ls igma ls to it lsi ic c

e l

p ls ls w d la ic d l

r e ia f nuo l ia c a ao r m ia ia y i l

o t

o d e n t e ae t c t s r t t D

r S T RS ap L

a I

t n D e ooo CvC l

Dr L o e s Da C o

C o

D e

d 1 1 1 1 1 n 1 4 a 2 8 R R R R R ,

S 2 3 4 2 3 d

n 5 , a. b. d 2 T 1 d n C a 3 1 22 a7 6 d.

1 1 1 2 2 2 n 1 1 1 1 1 1 23 a 1 6 1 1 1 1 2 le 2 41 4 4 4 4 4 1 1 2 3 5 1 666 1 5 b 2

/ / / / / / a 3R 3 3 3 3 3 55 5 5 5 5 555 66 T 6 1 2 3 5 6 7 1 1 2 S

T A A A A A A A A A _

I e e e e e e L L L L L L L L L n n n n n n O .

N o

N o 0 4

0 4

1 5

2 5

g k O l t

s o

r 9 5

9 5

)

(

4 5

a

)

(

4 a

)

(

4 a

9 9 9 9 9

n 5 5 5 5 5 5 5 o 0 0 0 0 0 0 0 0 0 0 0 C 5 5 5 5 5 5 5 5 5 5 5 e

g R R R R R R R R R R R n

F C

F F F F F F F F F _

a C C C C C C C C C -

h 0 0 0 0 0 0 0 0 0 0 0 C 1 1 1 1 1 1 1 1 1 1 1 n

o it a

c m n m n m n _

o a io a a L

l r

gt io r gt r gt io _

a R R R op op op R R R R r ri ri e A A A Pc s r

Pc s r ri Pc s r A A A A n S S S S S S S M n e F F F Ae Ae Ae F F F F R o G U U U QD QD QD U U U U T it t

a r n o S e _

r T o . .

n m _

)

9 t s e

s y o ic G e _

1 yc e r lcy S lp __

ba e lt l t a r

it a -

f o it it .

o C e m dR e n n yng p t

n h i 8 s r o o it ri e t n

t S

io m f T

1 vi it it lao e m e o I n

e r n is is uit t e g g ee o o Qn o r lp m a o n t

a -

a pS u p p o m r p it R p

ic gm r f g _

s o ic i o m . s A _

(

e f n ls o m es .

X f a m r S c irl C r

e e a I

bo t ic i v a P a .

tg is y F R oa e p vn t o r g g y r g m nl a U T t r s p

o e r o n b o a O

s p it P A n o snpe t t cm p P r i r

o d e P r r g n en a N M n n dn a o B i

t p

o O g.

la a eo l o

it n n n P r myr S i it r n i p lp sr d n r o r

e o eo e M r c aol r t d ui v a t n v it c g lpt h o o en M n a t E

T s

e l t e aa cn t g

t be s C

o n

og e p it s

mro t o

I D AeH n g

n od w e s o s s e irb n D e R t n s it t n T oa i r r e l

it it s a i

v n . i f l e

E a a e ia em ic dsm T oou et e c d na e e c A CiFn le le r n r o or ic e n e

r r ue e r R a

p g v v ot e -

rSteo C s del u r P o r r ht ys r O

L iud d l

ia ls ia cf f d

u r o

t n mr oP e

s e

s es f e

e E qet e t e

t e

oe r e c f la ct I n In mre r R esi pr o s P- i y

t r

einm d e

d e f f o r p

t n s . n hiem ht e e ht hi et l b

acL c c o e e e i tL t f d

hli r n n ec f os .

mr f o f t on f

o f

o f V e t

ao ia ia cn na eu oE t a

ls r a t lp lp ar s e lig ird ls lsies s ls lsR r o

e ia C l

iaer d is u an u ia ian ia ia p t et h p e m

o m

o us t a qoc t t a t t t d r DeO i

C C GA Dc eh Rp er D e

DT e r D

e D

e Da en o c

i n

e d b d ,

n o n 2 , a, t S a s T g

, , , b. c. 2 t n

C . b. c. e. 1 i. h. 2 1 1 b. c. e 2 1 1 24 1 1 2 1 3 5 5 6622 m 2 2222 3 8 8 8 8 7 0 0 6677 e ir 6 6666 6 6 6 6 6 5 4 4 4444 u q

e r

d e

t 3 4 1 1 2 3 1 2 3 4 5 a S c T

I A

L A

L A A A A A A A A A o L L L L L L L L L le O 2 5

2 5

3 5

4 5

5 5

R

g A O l t

s o

r )

1 l

o5

)

0 1

9 5

l 1 o5

)

0 9

5 9

5

)

(

4 5

a

)

(

4 a

)

(

4 a

)

(

4 a

9 9 n 5 r r 5 5 5 5 5 o t n( 5 0 t n5 0 O 0 0 0 0 0 0 C 5 o 5 o( 5 '5 5 5 5 5 5 5 e

g

(

Cma R Cma R R R R R R R R M s F eg r s eg r F F F F F F n C C C C C C C F F a so C C C h D ar 0 so ar 0 0 0 0 0 0 0 0 C O BP 1 BP 1 1 1 1 1 1 1 1 n _

i o .

t a

c m n m n m n m n L

o a a a a r

gt io r io r io r io l gt gt gt a R R R op op op op R R r

e M s A s A A ri r ri r ri r ri r _

n C e S e Pc s Pc s Pc s Pc s A A e D s s S S S S G O a F a F F Ae Ae Ae Ae F F B U B U U QD QD OD OD U U -

r g -

)

9 r o n r r 1

o f is o o -

f a s f f f

o s t

i r

e e g ls n it d r n a -

9 e r d in v -

1 m s. c a s ia o -

e e e e r grp g r re c s n lt t n ip a

p iuu n o it t n t aa qt x a

( ei t p

it a i c e rd en .

X rM m p a m I g e c ic f

if c e O s a R n s c t ic e c r g .

T ia a r p la r A n t

nG o e p s p o w e s

. o m a

gO v

M i o e mve d

n a

p e s t n

er oe

,i nv ie s

w r

p r g

S t

p eis R latr a d r it v ie n o i

r lpo s p uo l

p n it v o r p

M c dr u d p a an it e it E s e

mp l a t r iv e t o g ico f it a c r c e lo T ix d a iR n s t r I

D rE n d g id a it n

o t fo d t t D a S ins n in oic d n r n it ia mi f u e o p o E s n t it T S h hm la r ,ce a v it c d a it it e t e n n o s A os M w wLg i

r n sp e d n

e s C hk T o rS a le t e it e O t n d ls ul b r ia c L ea S e dn ei ia d d a a d o E mT A t a aa t t t

e e

n ec ie w t r

o dr o

a r

r p

R ep ol .

ic ir ce d iaf

. cin o v p c e e ti rh s o o h u op t f pc e e e h t d s sO e c na t e r r r t h

t fo o l

ele cnf u s

a s

aer n os c f T o/s f

o f

o H s ia t e ge ls id el il lso l p si n ls s s ls ls ls ls ai u r e e s a iC a

l ia u ia n n l

ia ia ia i

a ia m tece a t

eq f eie t

e e he t

o t

e he t e

t e

DiL Rd D Dt C Dt Dih L c D D D D D d

d n 4 6 c. n a S 2 a 1 1 1 T 1 2 , , a. b. 1 1 2 2 C 1 1 23 1 1 A A A 1

1 1

1 1 1 1 1 33 2 A A A A L L L 2 L L L L 4d4 8 0 1 4

/n/ 999 99 1 4 5 5 6 1 1 1 3a3 4 666 66 6 6 6 6 6 6 6 6 S 6 7 1 2 1 T

I A A A A A L L L L L e e e e e e e n n n n n n O 5 5

5 5

6 5

7 5 N o

N o

N n

o N

o

CAD Systea 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System i

LCO 3.6.3.2 CAD System shall be OPERABLE. I APPLICABILITY: MODE 1 during the time period:

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

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to < 15% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l 1

A. CAD System inoperable. A.1 --------NOTE---------

LC0 3.0.4 is not b

l applicable.

O .....................

j Restore CAD System to 31 days .

OPERABLE status. !

j B. Required Action and C.1 Be in MODE 2. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months associated Completion i Time not met. i i

j O '

Brunswick Unit 1 3.6-27 Amendment No.

CAD System 3.6.3.2 SURVEILLANCE REQUIRENENTS SURVEILLANCE FREQUENCY SR '3.6.3.2.1 Verify ;t 4350 gal of liquid nitrogen are 31 days contained in the CAD System.

SR 3.6.3.2.2 Verify each CAD _ subsystem manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

SR 3.6.3.2.3 Cycle each power operated, excluding 24 months automatic, valve in the flow path through one complete cycle.

b 13 C SR 3.6.3.2.4 -------------------NOTE------------------

Failure to meet this SR does not render the CAD System inoperable. Enter applicable Condition and Required Actions of LCO 3.6.1.3, " Primary Containment Isolation Valves (PCIVs)," in the event of failure to meet this SR. _

j i

Verify each automatic valve in the flow 24 months path actuates to the isolation position on an actual or simulated isolation l signal. '

O-Brunswick Unit 1 3.6-28 Amendment No.

J

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

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

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

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A 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 C. Secondary containment C.1 --------NOTE--------- i inoperable during LC0 3.0.3 is not i movement of irradiated applicable.

fuel assemblies in the ---------------------

secondary containment, '

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

AND (continued)

Brunswick Unit 1 3.6-29 Amendment No.

J

l Secondary Containment 3.6.4.1 l

I

O ACTi-S

CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Suspend CORE Immediately l ALTERATIONS.

AND C.3 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify all secondary containment 24 months ,

equipment hatches are closed and sealed. l O

SR 3.6.4.1.2 Verify one secondary containment access A

24 months door is closed in each access opening.

SR 3.6.4.1.3 Verify each SGT subsystem can maintain 24 months on a l a: 0.25 inch of vacuum water gauge in the STAGGERED TEST

secondary containment for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a BASIS flow rate s 3000 cfm.

l

'O i

l Brunswick Unit 1 3.6-30 Amendment No.

SCIDs 3.6.4.2 O- 35 Coataraaca1 svstcas

- 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)

LCO 3.6.4.2 Each SCID shall be OPERABLE.

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

ACTIONS

....................................-NOTES----------------------..-.--..---.-.

.1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made O. inoperable by SCIDs.

l CONDITION REQUIRED ACTION COMPLETION TIME I

A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months penetration flow paths penetration flow path !

with one SCID by use of at least inoperable. one closed and !

de-activated automatic damper, i closed manual damper, or blind flange.

8!E (continued)

O Brunswick Unit 1 3.6-31 Amendment No.

4

1 SCIDs 3.6.4.2

.O ^C11oas CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 --------NOTE---------

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 92 days penetration flow path is isolated.

B. ---------NOTE--------- B.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path penetration flow paths by use of at least with two isolation one closed and dampers, de-activated 1 automatic damper, l C

closed manual damper, One or more or blind flange, penetration flow paths with two SCIDs l

inoperable.

l l

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

associated Completion l Time of Condition A AND 1 or B not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months l

(continued) b)

v Brunswick Unit 1 3.6-32 Amendment No.

SCIDs 3.6.4.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.I --------NOTE---------

associated Completion LCO 3.0.3 is not '

Time of Condition A applicable, or B not met during ---------------------

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

AND D.2 Suspend CORE Immediately ALTERATIONS.

l AND j

D.3 Initiate action to Immediately !

suspend OPDRVs. l O

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each 24 months automatic SCID is within limits.

SR 3.6.4.2.2 Verify each automatic SCID actuates to 24 months the isolation position on an actual or simulated actuation signal.

.O Brunswick Unit 1 3.6-33 Amendment No.

J

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

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

I During operations with a potential for draining the reactor vessel (0PDRVs). l 4

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

2 or 3. '

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A 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 E

1 Two SGT subsystems inoperable in MODE 1, 2, or 3.

(continued)

O Brunswick Unit 1 3.6-34 Amendment No.

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION -COMPLETION TIME C. One SGT subsystem C.1 Restore SGT subsystem 31 days inoperable during to OPERABLE status.

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

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

associated Completion LCO 3.0.3 is not applicable.

Time of Condition C ----------------------------

not met. i D.1 Place OPERABLE SGT Immediately subsystem in operation.

9a D.2.1 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

8!!Q D.2.3 Initiate action to Immediately suspend OPDRVs.

(continued)

O Brunswick Unit 1 3.6-35 , Amendment No.

J

i SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two SGT subsystems E.1 --------NOTE-------- l inoperable during LCO 3.0.3 is not movement of irradiated applicable. l fuel assemblies in the -------------------- 1 secondary containment, ,

during CORE Suspend movement of Immediately I ALTERATIONS, or during irradiated fuel !

OPDRVs. assemblies in I secondary l containment. l l

AND E.2 Suspend CORE Immediately ALTERATIONS.

AND E.3 Initiate action to Immediately suspend OPDRVs.

O SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for a: 10 31 days continuous hours with heaters operating.

i SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

I l

l SR 3.6.4.3.3 Verify each SGT subsystem actuates on an 24 months actual or simulated initiation signal.

[

Brunswick Unit 1 3.6-36 Amendment No.

Primary Containment Oxygen Concentration B 3.6.3.1 O B 3.6 C0a1AlaaEaT Sv51taS B 3.6.3.1 Primary Containment Oxygen Concentration BASES BACKGROUND The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration < 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration. The capability to inert the primary containment and maintain oxygen

< 4.0 v/o works together with the Containment Atmosphere Dilution System (LCO 3.6.3.2, " Containment Atmosphere A Dilution (CAD) System") to provide redundant and diverse E methods to mitigate events that produce hydrogen and oxygen.

For example, an event that rapidly generates hydrogen from zirconium metal water reaction could result in excessive hydrogen in primary containment, but oxygen concentration will remain < 5.0 v/o and no combustion can occur. Long O term generation of both hydrogen and oxygen from radiolytic decomposition of water may eventually result in a combustible mixture in primary containment if the initial primary containment oxygen concentration exceeded 4.0 v/o during operation in the applicable conditions. This LCO ensures that oxygen concentration does not exceed 4.0 v/o during operation in the applicable conditions.

APPLICABLE SAFETY ANALYSES The Reference I calculations assume that the primary containment is inerted when a Design Basis Accident (DBA) h loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment.

Oxygen, which is subsequently generated by radiolytic decomposition of water, is diluted by the CAD System more rapidly than it is produced.

Primary containment oxygen concentration satisfies Criterion 2 of Reference 2. d (continued)

O Brunswick Unit 1 B 3.6-60 Revision No.

Primary Containment Oxygsn Concentration B 3.6.3.1 O sasEs (centinued)

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODE 1, since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible during a scheduled power reduction to s 15% RTP. As long as reactor power is s 15% RTP, the potential for an event that generates significant hydrogen and oxygen is low and the primary containment need not be inert. Furthermore, the O probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a scheduled power reduction s 15% RTP, is low enough that these " windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

ACTIONS Ad l

If oxygen concentration is a 4.0 v/o at any time while i operating in MODE 1, with the exception of the relaxations !

allowed during startup and shutdown, oxygen concentration !

must be restored to < 4.0 v/o within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months !

