ML20248A468
| ML20248A468 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/22/1998 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20248A452 | List: |
| References | |
| NUDOCS 9805290389 | |
| Download: ML20248A468 (540) | |
Text
{{#Wiki_filter:- SLs 2.0 2.0 . SAFETY. LIMITS (SLs)
.2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig'or core flow < 10% rated core flow:
THERMAL POWER shall be s 25% RTP. 2.1.1.2 --------------------------NOTE--------------------------- MCPR SL values are only applicable for Cycle 12 operation. b With the reactor steam dome pressure d 785 psig and core-flow a 10% rated core flow: MCPR shall be h 1.09 for two recirculation loop operation or 2 1.10 for single recirculation loop operation. A 2.1.1.3 Reactor vessel water level shall be greater than the top _ of active irradiated fuel. 2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be s 1325 psig. 1 2.2 SL Violations j With any SL violation, the following actions shall be completed within I 2 hours: 2.2.1 Restore compliance with all SLs; and 2.2.2 Insert all insertable control rods.
-l ! 9905290399 990522 C l x PDR ADOCK 05000324 4 P PDR- . ,
Brunswick Unit 1 2.0-1 Amendment No.
. _ _ _ _ _ _ .. ._ _ = _ _ _ _ _ _ _ _ _ _ _ _ - - -
Reactor Core SLs
., B 2.1.1 . BASES' APPLICABLE 2.I.1.3 Reactor V6ssel Water Level SAFETY ANALYSES . .
(continued) During MODES I and 2 the reactor vessel water level is required to be above the top of the active irradiated fuel to provide core cooling capability. In conjunction with LCOs, the limiting safety system settings, defined in LCO 3.3.1.1 as the Allowable Values, establish the threshold for protective system action to prevent exceeding acceptable limits, including this reactor vessel water. level SL, during . Design Basis Accidents. With fuel in the reactor vessel during periods when the reactor is shut down, consideration must be given to water level requirements due to the effect of decay heat. If the water level should drop below the top of the active irradiated fuel during this period, the ability to remove decay heat is reduced. This reduction in cooling capability could lead to elevated cladding temperature and clad perforation in the event that the water level becomes < 2/3 of the core height. The reactor vessel water level SL has been established at the top of the active irradiated fuel to provide a point that can be 1 monitored and to also provide adequete margin for effective action. O
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SAFETY LIMITS The reactor core SLs are established to protect the integrity of the fuel clad barrier to prevent the release of radioactive materials to the environs. SL 2.1.1.1 and i SL 2.1.1.2 ensure that the core operates within the fuel design criteria. SL 2.1.1.3 ensures that the reactor vessel water level is greater than the top of the active irradiated fuel in order to prevent elevated clad temperatures and resultant clad perforations. The MCPR SL values are based on an NRC approved methodology that uses cycle specific input parameters. As a resuit, SL 2.1.1.2 is medified by a Note which restricts use of the MCPR values in SL 2.1.1.2 to Cycle 12 operation only. 6 APPLICABILITY. SLs 2.1.1.1, 2.1.1.2, and 2.1.1.3 are applicable in all MODES. SAFETY' LIMIT Exceeding an SL may cause fuel damage and create a potential VIOLATIONS for radioactive releases in excess of 10 CFR 100, " Reactor
' Site Criteria," limits (Ref. 2). Therefore, it is required (continued) . Brunswick. Unit 1 B 2.0-4 Amendment No.
1
Cyke 2.o M.I 2.0 SAFETY LlHITS k LyIITING /AFETY y dTEM SEJ(lNGS) 2.1 SAFETY LIMITS THERMAL POWFR (Low Pressure or low Flow) 2.1.ti @ THERMAL POWER shall not exceed 25% of RATE iERMAL POWER with the reactor vessel steam dome pressure less than or core flow less than 10% of rated flow. gg [ PLACABILITY: CONDITIONS 1 and 2 ACTION: 9gg g of RATED THERMAL POWER and the reactor vessel
- 2. 2. fWithTHERM4LPOWERexceeding25 steam domo neaunca la" than or core flow less than 10% of rated -
2 j g ,, g in'at least HOT w rTnn W within 2 hour) 4y 2'** THERMAL POWER (Hlah Pressure and Hiah Flow) 7'IN*o% The HINIMUM CRITICAL POWER RATIO (HCPR) shall not belless than 1.09' 2.i.l.2.with @the reactor vessel steam dome pressure greater tha)@e ps+3 and core flowgreater tha310% of rated flow. r
@ PLACABILITY: CONDITIONS 1 and A'E (66 r5) 2 . 't.
[ Wit CPRless]than1.09 e reactor vessel steam dome pressure reate l b XF 90Tand core flow creater tnap 10% of rated flow.(t>e in at least HJ0 fmv) y nuivu m wnnin 2 hour REACTOR COOLANT SYSTEM PRESSURE z.i.? QGd) steam dome, shall not exceed 1325 psig.The reactor coolant system pressure, as measur [ APPLICABILITY: CONDITIONS 1.2.3.andD ACTION: (With the reactor coolant system pressure as measured in the reactor vessel
- 2. 2.
- l. steam dome, above 1325 psigf De in at least HUI bHUlUUWN with reactor coolanp em pressure s IJzb psig within 2 hours y 2.7.1 1 1.2 poic
+=