Completion Time is allowed when oxygen concentration is a 4.0 v/o because of the availability of other hydrogen and oxygen mitigating systems (e.g., Containment Atmosphere Dilution System) and the low probability and long duration ;

of an event that would generate significant amounts of '

hydrogen and oxygen occurring during this period. l (continued)

O Brunswick Unit 1 B 3.6-61 Revision No.

o Primary Containment Oxygen Concentration l B 3.6.3.1

)

BASES l

l ACTIONS S_d (continued)

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To l

achieve this status, power must be reduced to s 15% RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without l challenging plant systems.

. SURVEILLANCE SR 3.6.3.1.1 REQUIREMENTS The primary containment must be determined to be inerted by verifying that oxygen concentration is < 4.0 v/o. The 7 day Frequency is based on the slow rate at which oxygen concentration can change and on other indications of abnormal conditions (which would lead to more frequent checking by operators in accordance with plant procedures).

Also, this Frequency has been shown to be acceptable through operating experience.

REFERENCES 1. UFSAR, Section 6.2.5.

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

t

. U(')

Brunswick Unit 1 B 3.6-62 Revision No.

\

, J l

CAD System B 3.6.3.2 O B 3.6 CoaTAiaaEaT SvSTEaS B 3.6.3.2 Containment Atmosphere Dilution (CAD) System BASES BACKGROUND The CAD System functions to maintain combustible gas concentrations within the primary containment at or below the flammability limits following a postulated loss of coolant accident (LOCA) by diluting hydrogen and oxygen with nitrogen. To ensure that a combustible gas mixture does not occur, oxygen concentration is kept < 5.0 volume percent (v/o).

The CAD System is manually initiated and consists of two 100% capacity subsystems. Each subsystem consists of a common liquid nitrogen supply tank, an electric vaporizer, and connected piping to supply the drywell and suppression chamber volumes. The liquid nitrogen supply tank and electric vaporizers are common components which are shared between the CAD subsystems of the two units. Piping from the liquid nitrogen supply tank dcwnstream of the vaporizers is split and routed to each unit. Each pipe to a particular unit is. divided to provide the capability to supply nitrogen O to both the drywell and the suppression chamber. The d nitrogen storage tank contains 2: 4350 gal, which is adequate for 30 days of CAD subsystem operation.

The CAD System operates in conjunction with emergency operating procedures that are used to reduce primary containment pressure periodically during CAD System operation. This combination results in a feed and bleed approach to maintaining hydrogen and oxygen concentrations below combustible levels.

APPLICABLE To evaluate the potential for hydrogen and oxygen SAFETY ANALYSES accumulation in primary containment following a LOCA, hydrogen and oxygen generation is calculated (as a function of time following the initiation of the accident). The assumptions stated in Reference 1 are used to maximize the amount of hydrogen and oxygen generated. The calculation confirms that when the mitigating systems are actuated in accordance with emergency operating procedures, the peak oxygen concentration in primary containment is < 5.0 v/o (Ref. 2).

(continued)

Brunswick Unit 1 B 3.6-63 Revision No. I I

CAD System B 3.6.3.2 BASES APPLICABLE Hydrogen and oxygen may accumulate within primary ;

SAFETY ANALYSES containment following a LOCA as a result of: !

a. A metal water reaction between the zirconium fuel rod cladding and the reactor coolant; or

b. Radiolytic decomposition of water in the Reactor Coolant System.

The CAD System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref.3).

LC0 The CAD System (two CAD subsystems) must be OPERABLE with an OPERABLE flow path capable of supplying nitrogen to the drywell. This ensures operation of at least one CAD subsystem in the event of a worst case single active failure. Operation of at least one CAD subsystem is designed to maintain primary containment post-LOCA oxygen concentration < 5.0 v/o for 30 days.

APPLICABILITY In MODE 1 when primary containment oxygen concentration is b3/ required to be < 4.0 v/o (i.e., primary containment inerted) in accordance with LC0 3.6.3.1, " Primary Containment Oxygen Concentration," the CAD System is required to maintain the oxygen concentration within primary containment below the flammability limit of 5.0 v/o following a LOCA. This ensures that the relative leak tightness of primary containment is adequate and prevents damage to safety related equipment and instruments located within primary containment.

In MODE 1, when primary containment oxygen concentration is not required to be < 4.0 v/o in accordance with LCO 3.6.3.1,

" Primary Containment Oxygen Concentration," and in MODE 2, the potential for an event that generates significant hydrogen and oxygen is low, the primary containment need not be inert, and the CAD System is not required to be OPERABLE.

Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a scheduled power reduction < 15% RTP (i.e., when primary containment oxygen concentration is not required to be < 4.0 v/o in accordance with LC0 3.6.3.1), is low enough that these " windows," when the primary containment is not inerted and the CAD System is not required to be OPERABLE, are also ju.:tified.

-(continued)

Brunswick Unit 1 B 3.6-64 Revision No.

CAD System B 3.6.3.2 l

O BASES l

l APPLICABILITY In MODE 3,'both the hydrogen and oxygen production rates and l (continued) the total amounts produced after a LOCA would be less than !

l those calculated for the Design Basis Accident LOCA. Thus, l if the analysis were to be performed starting with a LOCA in MODE 3, the time to reach a flammable concentration would be extended beyond the time conservatively calculated for )

MODE 1. The extended time would allow hydrogen removal from '

the primary containment atmosphere by other means and also allow repair of an inoperable CAD subsystem, if CAD were not

, available. Therefore, the CAD System is not required to be

! OPERABLE in MODE 3.

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

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

Required Action A.1 has been modified by a Note that indicates that the provisions of LC0 3.0.4 are not applicable. As a result, a MODE change is allowed when the CAD System (one or both subsystems) is inoperable. This allowance is provided because of the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flammability limit, the amount of time available after a postulated LOCA for operator action to prevent exceeding the flammability limit, and the availability of other hydrogen mitigating systems.

, (continued)

O Brunswick Unit 1 B 3.6-65 Revision No.

l

CAD System B 3.6.3.2 BASES ACTIONS M (continued)

If Required Action A.1 cannot be met within the associated Completion Time, the plant must be brought to a MODE in which the LC0 doe:; not apply. To achieve this status, the plant must be brought to at least MODE 2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS Verifying that there is 2: 4350 gal of liquid nitrogen supply in the CAD System will ensure at least 30 days of post-LOCA CAD operation. This minimum volume of liquid nitrogen allows sufficient time after an accident to replenish the nitrogen supply for long term inerting. This is verified every 31 days to ensure that the system is capable of performing its intended function when required. The 31 day Frequency is based on operating experience, which has shown n

V 31 days to be an acceptable period to verify the liquid g nitrogen supply and on the availability of other hydrogen mitigating systems.

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

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable because the CAD System is manually initiated.

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

(continued)

Brunswick Unit 1 B 3.6-66 Revision No.

l CAD System l B 3.6.3.2 t-

-O BASES l

SURVEILLANCE SR 3.6.3.2.2 (continued)

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

SR 3.6.3.2.3 Cycling each power operated valve, excluding automatic valves, in the CAD System flow path through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. ;

While this Surveillance may be performed with the reactor at i power, the 24 month Frequency of the Surveillance is intended to be consistent with expected fuel cycle lengths.

Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be 1 acceptable from a reliability standpoint.

O J.R 3.6.3.2.4 i On Group 2 and 6 primary containment isolation signals, automatic valves in the CAD System flow path close to b-prevent leakage of radioactive material from primary j containment following a design basis accident. The 4 automatic valves in the CAD System flow path that close on Group 2 and 6 primary containment isolation signals are primary containment isolation valves (PCIVs) as identified i in UFSAR Table 6.2.4-1 (Ref. 4). This SR ensures that each automatic PCIV in the CAD System will actuate to its ;

isolation position on the associated Group 2 and 6 primary l containment isolation signals. The LOGIC SYSTEM FUNCTIONAL TEST in LC0 3.3.6.1, " Primary Containment Isolation Instrumentation," overlaps this SR to provide complete :

testing of the safety function. The 24 month Frequency is !

based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency.

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

(continued) g O Brunswick Unit 1 B 3.6-67 Revision No.

CAD System B 3.6.3.2 ,

( BASES SURVEILLANCE SR 3.6.3.2.4 (continued)

REQUIREMENTS This SR is modified by a Note indicating that failure to meet SR 3.6.3.2.4 does not affect the OPERABILITY of the CAD i System. As such, when the CAD System liquid nitrogen supply tank, valves, and piping are OPERABLE such that an OPERABLE flow path is available to supply nitrogen to the drywell, but one or more PCIVs in the CAD System will not actuate to isolate the CAD System flow path from the primary containment in response to a simulated or actual primary containment isolation signal, the CAD System is still OPERABLE. To ensure the ACTIONS of LC0 3.6.1.3, " Primary Containment Isolation Valves (PCIVs)," are entered when the ability to isolate the CAD System flow path from the primary containment in response to a primary containment isolation signal is lost, the Note to SR 3.6.3.2.4 also indicates that failure to meet SR 3.6.3.2.4 requires the ACTIONS for LC0 3.6.1.3 to be immediately entered. The ACTIONS of LC0 3.6.1.3 provide the appropriate restrictions for one or more inoperable PCIVs. A REFERENCES 1. Safety Guide 7, March 1971.

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

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

4. UFSAR, Table 6.2.4-1.

l O i Brunswick Unit 1 B 3.6-68 Revision No.

l l l

Secondary Containment B 3.6.4.1 l B 3.6 CONTAINMENT SYSTEMS B 3.6.4.1 Secondary Containment i

i BASES BAc 'ADUND The function of the. secondary containment is to contain and hold up fission products that may leak from primary containment following a Design Basis Accident (DBA). In !

conjunction with operation of the Standby Gas Treatment l (SGT) System and closure of certain valves whose lines penetrate the secondary containment, the secondary containment is designed to reduce the activity level of the fission products prior to release to the environment and to isolate and contain fission products that are released during certain operations that take place inside primary containment, when primary containment is not required to be OPERABLE, or that take place outside priuary containment.

The secondary containment is a structure that completely encloses the primary containment and those components that ,

may be postulated to contain primary system fluid. This '

structure forms a control volume that serves to hold up the

] fission products. It 1.s possible for the pressure in the control volume to rise relative to the environmental pressure. To prevent ground level exfiltration while allowing the secondary containment to be designed as a conventional structure, the secondary containment requires support systems to maintain the control vol ue pressure at less than the external pressure. Requiremk s 'for tirase systems are specified separately in LC0 3.6.4.2, " Secondary Containment Isolation Dampers (SCIDs)," and LC0 3.6.4.3,

" Standby Gas Treatment (SGT) System."

APPLICABLE There are two principal accidents for which credit is taken SAFETY ANALYSES for secondary containment OPERABILITY. These are a loss of ,

coolant accident (LOCA) (Refs. I and 2) and a fuel handling accident inside secondary containment (Refs. 1 and 3). The '

secondary containment performs no active function in response to each of these limiting events; however, its leak tightness is required to ensure that fission products entrapped within the secondary containment structure will be treated by the SGT System prior to discharge to the l

l environment.

l Secondary containment satisfies Criterion 3 of Reference 4.

(continued)

Brunswick Unit 1 B 3.6-69 Revision No.

Secondary Containment B 3.6.4.1 O BASES (cent 1#ued)

LCO An OPERABLE secondary containment provides a control volume into which fission products that leak from primary containment, or are released from the reactor coolant pressure boundary components or irradiated fuel assemblies located in secondary containment, can be processed prior to release to the environment. For the secondary containment i to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained, at least one door in each access to the Reactor Building must be closed, and the sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) must be OPERABLE.

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature r~g limitations in these MODES. Therefore, maintaining C/ secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.

ACTIONS A_d If secondary containment is inoperable, it must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

(continued)

Brunswick Unit 1 B 3.6-70 Revision No.

Secondary Containment

, B 3.6.4.1 j r

b) BASES l ACTIONS B.1 and B.2 (continued)

If secondary containment cannot be restored to OPERABLE l status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 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 l power conditions in an orderly manner and without '

challenging plant systems.

C.1. C.2. and C.3 Movement of irradiated fuel assemblies in the secondary I containment, CORE ALTERATIONS, and OPDRVs can be postulated i to cause fission product release to the secondary containment. In such cases, the secondary containment is i the only barrier to release of fission p.roducts to the ;

environment. CORE. ALTERATIONS and movement of irradiated fuel assemblies must be immediately suspended if the '

(] secondary containment is inoperable. Suspension of these V activities shall not preclude completing an action that ;

involves moving a component to a safe position. Also, !

action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LC0 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action C.1 has been modified by a Note stating that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

(continued)

O Brunswick Unit 1 B 3.6-71 Revision No.

Secondary Containment B 3.6.4.1 .

O BASES (continued)

SURVEILLANCE SR 3.6.4.1.1 and SR 3.6.4.1.2 REQUIREMENTS Verifying that secondary containment equipment hatches and one secondary containment access door in each access opening are closed ensures that the infiltration of outside air of such magnitude as to prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur.

In this application, the term " sealed" has no connotation of leak tightness. Maintaining secondary containment A OPERABILITY requires verifying one door in each access opening is closed. The 24 month Frequency for these SRs has been shown to be adequate, based on operating experience, and is considered adequate in view of other indications of door and hatch status that are available to the operator.

SR 3.6.4.1.3 The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment.

O To ensure that fission products are. treated, SR 3.6.4.1.3 verifies that the SGT System will establish and maintain a b.

negative pressure in the secondary containment. This is '

confirmed by demonstrating that one SGT subsystem can maintain 2: 0.25 inches of vacuum water gauge for I hour at a flow rate s 3000 cfm. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months test period allows secondary containment to be in thermal equilibrium at steady i state conditions. Therefore, this test is used to ensure '

secondary containment boundary integrity. Since this SR is i a secondary containment test, it need not be performed with ;

each SGT subsystem. The SGT subsystems are tested on a l STAGGERED TEST BASIS, however, to ensure that in addition to .

the requirenents of LC0 3.6.4.3, either SGT subsystem will i perform this test. Operating experience has demonstrated '

these components will usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. J (continued) l Brunswick Unit 1 B 3.6-72 Revision No.

Secondary Containment B 3.6.4.1 O BASES (coatinued)

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

2. UFSAR, Section 15.6.4.

3. UFSAR, Section 15.7.1.

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

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

6. Regulatory Guide 1.52, Revision 1.

O i

l l

l O

Brunswick Unit 1 'B 3.6-73 Revision No.

SCIDs B 3.6.4.2 8 3.6 CONTAINMENT SYSTEMS B 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)

BASES BACKGROUND The function of the SCIDs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DBAs) (Refs. 1, 2, and 3). Secondary containment isolation within the time limits specified for those isolation dampers designed to close automatically ensures that fission products that leak from primary containment following a DBA, or.that are released during.certain operations when primary containment is not required to be OPERABLE or take place outside primary containment, are maintained within the secondary containment boundary.

The OPERABILITY requirements for SCIDs help ensure that an adequate secondary containment boundary is maintained during and after an accident by minimizing potential paths to the environment. These isolation devices consist of active (automatic) devices.

Automatic SCIDs close on a secondary containment isolation l signal to establish a boundary for untreated radioactive i material within secondary containment following a DBA or other accidents.

APPLICABLE The SCIDs must be OPERABLE to ensure the secondary SAFETY ANALYSES containment barrier to fission product releases is- :

established. The principal accidents for which the !

secondary containment boundary is required are a loss of :

coolant accident (Refs. I and 2) and a fuel handling accident inside secondary containment'(Refs. I and 3). The '

secondary containment performs no active function in response to either of these limiting events, but the boundary established by SCIDs is required t'o ensure that leakage from the primary containment is processed by the Standby Gas Treatment (SGT) System before being released to the environment.

(continued)

O Brunswick Unit 1 B 3.6-74 Revision No.

SCIDs B 3.6.4.2 BASES APPLICABLE Maintaining SCIDs OPERABLE with isolation times within SAFETY ANALYSES limits ensures that fission products will remain trapped (continued) inside secondary containment so that they can be treated by the SGT System prior to discharge to the environment.

SCIDs satisfy Criterion 3 of Reference 4.

LCO SCIDs form a part of the secondary containment boundary.

The SCID safety function is related to control of offsite radiation releases resulting from DBAs.

The isolation dampers are considered OPERABLE when their associated accumulators are pressurized, their isolation times are within limits, and the dampers are capable of actuating on an automatic isolation signal. The dampers covered by this LCO, along with their associated stroke times, are listed in Reference 5.

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product release to the primary containment that leaks to the n

V secondary containment. Therefore, the OPERABILITY of SCIDs is required.

In MODES 4 and 5, the probability and consequences of these events are reduced due to pressure and temperature limitations in these MODES. Therefore, maintaining SCIDs OPERABLE is not required in MODE 4 or 5, except for other situations under which significant radioactive releases can be postulated, such as during operations with a potential for draining the reactor vessel (0PDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel 5

assemblies in the secpndary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES 1, 2, and 3.

ACTIONS The ACTIONS are modified by three Notes. The first Note allows penetration flow paths to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator, who is in continuous communication with the control room, at the controls of the isolation device. In this way, the penetratioh can be rapidly isolated when a need for secondary containment isolation is indicated.

(continued)

Brunswick Unit 1 B 3.6-75 Revision No.

SCIDs B 3.6.4.2 BASES j ACTIONS The second Note provides clarification that for the purpose (continued) of this LCO separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each condition provide appropriate compensatory actions for each inoperable SCID. Complying l

with the Required Actions may allow for continued operation, and subsequent inoperable SCIDs are governed by subsequent i Condition entry and application of associated Required Actions.

The third Note ensures-appropriate remedial actions are taken, if necessary, if the affected system (s) are rendered inoperable by an inoperable SCID.

A.1 and A.2 In the event that'there are one or more penetration flow paths with one SCID inoperable, the affected penetration !

flow path (s) must be isolated. The method of isolation must !

include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

,A Isolation barriers that meet this criterion are a closed and U de-activated automatic SCID, a closed manual damper, and a blind flange. For penetrations isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available device to secondary containment. The Required Action must be completed within the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time. The specified ,

time period is reasonable considering the time required to ,

isolate the penetration, and the probability of a DBA, which l requires the SCIDs to close, occurring during this short time is very low.

For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration must be verified to be isolated on a periodic basis. This is necessary to ensure that secondary containment penetrations required to be isolated following an accident, but no longer capable of being automatically isolated, will be .in the isolation position should an event occur. The Completion Time of once per 92 days is appropriate because the devices are operated under administrative controls and the probability of their

, misalignment is low. This Required Action does not require any testing or device manipulation. Rather, it involves verification that the affected penetration remains isolated.

(continued)

Brunswick Unit 1 B 3.6-76 Revision No.

SCIDs B 3.6.4.2 BASES ACTIONS A.1 and A.2 (continued)

Required Action A.2 is modified by a Note that applies to devices located in high radiation areas and allows them to be verified closed.by use of administrative controls.

Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment, once they have been verified to be in the proper position, is low.

E.d With two SCIDs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that meet this criterion are a closed and de-activated automatic damper, a closed manual damper, and a blind flange. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to isolate the penetration and

,O. the probability of a DBA, which requires the SCIDs to close, occurring during this short time, is very low.

The Condition has been modified by a Note stating that I Condition B is only applicable to penetration flow paths with two isolation dampers. This clarifies that only Condition A is entered if one SCID is inoperable in each of two penetrations.

I C.1 and C.2' l If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant 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.

(continued)

O Brunswick Unit 1 B 3.6-77 Revision No.

SCIDs B 3.6.4.2 BASES ACTIONS D.1. D.2. and D.3 (continued)

If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LCO does not apply. If applicable, CORE ALTERATIONS and the movement of irradiated fuel assemblies in the secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to'a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release.

Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action D.1 has been modified by a Note stating that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0.3 would not specify any action. If moving fuel while in I MODE 1, 2, or 3, the fuel movement is' independent of reactor operations. Therefore, in either case, inability to suspend l movement of irradiated fuel assemblies would not be a O

1 sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.2.1 REQUIREMENTS Verifying that the isolation time of each automatic SCID is g

within limits, by cycling each SCID through one complete cycle of full travel and measuring the isolation time, is required to demonstrate OPERABILITY. The isolation time test ensures that the SCID will isolate in the required time period. The Frequency of this SR is once per 24 months.

Operating experience has demonstrated these components will usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. ,

SR 3.6.4.2.2

-Verifying that each automatic SCID closes on a secondary containment isolation signal is required to minimize leakage of radioactive material from secondary containment following (continued)

O Brunswick Unit 1 B 3.6-78 Revision No.

E SCIDs B 3.6.4.2 h BASES SURVEILLANCE SR 3.6.4.2.2 (continued)

REQUIREMENTS a DBA or uther accidents. This SR ensures that each automatic SCID will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST :n LC0 3.3.6.2, " Secondary Containment.

Isolation Instrumentation," overlaps this SR to provide i

complete testing of the safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance j were performed with the reactor at power. Operating experience has demonstrated these components will usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be i acceptable from a reliability standpoint.

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

2. UFSAR, Section 15.6.4.

3. UFSAR, Section 15.7.1.

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

5. Technical Requirements Manual.

l l

l O

Brunswick Unit 1 B 3.6-79 Revision No.

SGT System B 3.6.4.3 8 3.6 CONTAINMENT SYSTEMS B 3.6.4.3 Standby Gas Treatment (SGT) System BASES BACKGROUND The function of the SGT System is to ensure that the release of radioactive materials that leak from the primary containment into the secondary containment following a Design Basis Accident (DBA) is minimized by filtration and adsorption prior to exhausting to the environment.

The SGT System consists of a suction duct, two parallel and independent filter trains'with associated blowers, valves and controls, and a discharge vent.

Each filter train consists of (components listed in order of the direction.of the air flow):

a. A moisture separator;

b. An electric heater;

c. A prefilter;

d. A high efficiency particulate air (HEPA) filter;

e. Two in-line charcoal adsorber beds;

f. A second HEPA filter; and

g. A centrifugal fan.

The SGT System is designed to restore and maintain secondary containment at a negative pressure of at least 0.25 inches water gauge relative to the atmosphere following a secondary containment isolation signal- Maintaining this negative pressure is based on a SGT System flow rate of at least 3000 cfm. A secondary containment negative pressure of 0.25 inches water gauge minimizes the release of radioactivity from secondary containment by ensuring primary containment leakage is treated prior to release.

The moisture separator is provided to remove entrained water

-in the air, while the electric heater reduces the relative humidity of the airstream to less than 70% (Ref. 1). The prefilter removes large particulate matter, while the HEPA (continued)

Brunswick Unit 1 B 3.6-80 Revision No.

SGT System B 3.6.4.3 O BASES BACKGROUND filter removes fine particulate matter and protects the (continued) charcoal from fouling. The charcoal adsorber beds remove gaseous elemental iodine and organic iodides, and the final HEPA filter collects any carbon fines exhausted from the charcoal adsorber.

The SGT System automatically starts and operates in response to actuation signals indicative of conditions or an accident that could require operation of the system. Following an initiation signal, both SGT charcoal filter train fans start.

APPLICABLE The design basis for the SGT System is to mitigate the SAFETY ANALYSES consequences of a loss of coolant accident and fuel handling accidents (Refs. 2, 3, and 4). For all events analyzed, the SGT System is shown to be automatically initiated to reduce, via filtration and adsorption, the radioactive material released to the environment.

The SGT System satisfies Criterion 3 of Reference 5.

LC0 Following a DBA, a minimum of one SGT subsystem is required to maintain the secondary containment at a negative pressure with respect to the environment and to process gaseous releases. Meeting the LC0 requirements for two OPERABLE subsystems ensures operation of at least one SGT subsystem in the event of a single active failure.

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product releaso to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System in OPERABLE status is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (0PDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.

(continued)

O ,

l Brunswick Unit 1 B 3.6-81 Revision No. l

)

SGT System B 3.6.4.3

.O BASES (continued)

ACTIONS Ad With one SGT subsystem inoperable in MODE 1, 2, or 3, the inoperable subsystem must be restored to OPERABLE status in l 7 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the l'

OPERABLE subsystem could result in the radioactivity release control function not being. adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a DBA occurring during this period.

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

L1 i With one SGT subsystem inoperable during movement of l irradiated fuel cssemblies in secondary containment, during CORE ALTERATIONS, or during OPDRVs, the inoperable subsystem must be restored to OPERABLE status in 31 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function.- However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 31 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the probability and consequences of an event requiring the radioactivity release control function during this period.

(continued)

~

O Brunswick Unit 1 B 3.6-82 Revision No.

l SGT System B 3.6.4.3

'O l

sasts ACTIONS D.I. D.2.1. 0.2.2. and D.2.3 (continued)

During movement of irradiated fuel assemblies, in the-secondary containment, during CORE ALTERATIONS, or during OPDRVs, when Required Action C.1 canriot be completed within the required Completion Time, the OPERABLE SGT subsystem should immediately be placed in operation. This action ensures that the remaining subsystem is OPERABLE, that'no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.

L i

An alternative to Required Action D.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk. If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies must immediately be suspended. Suspension of these activities must not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in i

order to minimize the probability of a vessel draindown and l subsequent potential for fission product release. Actions l must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable in N0DE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D have been modified by a Note stating that LC0 3.0.3 is not applicable. If moving

! irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0.3

! would not specify any action. If moving irradiated fuel l assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either

l. case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a l reactor shutdown.

l E.1. E.2. and E.3 1 When two SGT subsystems are inoperable, if applicable, CORE l

ALTERATIONS and movement of irradiated fuel assemblies in secondary containment must immediately be suspended.

Suspension of these activities shall not preclude completion 1 of movement of a component to a safe position. Also, if )

(continued)

O Brunswick Unit 1 B 3.6-83 Revision No.

l

i SGT Systen B 3.6.4.3 O BASES

)

ACTIONS E.1. E.2. and E.3 (continued) applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action E.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem, by initiating (from the tO control room) flow through the HEPA filters and charcoal adsorbers, for a 10 continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on automatic /A control for 210 continuous hours every 31 days eliminates a moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is ,

performed in accordance with the Ventilation Filter Testing i Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6), except as n specified in Specification 5.5.7, " Ventilation Filter QA Testing Program (VFTP)". The VFTP includes testing HEPA (continued)

O Brunswick Unit 1 B 3.6-84 Revision No.

SGT System B 3.6.4.3 O BASES-i SURVEILLANCE SR 3.6.4.3.2 (continued)

REQUIREMENTS filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (geaeral use and following specific operations). Specifir. test frequencies and additional information are disctssed in detail in the VFTP.

SR '3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. While this Surveillance can'be performed with the reactor at power, operating experience has demonstrated that these components will usually pass the Surveillance when performed at the 24 month Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, " Secondary Containment Isolation Instrumentation," 'overlaps this SR to provide complete testing of the safety function. Therefore,.the Frequency was found to be acceptable from a reliability standpoint.

O REFERENCES 1. uFSAR Section 6.5.1.

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

3. UFSAR Section 15.6.4.

i

4. UFSAR Section 15.7.1. !

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

6. Regulatory Guide 1.52, Revision 1. b I

O Brunswick Unit 1 B 3.6-85 Revision No.

F

]

CAD System 3.6.3.2

)

3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System l

LC0 3.6.3.2 CAD System shall be OPERABLE.

t APPLICABILITY: MODE.1 during the time period:

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

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to < 15% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CAD System inoperable. A.1 --------NOTE---------

LCO 3.0.4 is not ;

Restore CAD System to 31 days OPERABLE status.

B. Required Action and C.1 Be in MODE 2. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months associated Completion Time not met.

l O !

Brunswick Unit 2 3.6-27 Amendment No.

I i

CAD System 3.6.3.2 i

O suavoit'^ ace accurataea's SURVEILLANCE FREQUENCY l

SR 3.6.3.2.1 Verify 2: 4350 gal of liquid nitrogen are 31 days j contained in the CAD System.

SR 3.6.3.2.2 Verify each CAD subsystem manual, power 31 days operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct. position or can be aligned to the correct position.

l SR 3.6.3.2.3 Cycle each power operated, excluding 24 months automatic, valve in the flow path through one complete cycle.

!D b

'V SR 3.6.3.2.4 -------------------NOTE------------------

, Failure to meet this SR does not render the CAD System inoperable. Enter applicable Condition and Required Actions I

of LCO 3.6.1.3, " Primary Containment Isolation Valves (PCIVs)," in the event of failure to meet this SR.

l Verify each automatic valve in the flow 24 months path actuates to the isolation position l on an actual or simulated isolation signal.

l O

Brunswick Unit 2 3.6-28 Amendment No.

l L-___--___----_-____-___--__ _

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

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

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

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

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Secondary containment C.1 --------NOTE---------

inoperable during LCO 3.0.3 is not movement of irradiated applicable.

fuel assemblies in the ---------------------

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

AND (continued)

Brunswick Unit 2 3.6-29 Amendment No.

Sscondary Containment 3.6.4.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) 0.2 Suspend CORE Immediately ALTERATIONS.

O C.3 Initiate action to Immediately l suspend OPDRVs.

L i

SURVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY l SR 3.6.4.1.1 Verify all secondary containment 24 months j equipment hatches are closed and sealed.

LO SR 3.6.4.1.2 Verify one secondary containment access 24 months b door is closed in each access opening.

SR 3.6.4.1.3 Verify each SGT subsystem can maintain 24 months on a m 0.25 inch of vacuum water gauge in the STAGGERED TEST secondary containment for I hour at a BASIS flow rate s 3000 cfm.

I l !

l l !

l l 0

Brunswick Unit 2 3.6-30 Amendment No.

SCIDs 3.6.4.2~

O 2.6 CONTAiNNENT SvSTENS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)

LCO 3.6.4.2 Each SCID shall be OPERABLE.

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

ACTIONS -

NOTES------------------------------------

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made O- inoperable by SCIDs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or.more A.I Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months penetration flow paths penetration flow path with one SCID by use of at least inoperable. . one closed and i de-activated automatic damper, l closed manual damper, or blind flange.

.MQ (continued) l O

Brunswick' Unit 2 3.6-31 Amendment No.

1 SCIDs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

)

A. (continued) A.2 --------NOTE---------

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 92 days penetration flow path is isolated.

B. ---------NOTE--------- B.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path penetration flow paths by use of at least with two isolation one closed and dampers. de-activated

automatic damper,

<Ci closed manual damper, V One or more or blind flange.

penetration flow paths with two SCIDs )

inoperable.

l

)

i C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND

or B not met in i MODE I, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Brunswick Unit 2 3.6-32 Amendment No.

SCIDs 3.6.4.2 l

O AC110NS (centinued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.I --------NOTE---------

associated Completion LC0 3.0.3 is not Time of Condition A applicable.

or B not met during ---------------------

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

AND D.2 Suspend CORE Immediately ALTERATIONS.

AND 0.3 Initiate action to Immediately suspend OPDRVs.

O 1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 Verify the isolation time of each 24 months automatic SCID is within limits.

SR 3.6.4.2.2 Verify each automatic SCID actuates to 24 months the isolation position on an actual or simulated actuation signal.

n IU l

Brunswick Unit 2 3.6-33 Amendment No.

SGT System 3.6.4.3 l

O 3.6 CON m N- NT SvSuMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITv: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, 1 During operations with a potential for draining the reactor j vessel (OPDRVs). l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I

A. One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable in MODE 1, to OPERABLE status.

2 or 3.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A 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 98

, Two SGT subsystems inoperable in MODE 1, 2, or 3.

j (continued)

I O

Brunswick Unit 2 3.6-34 Amendment No.

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One SGT subsystem C.I Restore SGT subsystem 31 days inoperable during to OPERABLE status.

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

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

associated Completion LCO 3.0.3 is not applicable.

Time of Condition C ----------------------------

noi met.

D.1 Place OPERABLE SGT Immediately subsystem in operation.

QB' D.2.1 Suspend movement of Immediately i irradiated fuel I assemblies in secondary containment.

AND -

j D.2.2 Suspend CORE Immediately ALTERATIONS.

O j D.2.3 Initiate action to Immediately suspend OPDRVs.

l (continued) '

i O

Brunswick Unit 2 3.6-35 Amendment No.

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two SGT subsystems E.1 --------NOTE--------

inoperable during LC0 3.0.3 is not movement of irradiated applicable.

fuel assemblies in the --------------------

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

AND E.2 Suspend CORE Immediately ALTERATIONS.

AND l E.3 Initiate action to Immediately l

suspend OPDRVs.

O V ;

l i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for a: 10 31 days continuous hours with heaters operating.

SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

i SR 3.6.4.3.3 Verify each SGT subsystem actuates on an 24 months actual or simulated initiation signal.

v)

Brunswick Unit 2 3.6-36 Amendment No.

l

Prinary Containment Oxygen Concentration B 3.6.3.1 (3

V B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1 Primary Containment Oxygen Concentration l

BASES i

l BACKGROUND The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration < 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containt.sent for any hydrogen concentration. The capability to inert the primary containment and maintain oxygen

< 4.0 v/o works together with the Containment Atmosphere Dilution System (LCO 3.6.3.2, " Containment Atmosphere Dilution (CAD) System") to provide redundant and diverse g methods to mitigate events that produce hydrogen and oxygen.

For example, an event that rapidly generates hydrogen from zirconium metal water reaction could result in excessive hydrogen in primary containment, but oxygen concentration A will remain < 5.0 v/o and no combustion can occur. Long term generation of both hydrogen and oxygen from radiolytic U decomposition of water may eventually result in a combustible mixture in primary containment if the initial ,

primary containment oxygen concentration exceeded 4.0 v/o l during operation in the applicable conditions. This LC0 !

ensures that oxygen concentration does not exceed 4.0 v/o during operation in the applicable conditions.

APPLICABLE SAFETY ANALYSES The Reference 1 calculations assume that the primary containment is inerted when a Design Basis Accident (DBA) b loss of coolant accident occurs. Thus, the hydrogen assumed l to be released to the primary containment as a result of '

metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment.

Oxygen, which is subsequently generated by radiolytic decomposition of water, is diluted by the CAD System more g

rapidly than it is produced.

l Primary containment oxygen concentration satisfies Criterion 2 of Reference 2.

1 (continued) l O

Brunswick Unit 2 B 3.6-60 Revision No.

i l

Primary Containment Oxygen Concentration B 3.6.3.1 BASES (continued)

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible j mixture inside primary containment.

APPLICABILITY The primary cordainment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and

shutdown addressed below. The primary containment must be I

inert in MODE 1, since this is the condition with the l highest probability of an event that could produce hydrogen and oxygen.

l

' Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible during a i

scheduled power reduction to s 15% RTP. As long as reactor power is s 15% RTP, the potential for an event that generates significant hydrogen and oxygen is low and the

VG primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a scheduled power reduction s 15% RTP, is low enough that these " windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

ACTIONS A_d If oxygen concentration is a 4.0 v/o at any time while operating in MODE 1, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is allowed when oxygen concentration is a 4.0 v/o because of the availability of other hydrogen and oxygen mitigating systems (e.g., Containment Atmosphere Dilution System) and the low probability and long duration of an event that would generate significant amounts of I l hydrogen and oxygen occurring during this period.

l (continued)

Brunswick Unit 2 B 3.6-61 Revision No.

Primary Containment Oxygen Concentration ,

B 3.6.3.1 l BASES l

ACTIONS L1 (continued) l If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, power must be reduced to s 15% RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without I

challenging plant systems.

SURVEILLANCE SR 3.6.3.1.1 REQUIREMENTS The primary containment must be determined to be inerted by verifying that oxygen concentration is < 4.0 v/o. The 7 day Frequency is based on the slow rate at which oxygen concentration can change and on other indications of abnormal conditions (which would lead to more frequent l checking by operators in accordance with plant procedures).

Also, this Frequency has been shown to be acceptable through operating experience.

pd REFERENCES 1. UFSAR, Section 6.2.5.

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

l fO Brunswick Unit 2 B 3.6-62 Revision No.

l CAD System B 3.6.3.2 8 3.6 CONTAINMENT SYSTEMS B 3.6.3.2 Containment Atmosphere Dilution (CAD) System BASES BACKGROUND The CAD System functions to maintain combustible gas concentrat. tons within the primary containment at or below the flammability limits following a postulated loss of )

coolant accident (LOCA) by diluting hydrogen and oxygen with l nitrogen. To ensure that a combustible gas mixture does not i occur, oxygen concentration is kept < 5.0 volume percent (v/o).

The CAD System is manually initiated and consists of two 100% capacity subsystems. Each subsystem consists of a common liquid nitrogen supply tank, an electric vaporizer, and connected piping to supply the drywell and suppression chamber volumes. The liquid nitrogen supply tank and electric vaporizers are common components which are shared between the CAD subsystems of the two units. Piping from the liquid nitrogen. supply tank downstream of the vaporizers is split and routed to each unit. Each pipe to a particular

( unit is divided to provide the capability to supply ultrogen to both the drywell and the suppressicn chamber. The nitrogen storage tank contains a: 4350 gal, which is adequate for 30 days of CAD subsystem operation.

The CAD System operates in conjunction with emergency operating procedures that are used to reduce primary '

1 containment pressure periodically during CAD System operation. This combination results in a feed and bleed approach to maintaining hydrogen and oxygen concentrations below combustible levels.

APPLICABLE To evaluate the potential for hydrogen and oxygen l SAFETY ANALYSES accumulation in primary containment following a LOCA, hydrogen and oxygen generation is calculated (as a function of time following the initiation of the accident). The ;

assumptions stated in Reference 1 are used to maximize the '

amount of hydrogen and oxygen generated. The calculation confirms that when the mitigating systems are actuated in accordance with emergency operating procedures, the peak oxygen concentration in primary containment is < 5.0 v/o !

(Ref. 2).

(continued)

V Brunswick Unit 2 B 3.6-63 Revision No.

l I

CAD System '

B 3.6.3.2 BASES APPLICABLE Hydrogen'and oxygen may accumulate within primary SAFETY ANALYSES containment following a LOCA as a result of:

(continued)

a. A metal water reaction between the zirconium fuel rod cladding and the reactor coolant; or i

b. Radiolytic decomposition of water in the Reactor Coolant System.

The CAD System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref.3).

LCO The CAD System (two CAD subsystems) must be OPEPABLE with an OPERABLE flow path capable of supplying nitrogen to the drywell. This ensures operation of at least_one CAD subsystem in the event of a worst case single active failure. Operation of at least one CAD subsystem is designed to maintain primary containment post-LOCA oxygen concentration < 5.0 v/o for 30 days.

APPLICABILITY In MODE 1 when primary containment oxygen concentration is b L required to be < 4.0 v/o (i.e., primary containment inerted) in accordance with LCO 3.6.3.1, " Primary Containment Oxygen t

Concentration," the CAD System is required to maintain the

! oxygen concentration within primary containment below the i flammability limit of 5.0 v/o following a LOCA. This

ensures that the relative leak tightness of primary-

containment is adequate and prevents damage-to safety i related equipment and instruments located within primary containment.

In MODE 1, when primary containment oxygen concentration is l: not required to be <'4.0 v/o in accordance with LCO 3.6.3.1,

! " Primary Containment Oxygen Concentration," and in MODE 2, l the potential for an event that generates significant i- hydrogen and oxygen is low, the primary containment need not be inert, and the CAD System is not required to be OPERABLE.

Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a scheduled power reduction < 15% RTP (i.e., when primary containment oxygen concentration is not required to be < 4.0 v/o in accordance with LCO 3.6.3.1), is low enough that these " windows," when the primary containment is not inerted and the CAD System is not required to be OPERABLE, are also justified.

(continued)

Brunswick Unit 2 B 3.6-64 Revision No.

, 1 l l CAD System B 3.6.3.2 l

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

In MODES 4 and 5, the probability and consequences of a LOCA l are reduced due to the pressure and temperature limitations !

of these MODES. Therefore, the CAD System is not required i to be OPERABLE in MODES 4 and 5. I l

l ACTIONS Ad If the CAD System (one or both subsystems) is inopt aable, it must be restored to OPERABLE status within 31 days. In this Condition, the oxygen control function of the CAD System is pd lost. However, alternate oxygen control capabilities may be provided by the Containment Inerting System. The 31 day Completion Time is based on the low probability of the & ,

occurrence of a LOCA that would generate hydrogen and oxygen l in amounts capable of exceeding the flamability limit, the amount of time available after the event for operator action '

to prevent exceeding this limit, and the availability of '

other hydrogen mitigating systems.

Required Action A.1 has been modified by a Note that indicates that the provisions of LCO 3.0.4 are not applicable. As a result, a MODE change is allowed when the CAD System (one or both subsystems) is inoperable. This allowance is provided because of the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flamability limit, the amount of time available after a postulated LOCA for operator action to prevent exceeding the flamability limit, and the availability of other hydrogen mitigating systems.

(continued)

Brunswick Unit 2 B 3.6-65 Revision No.

CAD System 8 3.6.3.2 iO 8ASES ACTIONS Rd (continued) l If Required Action A.1 cannot be met within the associated l Completion Time, thi plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging l plant systems.

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS Verifying that there is 2: 4350 gal of liquid nitrogen supply in the CAD System will ensure at least 30 days of post-LOCA l CAD operation. This minimum volume of liquid nitrogen allows sufficient time after an accident to replenish the nitrogen supply for long term inerting. This is verified every 31 days to ensure that the system is capable of performing its intended function when required. The 31 day Frequency is based on operating experience, which has shown 31 days to be an acceptable period to verify the liquid g L nitrogen supply and on the availability of other hydrogen mitigating systems.

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

A valve is also allowed to be in the nonaccident position ,

provided it can be aligned to the accident position within !

the time assumed in the accident analysis. This is acceptable because the CAD System is manually initiated.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR i does not require any testing or valve manipulation; rather,

! it involves verification that those valves capable of being mispositioned are in the correct position.

(continued)

O Brunswick Unit 2 B 3.6-66 Revision No.

CAD System B 3.6.3.2 BASES SURVEILLANCE SR 3.6.3.2.2 (continued)

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

SR 3.6.3.2.5 4 Cycling each power operated valve, excluding automatic valves, in the CAD System flow path through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required.

While this Surveillance may be performed with the reactor at power, the 24 month Frequency of the Surveillance is intended to be consistent with expected fuel cycle lengths.

Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable.from a reliability standpoint.

A u b SR 3.6.3.2.4 On Group 2 and 6 primary containment isolation signals, automatic valves in the CAD System flow path close to prevent leakage of radioactive material from primary containment following a design basis accident. The automatic valves in the CAD System flow path that close on Group 2 and 6 primary containment isolation signals are primary containment isolation valves (PCIVs) as identified in UFSAR Table 6.2.4-1 (Ref. 4). This SR ensures that each automatic PCIV in the CAD System will actuate to its isolation position on the associated Group 2 and 6 primary containment isolation signals. The LOGIC SYSTEM FUNCTIONAL TEST in LC0 3.3.6.1, " Primary Ccntainment Isolation Instrumentation," overlaps this M to provide complete testing of the safety function. W e 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency.

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

(continued)

O Brunswick Unit 2 B 3.6-67 Revision No.

l l

CAD System B 3.6.3.2 BASES SURVEILLANCE SR 3.6.3.2.4 (continued)

REQUIREMENTS This SR is modified by a Note indicating that failure to meet SR 3.6.3.2.4 does not affect the OPERABILITY of the CAD System. As such, when the CAD System liquid nitrogen supply )

tank, valves, and piping are OPERABLE such that an OPERABLE I flow path is available to supply nitrogen to the drywell, '

but one or more PCIVs in the CAD System will not actuate to isolate the CAD System flow path from the primary containment in response to a simulated or actual primary containment isolation signal, the CAD System is still OPERABLE. To ensure the ACTIONS of LC0 3.6.1.3, " Primary Containment Isolation Valves (PCIVs)," are entered when the i ability to isolate the CAD System flow path from the primary I containment in response to a primary containment isolation signal is lost, the Note to SR 3.6.3.2.4 also indicates that failure to meet SR 3.6.3.2.4 requires the ACTIONS for LC0 3.6.1.3 to be immediately entered. The ACTIONS of LCO 3.6.1.3 provide the appropriate restrictions for one or g

more inoperable PCIVs.

REFERENCES 1. Safety Guide 7, March 1971.

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

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

4. UFSAR, Table 6.2.4-1.

O Brunswick Unit 2 B 3.6-68 Revision No.

Secondary Containment B 3.6.4.1 i B 3.6 CONTAINMENT SYSTEMS B 3.6.4.1 Secondary Containment BASES BACKGROUND The function of the secondary containment is to contain and hold up fission products that may leak from primary containment following a Design Basis Accident (DBA). In conjunction with operation of the Standby Gas Treatment (SGT) System and closure of certain valves whose lines penetrate the secondary containment, the secondary l containment is designed to reduce the activity level of the fission products prior to release to the environment and to isolate and contain fission products that are released during certain operations that take place inside primary containment, when primary containment is not required to be OPERABLE, or that take place outside primary containment.

The secondary containment is a structure that completely encloses the primary containment and those components that may be postulated to contain primary system fluid. This structure forms a control volume that serves to hold up the

% fission products. It is possible fc 'he pressure in the l ,

control volume to rise relative to tne environmental pressure. To prevent ground level exfiltration while allowing the secondary containment to be designed as a conventional structure, the secondary containment requires support systems to maintain the control volume pressure at less than the external pressure. Requirements for these systems are specified separately in LC0 3.6.4.2, " Secondary Containment Isolation Dampers (SCIDs)," and LCO 3.6.4.3,

" Standby. Gas Treatment (SGT) System."

APPLICABLE There are two. principal accidents for.which credit is taken SAFETY ANALYSES for secondary containment OPERABILITY. These are a loss of coolant accident (LOCA) (Refs. I and 2) and a fuel handling accident inside secondary containment (Refs. I and 3). The secondary containment performs no active function in response to each of these limiting events; however, its leak tightness is required to ensure that fission products entrapped within the secondary containment structure will be treated by the SGT System prior to discharge to the environment.

Secondary containment satisfies Criterion 3 of Reference 4.

(continued) l Brunswick Unit 2 B 3.6-69 Revision No.

Secondary Containment B 3.6.4.1 BASES (continued) i LCO An OPERABLE secondary containment provides a control volume into which fission products that leak from primary containment, or are released from the reactor coolant i pressure boundary components or irradiated fuel assemblies located in secondary containment, can be processed prior to release to the environment. For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained, at least one door in each access to the Reactor Building must be closed, and the sealing mechanism associated with each penetration (e.g., welds, bellows, or 0-rings) must be OPERABLE'.

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and conseq- ;es of the LOCA are reduced due to the pressure and temp ature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4

, or 5 to ensure a control volume, except for other situations i for which significant releases of radioactive material can be postulated, such as during operations with a potential

for draining the reactor vessel (OPDRVs), during CORE i

ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.

1 I

ACTIONS Ad

If secondary containment is inoperable, it must be restored

! to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion

, Time provides a period of time to correct the problem that

! is commensurate with the importance of maintaining secondary l containment during MODES 1, 2, and 3. This time period also

! ensures that the probability of an accident (requiring

! secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

(continued)

O Brunswick Unit 2 B 3.6-70 Revision No.

Secondary Containment B 3.6.4.1 BASES ACTIONS B.1 and B.2 (continued)

If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. 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.

C.I. C.2. and C.3 Movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, and OPDRVs can be postulated to cause fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the environment. CORE ALTERATIONS and movement of irradiated fuel assemblies must be immediately suspended if the secondary containment is operable. Suspension of these activities shall not preclude completing an action that l involves moving a component to a safe position. Also, i action must be immediately initiated to suspend OPDRVs to i minimize the probability of a vessel draindown and '

subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, !

2, or 3, Required Action C.1 has been modified by a Note i stating that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a <

reactor shutdown.

(coidinued) l O

Brunswick Unit 2 B 3.6-71 Rev.ision No.

j

o l

Secondary Containment B 3.6.4.1 O 8ASES (continued)

! SURVEILLANCE SR 3.6.4.1.1 and.SR 3.6.4.1.2 l REQUIREMENTS l

Verifying that secondary containment equipment hatches and one secondary containment access door in each access opening are closed ensures that the infiltration of outside air of such magnitude as to prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur.

In this application, the term " sealed" has no connotation of leak tightness. Maintaining secondary containment OPERABILITY r6 quires verifying one door in each access g '

opening is closed. The 24 month Frequency for these SRs has been shown to be adequate, based on operating experience, and is considered adequate in view of other indications of door and hatch status that are available to the operator.

1 SR 3.6.4.1.3 The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment. !

(

To ensure that fission products are treated, SR 3.6.4.1.3 verifies that the SGT System will establish and maintain a b

negative pressure in the secondary containment. This is confirmed by demonstrating that one SGT subsystem can maintain 2: 0.25 inches of vacuum water gauge for I hour at a flow rate s 3000 cfm. The I hour test period allows secondary containment to be in thermal equilibrium' at steady state conditions. Therefore, this test is used to ensure secondary containment boundary integrity. Since this SR is a secondary containment test, it need not be performed with each SGT subsystem. The SGT subsystems are tested on a STAGGERED TEST BASIS, however, to ensure that in addition to the requirements of LC0 3.6.4.3, either SGT subsystem will perform this test. Operating experience has demonstrated these components will usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

(continued)

(3 V

Brunswick Unit 2 B 3.6-72 Revision No.

Secondary Containment' B 3.6.4.1 l

I O BASES < continued >

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

2. UFSAR, Section 15.6.4.

3. UFSAR, Section 15.7.1.

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

O i

t O

Brunswick Unit 2 B 3.6-73 Revision No.

SCIDs

, B 3.6.4.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs)

BASES

~

BACKGROUND The function of the SCIDs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis j Accidents (DBAs) (Refs. 1, 2, and 3). Secondary containment '

isolation within the time limits specified for those isolation dampers designed to close automatically ensures that fission products that leak from primary containment following a DBA, or that are released during certain operations when primary containment is'not required to be OPERABLE or take place outside primary containment, are maintained within the secondary containment boundary.

The OPERABILITY requirements for SCIDs help ensure that an adequate secondary containment boundary is maintained during and after an accident by minimizing potential patns to the environment. These isolation devices consist of active !

(automatic) devices. i l]

i. - - Automatic SCIDs close on a secondary containment isolation signal to establish a boundary for untreated radioactive material within secondary containment following a DBA or I other accidents.

APPLICABLE The SCIDs must be OPERABLE to ensure the secondary SAFETY ANALYSES containment barrier to fission product releases is established. The principal accidents for which the '

secondary containment boundary is required are a loss of coolant accident (Refs. I and 2) and a fuel handling accident inside secondary containment (Refs. I and 3). The secondary containment performs no active function in response to either of these limiting events, but the boundary established by SCIDs is required to ensure that leakage from the primary containment is processed by the Standby Gas Treatment (SGT) System before being released to the environment.

(continuedl O

~ Brunswick Unit 2 B 3.6-74 Revision No.

I<

l i

SCIDs L B 3.6.4.2 O .ASES APPLICABLE Maintaining SCIDs OPERABLE with isolation times within l SAFETY ANALYSES limits ensures that fission products will remain trapped (continued) inside secondary containment so that they can be treated by the SGT System prior to discharge to the environment.

l SCIDs satisfy Criterion 3 of Reference 4..

LCO SCIDs fom a part of the secondary containment boundary.

The SCID safety function is related to control of offsite radiation releases resulting from DBAs.

The isolation dampers are considered OPERABLE when their associated accumulators are pressurized,'their isolation b

, times are within limits, and the dampers are capable of actuating on an automatic isolation signal. The dampers covered by this LCO, along with their associated stroke times, are listed in Reference 5.

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product release to the primary containment that leaks to the

V n secondary containment. Therefore, the OPERABILITY of SCIDs is required.

In MODES 4 and 5, the probability and consequences of these events are reduced due to pressure and temperature limitations in these MODES.. Therefore, maintaining SCIDs OPERABLE is not required in MODE 4 or 5, except for other situations under which significant radioactive releases can be postulated, such as_ during operations with a potential for draining the reactor vessel (OPDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES 1, 2, and 3.

ACTIONS The ACTIONS are modified by three Notes. The first Note allows penetration flow paths to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator, who is in continuous communication with the control room, at the controls of the isolation device. In this way, the penetration can be rapidly isolated when a need for secondary containment isolation is indicated.

(continued)

O ^

V Brunswick Unit 2 8 3.6-75 Revision No.

SCIDs B 3.6.4.2 ;

BASES ACTIONS The second Note provides clarification that for the purpose (continued) of this LCO separate. Condition entry is allowed for each i penetration flow path. This is acceptable, since the !

Required Actions for each Condition provide appropriate ,

compensatory actions for each inoperable SCID. Complying '

with the Required Actions may allow for continued operation, and subsequent inoperable SCIDs are governed by subsequent Condition entry and application of associated Required Actions, ]

i i

The third Note ensures appropriate remedial actions are !

taken, if necessary, if the affected system (s) are rendered inoperable by an inoperable SCID.

A.1 and A.2 In the event that there are one or more penetration flow paths with one SCID. inoperable, the affected penetration flow path (s) must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

'A Isolation barriers that meet this criterion are a closed and U de-activated automatic SCID, a closed manual damper, and a -

blind flange. For penetrations isolated in accordanco with-Required Action A.1, the device used to isolate the penetration should be the closest available device to secondary containment. The Required Action must be completed within the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time. The specified time period is reasonable considering the time required to isolate the penetration, and the probability of a DBA, which 1 requires the SCIDs to close, occurring during this short time is very low.

For affected penetrations that have been isolated in !

accordance with Required Action A.1, the affected penetration must be verified to be isolated on a periodic basis. This is necessary to ensure that secondary containment penetrations required to be isolated following an accident, but no longer capable of being automatically isolated, will be in the isolation position should an event occur. The Completion Time of once per 92 days is i appropriate because the devices are operated under administrative controls and the probability of their misalignment is low. This Required Action does not require any testing or device manipulation. Rather, it involves verification that the affected penetration remains isolated.

(continued) 1 Brunswick Unit 2 B 3.6-76 Revision No. i i

SCIDs B 3.6.4.2.

O BASES ACTIONS A.1 and A.2 (continued)

Required Action A.2 is modified by a Note that applies to devices located in high radiation areas and allows them to be verified closed by use of administrative controls.

Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment, once they have been verified to be in the proper position, is low.

I.d With two SCIDs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that meet this criterion are a closed and de-activated automatic damper, a closed manual' damper, and a blind flange. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable considering the time required to isolate the penetration and the probability of a DBA, which requires the SCIDs to close, occurring during this short time, is very low.

The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation dampers. This clarifies that only Condition A is entered if one SCID is inoperable in each of ;

two penetrations.

C.1 and C.2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a l MODE in which the LCO does not apply. To achieve this i status, the plant must be brought to at least MODE 3 within I 12 eours and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed i Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued) j O ;

i Brunswick Unit 2 B 3.6-77 Revision No. .

J

r l

l SCIDs B 3.6.4.2 l

l O 8:sES l ACln 'S D.1. D.2' and 0.3 l (continued)

If any Required Action and associated Completion Time are ;

not met, the plant must be placed in a condition in which the LCO does not apply. If applicable, CORE ALTERATIONS and the movement of irradiated fuel assemblies in the secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement i of a component to a safe position. Also, if applicable, i

actions must be immediately initiated to suspend OPDRVs in !

l order to minimize the probability of a vessel draindown and '

the subsequent potential for fission product release.

Actions must continue until OPDRVs are suspended.

l LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement'can occur in MODE 1, l 2, or 3, Required Action D.1 has been modified by a Note stating that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5 LC0 3.0.3 would not specify any action. If moving fuel while in MODE 1, 2, or 3, the fuel movement is independent of reactor

, , operations. Therefore, in either case, inability to suspend lO movement of irradiated fuel assemblies would not be a

! sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.2.1 l REQUIREMENTS b

Verifying that the isolation time of each automatic SCID is within limits, by cycling eacn SCID through one complete cycle of full travel and measuring the isolation time, is required to demonstrate OPERABILITY. The isolation time .

test ensures that the SCID will isolate in the required time )

period. The Frequency of this SR is once per 24 months.

Operating experience has demonstrated these components will usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be l acceptable from a reliability standpoint.

SR 3.6.4.2.2

, Verifying that each automatic SCID closes on a secondary containment isolation signal is required to minimize leakage of radioactive material from secondary containment following (continued)

Brunswick Unit 2 B 3.6-78 Revision No. I i

SCIDs B 3.6.4.2 l

O BASES SURVEILLANCE SR 3.6.4.2.2-(continued)

REQUIREMENTS I a DBA or other accidents. This SR ensures that each

! automatic SCID will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST.in LCO 3.3.6.2, " Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance

< were performed with the reactor.at power. Operating l experience has demonstrated these components will usually l pass the Surveillance when performed at the ?.4 month l Frequency. Therefore, the Frequency was concluded to be i acceptable from a reliability standpoint.

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

G 2. UFSAR, Section 15.6.4.

U

3. UFSAR, Section 15.7,1.

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

5. Technical Requirements Manual.

O Brunswick Unit 2 B 3.6-79 Revision No.

SGT System B 3.6.4.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.4.3 Standby Gas Treatment (SGT) System BASES BACKGROUND The fundion of the SGT System is to ensure that the release of radioactive materials that leak from the primary containment into the secondary containment following a Design Basis Accident (DBA) is minimized by filtration and adsorption prior to exhausting to the environment.

The SGT System consists of a suction duct, tuo parallel and independent filter trains with associated blowers, valves and controls, and a discharge vent.

Each filter train consists of (components listed in order of the direction of the air flow):

a. A moisture separator;

b. An electric heater;

c. A prefilter; (G3

d. A high efficiency particulate air (HEPA) filter;

e. Two in-line charcoal adsorber beds;

f. A second HEPA filter; and

g. A centrifugal fan.

The SGT System is designed to restore and maintain secondary containment at a negative pressure of at least 0.25 inches water gauge relative to the atmosphere following a secondary containment isolation signal. Maintaining this negative pressure is based on a SGT System flow rate of at least 3000 cfm. A secondary containment negative pressure of 0 1.5 inches water gauge minimizes the release of radioactivity from secondary containment by ensuring primary containment leakage is treated prior to release.

The moisture separator is provided to remove entrained water in the air, while t M electric heater reduces the relative humidity of the utrstream to less than 70% (Ref.1). The prefilter removes large particula- matter, while the HEPA (continued)

Brunswick Unit 2 8 3.6-80 Revision No.

SGT System B 3.6.4.3

,O sasts BACKGROUND filter removes fine particulate matter and protects the I (continued) charcoal from fouling. The charcoal adsorber beds remove gaseous elemental iodine and oraanic iodides, and the final HEPA filter collects any carbon fines exhausted from the charcoal adsorber.

The SGT System automatically starts and operates in response tc actuation signals indicative of conditions or an accident that could require operation of the system. Following an initiation signal, both SGT charcoal filter train fans start.

APPLICABLE The design basis for the SGT System is to mitigate the SAFETY ANALYSES consequences of a loss of coolant accident and fuel handling accidents (Refs. 2, 3, and 4). For all events analyzed, the SGT System is shown to be automatically initiated to reduce, via filtration and adsorption, the radioactive material released to the environment.

The SGT System satisfies Criterion 3 of Reference 5.

LCO Following a DBA, a minimum of one SGT subsystem is required to maintain the' secondary containment at a negative pressure with respect to the environment and to process gaseous releases. Meeting the LCO requirements for two OPERABLE subsystems ensures operation of at least one SGT subsystem in the event of a single active failure.

APPLICABILITY In MODES 1, 2,.and 3, a DBA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System in OPERABLE status is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during operations with. a potential for draining the reactor vessel (OPDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.

(continued)

Brunswick Unit 2 B 3.6-81 Revision No.

SGT System B 3.6.4.3 ,

BASES (continued)

ACTIONS L1 With one SGT subsystem inoperable in MODE 1, 2 or 3, the inoperable subsystem must be restored.to OPERABLE status in 7 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. Hcwever, the overall system reliability is reduced becaust a single failure in the

OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on corsideration of such factors as the avai'. ability of the OPERABLE redundant SGT subsystem and the low probability of a DBA occurring during this period.

B.1 and B.2 In MODE 1, 2, or 3, if one SGT subsystem cannot be restored to OPERABLE status within the required Completion Time or both SGT subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least p 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 v 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.

C.1 With one SGT subsystem. inoperable during movement of irradiated fuel assemblies in secondary' containment, during CORE ALTERATIONS, or during OPDRVs, the inoperable subsystem must be restored to OPERABLE status in 31 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could re'sult in the radioactivity release control function not being adequately performed. The 31 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the probability and consequences of an event requiring the radioactivity release control function during this period.

(continued)

O -

Brunswick Unit 2 B 3.6-82 Revision No.

I

SGT System B 3.6.4.3 O sases ACTIONS D.I. D.2.1. D.2.2. and D.2.3 (continued)

During movement of irradiated fuel assemblies, in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, when Required Action C.1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should immediately be placed in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk. If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies must immediately be suspended. Suspension of these activities must not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a. vessel draindown and subsequent potential for fission product release. Actions O must continue until OPDRVs are suspended.

LCO 3.0.3 is not applicable in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D have been modified by a Note stating that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

E.1. E.2, and E.3 When two SGT subsystems are inoperable, if applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in secondary containment must immediately be suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if (continued)

.O Brunswick Unit 2 B 3.6-83 Revision No.

l SGT System B 3.6.4.3 O BASES ACTIONS E.1. E.2. and E.3 (continued) applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

- LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action E.1 has been modified by a Note l stating that LCO 3.0.3 is not applicable. If moving 1 irradiated fuel assemblies while in MODE 4 or 5, LC0 3.0.3 '

would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem, by initiating (from the O control room) flow through the HEPA filters and charcoal adsorbers, for a 10 continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for l corrective action. Operation with the heaters on automatic i control for a 10 continuous hours every 31 days eliminates A ,

moisture on the adsorbers and HEPA filters. The 31 day !

Frequency was developed'in consideration of the known !

reliability of fan motors and controls and the redundancy !

available in the system. !

SR 3.6.4.3.2 4

This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6), except as /A specified in Specification 5.5.7, " Ventilation Filter C Testing Program (VFTP)". The VFTP includes testing HEPA (continued)

O - ;

Brunswick Unit 2 B 3.6-84 Revision No.

I

SGT System B 3.6.4.3 O BASES SURVEILLANCE SR 3.6.4.3.2 (continued)

REQUIREMENTS filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activatd charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. While this Surveillance can be performed with the reactor at power, operating experience has demonstrated that these components will usually pas ~s the Surveillance when performed at the 24 month Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in LC0 3.3.6.2, " Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function. Therefore, the Frequency was found to be acceptable from a reliability standpoint.

REFERENCES 1. UFSAR, Section 6.5.1.

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

3. UFSAR Section 15.6.4.

4. UFSAR.Section 15.7.1.

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

6. Regulatory Guide 1.52, Revision 1. b l !

t 1

n v

Brunswick Unit 2 B 3.6-85 Revision No.

1 Cab t ta d.7 i

A.i

'3,G CONTAllEENT SYSTEMS

( MIMENT AlEMOSPEERE DIMITION SYlif DITION PERAT

( ITI

[g 3(3,1 IM The containment atmosphere dilution (CAD) system shall be OPERABLE with a s. . OPERABLE path le of a ying nitro to the dyydell, 64./

I

,5g, h .3.1.l @9 A minimum supply of 4350 gallons of liquid nitrogen.

, APPLICABILITY: (NDITION1 ACTION:

D* N b fWiththeCADs temr inoperable, be in at leastrestore the CAD STARIUP system within to OPERABLE the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Thestatus ggg within 31 da_

provisions of ecification 3.0.4 are not applicabla.

I A- M *it- SURVEILIANG REQUIREMENIS Q The CAD system shall be demonstrated to be OPERABLE:

(30 At least once per. 31 days by verifying thats Q() The system contains a minimum of 4350 gallons of liquid Sft. g 3 3 ,g nitrogen, and

@ Each valve (manual, power-operated, or automatic) in the flow g g,3,2.t path not locked, sealed, or otherwise secured in position, is in i its correct position y c. g om.t wqg4 g by: D- O " 18" EI'3

$) At least once per son D.1 4, fr. S.4.1.2.4 2el

$R %3,?.3 h Cycling each pous rated uding automatic) valve in the (.4.2 flow path through at least one complete cycle (T psil tyve and -

y g,g,g 'q $ + Verif its g'ge'rept hat each automatie valve in the flow path actuates to sition on a@yand$ isolation est signal.

l O

isofsh% y l

L . 2.

AJ4 p, gos,t yde do 54. SL3,2A l. . l When oxygen concentratica is required to be < 4% per Specification 3.6.6.3. d.'Z.

BRUNSWICK - UNIf 1 3/4 6-28 Amendment No. 59

$ 4

l I

c'ikca M sw D. b d,1 0-

\

l 3.6 CONTADMENT SYSTEMS l

! GUNES AmF.Nr ATHOSPEER5- DIIDTION JYST ITING NDITIO E OPE N

~ <

l g 3,c,3,'1M The containment atmosphere dilution (CAD) system shall be OPERABLE withs i

OPERAB ow path ble of sup ng nitrog the d 1, l.A. I l sg, g,g,3,1,g $ A minimum supply of 4350 gallons of liquid nitrogen.

, APPLICABILITY: pKDIIION1*

ACTION: i ACD64 A (With the CAD system inoperable, restore the CAD system to OPERABLE status !

At'no4 B (within 31 dam 6r be in at least STARIUP within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The g g % provisions of rpecification 3.0.4 are not applicable.

SURVEILLANE REQUIREMENTS 1

@ The CAD syste:s shall be demonstrated to be OPERABLE:

$ At least once per 31 days by verifying thats g ,j,g.gg @ The system contains a ninfaum of 4350, gallons of liquid nitrogen, and SR. S t., u.z. @ E*ch v81'* (=*n=*l, Power-operated, or automatic) in the flow path not locked, sealed, or otherwise secured in position, is in its correct position F Cor ca- te- *Wed + A c.a A @m A.3 p At least once per ao 24 by: 0.t L

4, se Ec,s,1,3 4, St. AL .'3,7.4 gg g,g,g,L 3 - p Cycling each powe rat uding autonstic) valve in the flow path through at least one complete cycle @ tynve L A . 'Z.

gg S c,3,'L/.{ hat each automatie vm1we in the flow path actuates to

@ f itserif r position on a(pd6p 7anV6) isolation signal.

you_ u HS 6 - u-(

^

p.a s. se sw.n u (m ,.,..s When oxygen concentration is required to be < 4% per Specification 3.6.6.3. A.2-BRUNSWICK - UNIT 2 3/4 6-28 Amendment No. 85 p 1.f 2.

DISCUSSION OF CHANGES l

ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM ADMINISTRATIVE I

A.1 In the conversion of the Brunswick Nuclear Plant (BNP) current Technical Specifications (CTS) to the plant specific Improved 3 Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, 3 reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor Standard Technical Specifications, NUREG-1433, Rev. 1.

A.2 The Applicability of CTS 3 6.6.2 is stated as CONDITION 1 when oxygen concentration is required to be < 4 % per CTS 3.6.6.3. The Applicability of CTS 3.6.6.3 is CONDITION 1 during the period from within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER > 15% RATED THERMAL POWER to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to

< 15% RATED THERMAL POWER. In the Applicability of ITS 3.6.3.2, the reference to CTS 3.6.6.3 is deleted and the Applicability of CTS 3.6.6.3 (ITS 3.6.3.1, " Primary Containment Oxygen Concentration") is explicitly stated, i.e., MODE 1 during the time period from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to < 15% RATED THERMAL POWER. Since the change involves no .

technical changes and is a presentation preference only, it is l considered to be administrative, l A.3 The CAD System is manually actuated (requiring repositioning of valves by the operator). In CTS, this is recognized and b 4 interpreted that "in the correct position" allows the valves to be '

in a non-accident position provided they can be realigned to the correct position. In the ITS, the words "in the correct position" mean that the valves must be in the accident position, unless they can be automatically. aligned on an accident signal. If so, then they can be in the non-accident position. Thus, for the CAD System, which is a manually actuated system, the additional words "or can be aligned to the correct position" are provided in SR 3.6.3.2.2 (CTS 4.6.6.2.a.2) to clarify that it is permissible for this systems' valves to be in the non-accident position and still be considered OPERABLE. Since this is consistent with the current requirement, this change is considered administrative.

A.4 CTS 4.6.6.2.b.2 requires periodic verification that each automatic valve in the flow path actuates to its correct position on a Group 2 and 6 isolation test signal. Under the same conditions, ITS SR 3.6.3.2.4 requires that each automatic valve in the flow path actuate to its isolation position. On Group 2 and 6 primary containment isolation signals, automatic valves in the CAD System flow path will actuate to the isolation position (i.e., close) to prevent leakage of radioactive material from primary containment following a design basis accident. The automatic valves in the CAD System flow path that close on Group 2 and 6 primary O c "t i" "t isai tio" sia" is re ari ars ca"t ia e#t isoi tie" valves (PCIVs) as identified in UFSAR Table 6.2.4-1. UFSAR BNP UNITS 1 & 2 1 Revision 0

DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM O = 1N1S m u n A.4 Table 6.2.4-1 also identifies that the post accident position of ,

(cont'd) these valves is closed. Therefore, the correct position of these l valves, in response to Group 2 and 6 primary containment isolation '

signals, is the isolated position. Since the change involves no technical changes and is a presentation preference only, it is considered to be administrative.

TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES - tESS RESTRICTIVE

" Generic" LA.1 The details in CTS 3.6.6.2 relating to CAD System OPERABILITY (in this case that the CAD System must have an OPERABLE flow path capable of supplying nitrogen to the drywell) are to be relocated to the Basos. These details for system OPERABILITY are not necessary in the LCO. The definition of OPERABILITY suffices. As such, these relocated details are not required to be included in the Technical Specifications to provide adequate protection of the O public health and safety. Changes to the Bases will be controlled by the provisions of the proposed Bases Control Program described in Chapter 5 of the ITS.

LA.2 The details relating to raethods for performing the Surveillance in CTS 4.6.6.2.b.1 (defining what constitutes one complete cycle of each power operated valve in flow path, i.e., one complete cycle I "of full travel") and the details relating to methods for performing the Surveillance in CTS 4.6.6.2.b.2 (the use of

" Group 2 and 6" isolation signals during the Surveillance) are to be relocated to the Bases. These details are not necessary to ensure the OPERABILITY of the CAD System. The requirements of ITS 3.6.3.2 and the associated Surveillance Requirements are adequate to ensure the CAD System is maintained OPERABLE. As a result, the methods of performing Surveillances are not necessary to ensure the CAD System can perform its intended safety function and the details are not required to be 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 Bases Control Program described in Chapter 5 of the ITS.

LD.1 CTS 4.6.6.2.b.1 specifies "once per 18 months" as the frequency for the cycling of ~each CAD System power operated, excluding ;

automatic, valve in the flow path through at least one complete ;

O v

cycle of travel. ITS SR 3.6.3.2.3 specifies a 24 month Frequency for this test. Therefore, the surveillance test interval of this SR is being increased from once every 18 months to once every BNP UNITS 1 & 2 2 Revision 0

DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE l

LD.1 24 months for a maximum interval of 30 months including the 25% !

(cont'd) grace period. ITS SR 3.6.3.2.3, cycling of each CAD System power i operated (excluding automatic) valve in the flow path through at 1 ieast one complete cycle, is performed to demonstrate that the valves are mechanically OPERABLE and functioning properly.

Extending the interval between SR performances will not have a significant impact on reliability because the CAD System is a manually initiated system and includes two subsystems. These two subsystems include redundant flow paths such that no single failure of an active component (e.g., a power operated valve in the flow path to primary containment) will render the system inoperable. In addition, most of these power operated valves are cycled on a more frequent basis during the operating cycle in accordance with the Inservice Testing Program.

A review of the surveillance test history for this Surveillance I Requirement was performed to validate the above conclusion. This historical review of the surveillance test history demonstrates that there are no failures that would invalidate the conclusion that the impact of this change, if any, on system availability is minimal.

LD.2 CTS 4.6.6.2.b.2 specifies the frequency for functional testing of I O CAD System PCIVs as once every 18 months. In ITS SR 3.6.3.2.4, '

the frequency for the CAD System PCIV functional testing is specified as once every 24 months. The surveillance interval of ,

this SR is being increased from once every 18 months to once every l 24 months for a maximum interval of 30 months including the 25%

grace period. This SR ensures that each CAD System automatic PCIV will actuate to its isolation position on Group 2 and 6 primary containment isolation signals. Some of these PCIVs are stroke tested on a more frequent basis during the operating cycle in accordance with the Inservice Testing Program. The stroke testing of these PCIVs tests a significant portion of the PCIVs circuitry and will detect failures of this circuitry. The PCIVs, including the actuating logic, are designed to be single failure proof and therefore, are highly reliable. Furthermore, as stated in the NRC Safety Evaluation Report (dated August 2,1993) relating to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3 surveillance. intervals from 18 to 24 months:

" Industry reliability studies for boiling water reactors

. (BWRs), prepared by the BWR Owners Group (NEDC-30936P) show that the overall safety systems' reliabilities are not dominated by the reliabilities of the logic system, but by that of the mechanical components, (e.g., pumps and valves),

which are consequently tested on a more frequent basis.

Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, O i"cre si"9 the ' 9'c >>>te r#"ctio" ' test '"terv 1 represents no significant change it the overall safety system unavailability."

BNP UNITS 1 & 2 3 Revision 0

( i DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE LD.2 Based on the above discussion, the impact, if any, of this change (cont'd) on system availability is minimal.

A review of the surveillance test history was performed to !

validate the above conclusion. This historical review of the !

surveillance test history demonstrates that there are no failures that would invalidate the conclusion that the impact on system availability, if any, is minimal.

j l

l " Specific" L.1 ITS SR 3.6.3.2.4 (CTS 4.6.6.2.b.2) requires periodic verification that each automatic valve in the CAD System flow path actuates to l the isolation position on a primary containment isolation signal (i.e., Group 2 and 6 primary containment isolation signals). The automatic valves in the CAD System flow path that close on Group 2 and 6 primary containment isolation signals are primary containment isolation valves (PCIVs) as identified in UFSAR Table 6.2.4-1. UFSAR Table 6.2.4-1 also identifies that the post ;

accident position of these valves is closed. The PCIV function of '

these valves, on receipt of Group 2 and 6 isolation signals, is to close to prevent leakage of radioactive material from primary /A j l/7 containment following a design basis accident. As a result, the 'D

(_/ CAD System flow path is isolated in this condition. The PCIV ;

function of these valves does not support the OPERACILITY of the CAD System function and is not required to ensure the CAD System function is maintained OPERABLE after a design basis accident (since the CAD System is designed to withstand the effects of a design basis accident). The CAD System function of these same valves is to be manually opened after a design basis accident to establish a flow path capable of supplying nitrogen to the primary containment. When the CAD System liquid nitrogen supply tank, valves, and piping are OPERABLE such that an OPERABLE flow path is available to supply nitrogen to the drywell, but one or more PCIVs in the CAD System will not actuate to isolate the CAD System flow path from the primary containment in response to a simulated or actual primary containment isolation signal, the CAD System is still OPERABLE. Therefore, a Note is added to ITS SR.3.6.3.2.4 (CTS 4.6.6.2.b.2) indicating that failure to meet SR 3.6.3.2.4 does not affect the OPERABILITY of the CAD System. In addition, to ensure the ACTIONS of ITS 3.6.I.3, " Primary Containment Isolation Valves (PCIVs)," are entered when the ability to isolate the CAD System flow path from the primary containment in response

to a primary containment isolation signal is lost, the Note to ITS BNP UNITS 1 & 2 4 Revision 0

f DISCUSSION OF CHANGES l ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE L.1 SR 3.6.3.2.4 also indicates that failure to meet ITS SR 3.6.3.2.4 (cont'd) requires the ACTIONS for ITS 3.6.1.3 to be immediately entered.

The ACTIONS of ITS 3.6.1.3 provide the appropriate restrictions for one or more inoperable PCIVs.

This change is considered to be less restrictive since, if CTS 4.6.6.2.b.2 were to be not met, the CAD System would be declared inoperable and the Action of CTS 3.6.6.2 would provide 31 days to restore the inoperability prior to requiring the unit to be placed in MODE 2. With the proposed Note, the CAD System would not be considered inoperable and the affected penetration flow path would be isolated in accordance with the ACTIONS of ITS 3.6.1.3 and operation could continue. In this condition, the l CAD System flow path would be isolated. However, since the CAD l

System is a manually initiated system and analysis demonstrates that at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months are available to initiate the system, sufficient time is available for operator action to unisolate the flow path from the control room in order to supply nitrogen to the primary containment. Therefore, it is unnecessary to require the unit to be placed in MODE 2 since the CAD System is still capable of performing its intended safety function in this condition. In

! addition, if the isolation of the affected primary containment penetration was such that the CAD System was not considered to be A capable of performing its intended safety function, then Note 3 of Os the ACTIONS of ITS 3.6.1.3 requires immediate entry into the applicable Conditions and Required Actions for ITS 3.6.3.2 (the ACTIONS of ITS 3.6.3.2 require restoration of the CAD System within 31 days). Therefore, assurance is provided that continuous operation is precluded when the CAD System is not capable of performing its intended function.

L.2 The phrase " actual or," in reference to the isolation test signal in CTS 4.6.6.2.b.2, is added to ITS SR 3.6.3.2.4 which verifies l that the CAD System automatic valves in the flow path actuate to the isolation position on an isolation signal. This allows satisfactory automatic CAD System valve isolations for other than test purposes to be used to fulfill the Surveillance Requirement.

OPERABILITY is adequately demonstrated in either case since the CAD System components cannot discriminate between " actual" or

" test" signals.

RELOCATED SPECIFICATIONS None l

O !

I BNP UNITS 1 & 2 5 Revision 0

O CAD Syst <

3.6.3 C[5/ Doc 5-z 3.6 CONTAINHENT SYSTEMS 3.6.3 neent Atmosphere Dilution (CAD) System 344.2./ LC0 3.6.3 @ CAD Mstenspshall be OPERABLE.

S2

/A.z. APP;.ICABILITY: MODE $1 @ d-:ag Ab PeE:

a. L 24 h.- s Ac Twtews. rede. is > #5 % RTP . cit g AAp/. p ETIONS L'*+ h*'

f' Y' " 5 d"#'d*J #'L" *E

THGE* M fo OSP.RTP, CONDITION REQUIRED ACTION COMPLETION TIME 5.t,.t. 7. A. @ CAD M stem A.1 "0TE Ac;noo Inoperable. LC0 3.0.4 is not applicable.

Restore 010 $ [ystem p' s to OPERAO.E status.

l O 8. Two CAD subsystems 8.1 Verify by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months i rable. a nirtrative means at the hydrogen Algl control functi is p s maintained. Once 12 rs after AllQ /

B.2 Restore one 7 days subsystem to ERABLE status.

E >

l 564.2

/ Tgho rs AcnW Required Action and . Se in MODI 3 associatedCompletion(/ \

Time not met.

l

(

~ ~/i S'EE 3.6-45 hv 1 - 04/07/ O O

j 1

1 CAD Syste CT5 /I)oc.5 3.6.34 p SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i

x-4(,4.n.) SR 3.6 3 QW'.f'.1Verify are cont k hal of liquid nitrogen

'n the CAD System.

31 days 2.) g.

SR 3{.6..f'. Verify each CAD subsystem manual, power 31 days 4c .(. 2.a 2./ operated, and automatic valve in the flow path that is not locked, sealed, or S'3 otherwise secured in position is in the i

correct position or can be aligned to the i correct position, j M*,* ' SA. 34.U 3 Cyc ecul 3 w,- o ,Je f, 24 m ~44 tv.t e u.Ld t. uwA, p,We v. .in A

-N -A

%c yele. A.3h ..

Q <

,0 \d<

- - e ra - -- -

4u.s.2 se. 3 6.3.2.4 - -

/Aa,tg F.: tu<< 4. - d his S R d m 0%% nd <,44,, + < . cab sp4m t 2- 1%p, Ale , c.b 9 g:c.4k rosthws uJ E,pi<.4 AJ -5 Cmfa'a J ef u o 34.1.3 " fr ,

ggs;m V.\vn PC % )[In -A ,. N ^i

,e g lw,e +, e< J- -na-- St.

p,;f as J, rk vdvc 2A mm%

g .4 4

AJ'5 isol.hfgsW 6.-

4 .A< 4 AIdof a gJ .<

is ollim siy d-

=/: .P 3.6-46 h :, c'/07/05 E 4 \ #

9

JUSTIFICATION FOR DEVIATIONS FROM NUREG-1433, REVISION 1 SECTION 3.6 - CONTAINMENT SYSTEMS O 33. NUREG-1433 Specification 3.6.3.4, " Containment Atmosphere Dilution (CAD)

System," is revised in BNP ITS 3.6.3.2 to be consistent with the current licensing basis. In addition, 18 month Surveillances are extended to 24 months to be consistent with the BNP cycle length, and a Note is added to a current licensing basis Surveillance to facilitate proper use d

and interpretation of the requirements in ITS (See Discussion of Change L.1 for ITS 3.6.3.2).

34. NUREG-1433 Surveillance Requirement 3.6.4.1.1 (verification that secondary containment is at a negative pressure) is not included in the i BNP ITS.. This change is consistent with the BNP current licensing !

basis. This Surveillance is not necessary to ensure the secondary ;

containment is maintained OPERABLE since reactor building low pressure !

alarms are available to alert the operator to a loss of secondary containment vacuum or a breach of secondary containment. In addition, interlocks are provided on the secondary access doors to ensure at least one door at each access opening is closed. As a result, the following surveillances are renumbered to reflect this change.

35. NUREG-1433 SR 3.6.4.1.4 verifies that a standby gas treatment (SGT) subsystem can draw down secondary containment within a specified time period. This surveillance is not included in the BNP ITS since the BNP UFSAR and associated analyses do not consider unfiltered releases during ;

SGT subsystem drawdown of secondary containment. This change is '

consistent with the BNP current licensing basis.

36. NUREG-1433 SR 3.6.4.2.1 verifies the secondary containment manual I isolation valves and blind flanges are closed. This SR is not included ,

in the BNP ITS since the BNP current licensing basis-does not include i secondary containment manual isolation valves and blind flanges. As a result, the subsequent NUREG-1433 surveillances are renumbered to reflect this change.

37. NUREG-1433 Specification 3.6.4'.3 ACTIONS do not provide a restoration period for a standby gas treatment (SGT) subsystem during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs. BNP ITS 3.6.4.3 ACTIONS provide 31 days to restore a SGT subsystem prior to suspending movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, and OPDRVs. The 31 day Completion Time is considered acceptable due to the reduced consequences associated with postulated events during shutdown conditions and the availability of the remaining SGT subsystem. This change is also consistent with BNP current licensing basis. As a result, the following requirements are renumbered to reflect this change.

O.

BNP UNITS 1 & 2 6 Revision 0

1 JUSTIFICATION FOR DEVIATIONS FROM NUREG-1433, REVISION 1 SECTION 3.6 - CONTAINMENT SYSTEMS

38. NUREG-1433 Specification 3.6.4.3 Required Action D.1, which requires immediately entering LCO 3.0.3 when two SGT subsystems are inoperable in MODE 1, 2, or 3, is not included in BNP ITS 3.6.4.3. Instead, the condition when two SGT subsystems are inoperable in MODE 1, 2, or 3 is added to BNP ITS 3.6.4.3 Condition B. BNP ITS 3.6.4.3 Required i

Actions B.1 and B.2 require the plant to be shutdown within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

This change to NUREG-1433 Specification 3.6.4.3 results in removing the plant from the MODES of Applicability one hour sooner and is consistent with the BNP current licensing basis.

l 39. The Frequencies of NUREG-1433 Surveillance Requirements 3.6.4.1.2

, (verification that all secondary equipment hatches are closed and i sealed) and 3.6.4.1.3 (verification that each secondary containment i access door is closed) are specified as 31 days. The Frequencies of BNP !

ITS SR 3.6.4.1.1 (verification that all secondary equipment hatches are l closed and sealed) and BNP ITS SR 3.6.4.1.2 (verification that one l secondary containment access door is closed in each access opening) are i revised to 24 months. The 24 month Frequency is consistent with the

current licensing basis reflected in plant procedures (i.e., the i performance of BNP ITS SR 3.6.4.1.3 (CTS 4.6.5.1.b), which verifies each i Standby Gas Treatment subsystem can maintain 2: 0.25 inch of vacuum water i gauge in the secondary containment. CTS 4.6.5.1.b is performed on a j refueling outage basis. If the requirements of BNP ITS SR 3.6.4.1.1 and SR 3.6.4.1.2 were not met, then BNP ITS SR 3.6.4.1.3 could not be satisfied.

In addition, the 24 month Frequency is considered to be adequate since reactor building low pressure alarms are available to alert the operator b I to a breach of secondary containment. In addition, interlocks are provided on the secondary containment access doors to ensure at least i one door at each access opening is maintained closed.

40. NUREG-1433 Surveillance Requirement 3.6.4.1.3 requires verification that ;

each secondary containment access door is closed, except when the access i opening is being used for entry and exit, then at least one door shall '

be closed. NUREG-1433 SR 3.6.4.1.3 is revised in BNP ITS SR 3.6.4.1.2 to require verification that one secondary containment access door is t

closed in each access opening. This change is consistent with the BNP current licensing basis requirements for Secondary Containment Integrity reflected in the definitions of the CTS.

O BNP UNITS 1 & 2 7 Revision 0 L

1 Primary Containment Oxygen Concentratio B 3.6.3 y B 3.6 CONTAll#iENT SYSTEMS B 3.6.3 Primary Containment Oxygen Concentration I

BASES

& p ,; e 3 ~4.;a. ,a .5 g BACKGROUND fly ngdea/reacInr(=ud esigned to withstand events i

that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The l primary method to control hydrogen is to inert the primary ;

containment. With the primary containment inert, that is, oxygen concentration < 4.0 volume percent (v/c), a combustible mixture cannot be present in the primary - (h j h@ containment for any hydrogen concentration. The capability to inert the primary containment and maintt n ervaen (,,J e dk )ol

< 4.0 v/o worksNogether with the dNMoneMern= Win System AWfu d h [*7 '

((AbM1skn E

~ (LCO 3.6.3 W "r hMNaDN

,mmew a- m ---

z- 9a=4 o r

== neca=hnie k

n')

nt and MJW 1

i diverse methods to mitigate eveists t at produce hydroge "7 For example, an event that rap enerates hydrogen from

, zirconium metal water reaction result in excessive (*dd i hydrogen in pr t oxygen concentration >

6.0 will remain < Mmary containment,v/o and no combustion can occur. Long term generation of both hydrogen and oxygen from radiolytic t'

' decomposition of water may eventually result in a G

~ ;.;&J

[b combustiblemixtureinprimarycontainmenf. 6 if i

e rec ners .-. npn vv o agm oxy gas maain an fas p-y<g~"j rek.N-ey ca p cad free radicMsis a m ombu tian e a areu . This LCO ensures that oxygen concentration does not exceed 4.0 v/o during operation in

[3

['"g a,o % ;.

,A i

the applicable conditions. g d.% s APPLICABLE The Ref.rtnce 1 calculations assume that the primaryMh SAFETY ANALYSES containment is inerted when a Design Basis Accident +1oss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce .

g combustible gas mixtures in the primary containment.e '414J 10xygen, which is subsequently generated byfadiol idecomposition of/ water, is Mielf.Dgby the cab sy s4@

gpapinert (Lc0AI.6.y.I) more rapidly than it is produce Primary containment oxygen concentration satisfies b

Criterion 2 of he,MERC P611cjV5tatedenJ.

Te4<m4.2.

~

(continued)

,-.8WR4 sM( - B 3.6-89 h 1, OUO7/ n O>

1

Primary Containment Oxygen Concentratio B 3.6.3 BASES i

l ACTIONS Rd '

(continued)

If oxygen concentration cannot be restored to within limits I within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. .le - -

achieve this status, power must be reduced to s (15 5 RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3 ~ (O REQUIREMENTS LJ The primary containment must be detemined to be iner by verifying that oxygen concentration is < 4.0 v/o. The 7 day Frequency is based on the slow rate at which oxygen concentration can change and on other indications of i

abnormal conditions (which would lead to more frequent i checking by operators in accordance with plant procedures). l

[Also,thisFrequencyhasbeenshowntobeacceptablethrough -

operating experience.

O ;

REFERENCES 1 h Section (6.2[

, i 2, Io c fR 5o.36 (c)( zk:1),

l

@V e/d CO B 3.6-91 'f r I, O'/0'/ M O

O CAD Syst B3.6. g s-B 3.6 CDNTAINMENT SYSTEMS B3.6.@.ContainmentAtmosphereDilution(CAD)

Cp System -

BASES BACKGROUND The CAD System functions to maintain combustible gas concentrations within the primary containment at or below the flammability limits following a tulated loss of

. coolant accident (LOCA) by diluting ydrogen and oxygen with nitrogen. To e'nsure that a combustib e gas atxture does not f-occur, oxygen concentration is kept <@.Qpolume percent (v/o)g er pyosw.. w-i6reuer u mayys .yv/J.

The CAD System is manually initiated and consists of two use mueaQ 1005 capacity subsystems. Each subsystem

( sA I 49 ETA 0 liquid nitrogen supply tank, Gaslenkv.popszer)

%L @qtlec trice 5H3tr, and connected piping to supply the crywell I ano suppression chamber volumes The nitrogen storage tanigg)

<. tw @ contai@@l35(q) pal, c is adequate for days of CAD subsystem operat'on.

snu- The CAD System operates in conjunction with emergency A O 8 operating procedures that are used to reduce primary containiment pressure periodically during CAD System operation. This combination results in a feed and bleed approach to maintaining hydrogen and oxygen concentrations

~~

below combustible levels.

APPLICABLE To evaluate the potential for hydrogen and oxygen SAFETY ANALYSES accumulation in primary containment following a LOCA, hydrogen and oxygen generation is calculated (as a function

. The of time following assumptions statedthe initiation of in Reference 1 aretheused accident)imize to max the amount of hydrogen and oxygen generated. The calculation confims that when the mitigating systems are actuated in accordancewithemergencyoperatingprocedures,thep@eak oxygen concentration in primary containment is <@.0 v/o (Ref. 2).

itydrogen and oxygen may accumulate within primary containment following a LOCA as a result of:

a. A metal water reaction between the zirconium fuel rod cladding and the reactor coolant; or (continued) m /' # B 3.6-92 t i 1, O'/0?/05 S-O

O O Insert B 3.6.3.2-1 i

The liquid nitrogen supply tank and electric vaporizers are common components

which are shared between the CAD subsystems of the two units. Piping from the l liquid nitrogen su) ply tank downstream of the vaporizers is split and routed to each unit. Eac1 pipe to a particular unit is divided to provide the A capability to supply nitrogen to both the drywell and the suppression chamber.

l 1

l l

LO 1 l

l l-I-

! a i

O

CAD System B 3.6.3 h

BASES APPLICABLE b. Radiolytic decomposition of water in the Reactor SAFETY ANALYSES Coolant System.

(continued)

The CAD System satisfies Criterion 3 of (fiMIRC401)t 8" d# I*'3M'N'N Q. (Rd. S) r LC0 ' tac dfwo CAD subsystems)must be OPERABLE 6 ensures operation,C

! c4D of at least one CAD subsystem in the event of a worst case f t-5 5*

single active failure. Operation of at least one CAD subsystem is designed to maintain primar containment post-TtA bs s.D LOCA cxygen concentration < 5.0 v/o for da s. h"'N^Ig "f "

I so(1)

@ APPLICABI'LITY In M00l$1 AfGF"JD the CAD System is required to maintain the dea P'.~ y ( oxygen concentration within primary containneat below the Amt a3g flammability limit of 5.0 v/o following a LOCA. This

"'jM ensures that the relative leak tightness of primary

.'5 containment is adequate and prevents damage to safety I

Opud 4o be. related equipment and instruments located within primary 44 , o vy, , containment. A

'*' ' f 0.<.3 In MODE 3, both the hydrogen and oxygen production rates and em4n:^~(aA ) i the total amounts produced after a LOCA would be less than ic,,tef' ace.,&.g those calculated for the Design Basis Accident LOCA. Thus,

4 g) in 3,3, , '

. if the analysis were to be performed starting with a LOCA in MODE 3, the time to reach a flammable concentration would be

" fr6 dua f =

}

l extended be and the time conservatively calculated for MODE $f 1 The extended time would allow hydrogen 08 removal from the primary containment atmosphere by other 7 (**d41'm ) means and also allow re air of an inoperable CAD subsystem, i

if CAD were not availab e. Therefore, the CAD System is not required to be OPERABLE in MODE 3.

In MODES 4 and 5, the probability and consequences of a LOCA

'Lsut- .are reduced due to the pressure and temperature limitations e v..)E-2. of these MODES. Therefore, the CAD System is not required to be OPERABLE in MODES 4 and 5.

CD '

i

,, t i

. (continued) i"'"./' STSA B 3.6-93 Da 1 ^'/07/a F V'

!O Insert B 3.6.3.2-2 In MODE 1. when primary containment oxygen concentration is not required to be

, < 4.0 v/o in accordance with LC0 3.6.3.1. " Primary Containment Oxygen Concentration." and in MODE 2. the potential for an event that generates significant hydrogen and oxygen is low. the primary containment need not be inert, and the CAD System'is not required to be OPERABLE. Furthermore' the probability of an event that generates hydrogen occurring within the first A 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a scheduled power reduction < 15% RTP (i.e., when primary containment oxygen concentration is not required to be < 4.0 v/o in accordance with LC0 3.6.3.1). is low enough that these " windows." when the arimary containment is not inerted and the CAD System is not. required to be OPERABLE, are also justified.

O

(

1

.O

CAD Syst B3.6. 7 h BASES (continued)

ACTIONS .

Ad [ en er b3E 5d'b If CAD Gb[ystem is inoperable, it must be restored to CD ,a " * * '*"'" * ' > - '" **' c d' - -

Ioremain ng E;""";

control w ;P;t=

nction de to erform i;d;e%overall wever, liabil y t

fik* **yja

- cMA M ,4 i is duced ause a s W system e ad - ah a = da--A le failurfinthe0 a--a-- eaa LE 2 i

of A. cab M-sn i+f The day Completion Time is based on the low probability p u g1. 4 o t e occurrence of a LOCA that would generate hydrogen and

'A ongen in amounts capable of exceeding the flammability w' g,4 e, . 1 limit, the amount of time available after the event for

T$* "#".5

operator action to prevent exceeding thin limit, and the 8 availability of sheAPLRAMELAD swisystem miliDother k yM b) hydrogen mitigating systems.

(, ele-.J

,g q.ky Required Action A.1 has been modified by a Note that indicates that the provisions of LCO 3.0.4 are not applicable.

dil!Wystem3 As a result, a MODE 1 s inoperable. This chan$e al owance is allowed is provided when dME cause of the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amount < c=anhle (m u L.% of exceeding the flammability limit.ffhe W orobability o3 O- sa 7sA4) Me 311ure of SMe UMMAW A suMYSteS( the amount of flee avai able after a postulated L KA for operator action to h

prevent exceeding the flammability limit,'and the. -

availability of other hydrogen mitigating systems.

B.1 and B.2 Revi r's Note: This Co ion is only all d for plants wi an alternate hyd n control system eptable to the nical staff.

With two CAD su stems inoperable e ability to perfo the hydrogen ntrol function vi 1 ternate capabilit must be ve led by administr ve means within 1 h . The alterna hydrogen control abilities are prov by the

[Pri Containment Ine ng System or one hy en iner and one Dr 1 Cooling System f . The I hour C lation Time all a reasonable pert f time to verify that a loss of hy en control functio does not exist.

[ Reviewer's Not . T e following is be used if a non-Technica pecification altern e hydrogen cont tion i used to justify thi ondition: In a tion, (continued)

=/4 J. 'B 3.6-94 "r; 1, 00/07/778*-

O

/

e

CAD Syst B3.6.3fp 1T BASES j ACTIONS .1 and B.2 (contin )

l the alternate drogen control system ca btTity must be verified o M r 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter ensure its - .

contin availability.: [Both] [initialj verification (and I subsequent ver'ficat s] may be performed as an ada6ntstrative check by a ning logs or other inf reation io detemine the avati ity of ti.e alternate

, gen !

control system. It s not mean to perfom Surveillances.no d to demonstrate OPE TY of the alternate hyd en control system. I e ability to performthj rogen control funct is maintained, continued operation is pemitt ith two CAD subsystems inoperele for up to 7 days ven days is a reasonabl tin ( to allow two CAD s stems to be inoperable be se the hydrogen control ction is maintained and use of i l

the low probabilit f the occurrence of a L hat would 1 i generate hydr in amounts capable of a ding the flammability mit.

With CAD subsystems inoperab , one CAD subsystem be restored to OPERABLE statu ithin 7 days. The y Completion Time is based o e low probability he g j occurrence of a LOCA t would generate hyd n in the amounts capable of eeding the flasmiabil imit, the amount of time ava able after the even or operator action '

to prevent exceeding this limit, an e availability of other hydrogen mitigating systems.

@@RequiredActions(a If be met within the associated etion Time, the plant must be brought to a NGDE in g, whi the LC0 does not apply. To achiev ges status the plant must be brought to at least MODEFwithin gThours. g I The allowed Completion Time o hours is reasonable, based ) E' on operating experience, to reac from full power ;

conditions in an orderly nner wit out challenging plant systems.

2-E (continued)

M /' :T 8 3.6-95 ce= 1. n u o7/A6>--

O .

CAD System B 3.6.3 g BASES (continued) !

l SURVEILLANCE SR 3.6.3 8 W

l REQUIREMENTS Verifying that there is 1 5 al of liquid trogen l supply in the CAD System ure at least Faaysof post-LOCA CAD operation. This minimum volume liquid nitrogen allows sufficient time after an accident to replenish the nitrogen supply for long term inerting. This is verified every 31 days to ensure that the system is capable of perfoming its intended function when required.

The 31 day Frequency is based on operating experience, which has shown 31 days to be an acceptable period to verify the liquid nitrogen supply and on the availability of other hydrogen mitigating systems. i SR 3.6.

V l Verifying the correct alignment for manual, power operated, and automatic valves in each of the CAD subsystem flow paths .

provides assurance that the proper flow paths exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since -

these valves were verified to be in the correct position O prior to locking, sealing, or securing. 8 :

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within

., the time assumed in the accident analysis. This is acceptable because the CAD System is manually initiated.

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

The 31 day Frequency is appropriate because the valves are operated under procedural control, imp per valve position would only affect a single subsystem, t e probability of an b'l event requiring initiation of the system is low, and the s w3.2 -3 system is a manually initiated system.

REFERENCES 1. Guide @7, EINTffb 2.@sAR,Section .c.s.., % , m, g

.3. lo cFLio. 3 G ce)(1)(n .

h. ursAR., f EAc G.2 4 - 1]

_ BWR/4 STLst 8 3.6-96 L ', e'/07/O O

O i l Insert 8 3.6.3.2-3 SR 3.6.3.2.3

, Cycling each power operated valve, excluding automatic valves, in the CAD S stem flow path through one complete cycle of full travel demonstrates that t e valves are mechanically OPERABLE and will function when required. While this Surveillance may be performed with the reactor at power, the 24 month Frequency of the Surveillance is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency.

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

SR 3.6.3.2.4 On the Group 2 and 6flow CAD System primarb containment pat close isolation to prevent leakagesignals, automaticmaterial of radioactive valves in from l primary containment following a design basis accident. The automatic valves

! in the CAD System flow path that close on Group 2 and 6 primary containment isolation signals are )rimary containment isolation valves (PCIVs) as identified in UFSAR Ta)le 6.2.4-1 (Ref. 4). This SR ensures that each i automatic PCIV in the CAD System will actuate to its isolation associated Group 2 and 6 primary containment isolation signals.The position LOGIC on the SYSTEM FUNCTIONAL TEST in LC0 3.3.6.1. " Primary Containment Isolation g

Instrumentation." overlaas this SR to provide complete testing of the safety function. The 24 month Ire uency is based on the need to perform this Surveillance under the cond tions that apply during a plant outage. Operating experience has demonstrated that these components will Jass this Surveillance when performed at the 24 month Frequency. Therefore tie Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by a Note indicating that failure to meet SR 3.6.3.2.4 does not affect the OPERABILITY of the CAD System. As such, when the CAD System liquid nitrogen supply tank. valves and piping are OPERABLE such that l- an OPERABLE flow path is available to supply nitrogen to the drywell, but one

! or more PCIVs in the CAD System will not actuate to isolate the CAD System l flow path from the primary containment in response to a simulated or actual I primary containment isolation signal, the CAD System is still 0PERABLE. To l

ensure the ACTIONS of LC0 3.6.1.3. " Primary Containment Isolation Valves (PCIVs)." are entered when the ability to isolate the CAD System flow path from the primary containment in response to a primary containment isolation

. signal is lost, the Note to SR 3.6.3.2.4 also indicates that failure to meet SR 3.6.3.2.4 requires the ACTIONS for LC0 3.6.1.3 to be immediately entered.

The ACTIONS of LCO 3.6.1.3 provide the appropriate restrictions for one or more inoperable PCIVs.

O

GENERIC NO SIGNIFICANT HAZARDS EVALUATION ,

RELOCATED SPECIFICATIONS f"R.x" labeled Coments/ Discussions Not used.

l i

t. 1 i

l lO al

! l l

i O

BNP UNITS 1 & 2 6 Revision 0

J GENERIC NO SIGNIFICANT HAZARDS EVALUATION O RELOCATED SPECIFICATIONS

("R.x" Labeled Coments/Pi >cussions Not used.

b O

O BNP UNITS 1 & 2 7 Revision 0

NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM

!.1 CHANGE In accordance with the criteria set forth in 10 CFR 50.92, Carolina Power &

Light Company has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

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

A Note is added to Surveillance that requires periodic verification that the prio ry containment isolation valves (PCIVs) in the Containment Atmosphere Dilution (CAD) System actuate to the isolation position in response to the applicable primary containment isolation signal. This proposed Note indicates that failure to meet the subject Surveillance does not affect the OPERABILITY of the CAD System. In addition, to ensure the ACTIONS of ITS 3.6.1.3, " Primary Containment Isolation Valves (PCIVs)," are entered when the ability to isolate the CAD System flow path from the primary containment in response to a primary containment isolation signal is lost, the Note to subject Surveillance also indicates that failure to meet the subject Surveillance requires the ACTIONS for ITS 3.6.1.3 to be immediately entered. The ACTIONS of ITS 3.6.1.3 provide the appropriate restrictions for one or more inoperable PCIVs. The CAD System and the PCIVs in the CAD System are not considered initiators of any previously analyzed accident.

Therefore, this change will not involve an increase in the probability O of an accident previously evaluated. The proposed change would allow the CAD System to not be considered inoperable when the subject Surveillance was not met, would require the affected penetration flow path to be isolated in accordance with the ACTIONS of ITS 3.6.1.3, and g would allow operation to continue rather than requiring the CAD System PCIV inoperability to be restored. In this condition, the CAD System flow path would be isolated. However, since the CAD System is a manually initiated system and analysis demonstrates that at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months are available to initiate the system, sufficient time is available for operator action to unisolate the flow path from the control room in order to supply nitrogen to the primary containment. Therefore, the CAD System is still capable of performing its intended safety function in this condition. In addition, the consequences of an event occurring with the proposed change are no more severe than the consequences of an event occurring during the current 31 day CAD System restoration time.

Therefore, this change will not involve a significant increase in the consequences of an accident previously evaluated.

O l

BNP UNITS 1 & 2 1 Revision 0

NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM O L.I CNA - (continued)

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

The change does not introduce a new mode of plant operation and does not involve physical modification to the plant. This change only eliminates the requirement to place the unit in MODE 2 when CAD System OPERABILITY is maintained and does not change the response of any equipment to an accident. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed change eliminates the restriction on the time period provided to restore inoperable PCIVs in the CAD System. With the proposed Note to the subject Surveillance, the CAD System would not be considered inoperable, the affected penetration flow path would be isolated in accordance with the ACTIONS of ITS 3.6.1.3, and operation could continue. In this condition, the CAD System flow path would be isolated. However, since the CAD System is a manually initiated system and analysis demonstrates that at 'least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months are available to initiate the system, sufficient time is available for operator action to unisolate the flow path from the control room in order to supply nitrogen to the primary containment. Therefore, it is unnecessary to require the unit to be placed in MODE 2 since the CAD System is still O- capable of performing its intended safety function in this condition. d In addition, if the isolation of the affected primary containment penetration was such that the CAD System was not considered to be capable of performing its intended safety function, then Note 3 of the ACTIONS of ITS 3.6.1.3 requires immediate entry into the applicable Conditions and Required Actions for ITS 3.6.3.2 (the ACTIONS of ITS 3.6.3.2 require restoration of the CAD System within 31 days).

Note 3 to the ACTIONS of ITS 3.6.1.3 provides assurance that continuous operation is precluded when the CAD System is not capable of performing its intended Nnction. Therefore, the change does not involve a significant reustion in a margin of safety.

O BNP UNITS 1 & 2 2 Revision 0

NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM O

V L.2 CHANGE In accordance with the criteria set forth in 10 CFR 50.92, Carolina Power &

Light Company has evaluated this proposed Technical Specifications change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

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

The phrase " actual or," in reference to the automatic isolation signal, is added to the ITS Surveillance Requirements. This addition does not impose a requirement to create an " actual" signal, and does not eliminate restrictions on producing an " actual" signal. While creating an " actual" signal could increase the probability of an event, existing procedures and 10 CFR 50.59 control of revisions to them, dictate the acceptability of generating a test signal. The proposed change does not affect the procedures governing plant operations and the acceptability of creating test signals; it simply allows an actual signal to be utilized in evaluating the acceptance criteria associated with Surveillance Requirements. Therefore, the change does not involve a significant increase in the probability of an accident previously evaluated. Since the method of test initiation does not affect the acceptance criteria of the Surveillance Requirements, the change does not involve a significant increase in the consequences of an accident previously evaluated. g

2. Does the change create the possibility of a new or di'Terent kind of accident from any accident previously evaluated?

The change does not introduce a new mode of plant operation and does not involve physical modification to the plant. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Use of an actual signal instead of the current Technical Specification requirement, which limits use to a simulated test signal, will not affect the performance or acceptance criteria of the Surveillances.

OPERABILITY is adequately demonstrated in either case (simulated or actual test signal) since the system itself can not discriminate between

" actual" or " simulated" signal.s. Therefore, the change does not involve a significant reduction in a margin of safety.

O BNP UNITS 1 & 2 3 Revision 0 u_ .

ML20217J917

Text

SUMMARY

SUMMARY

Navigation menu

Search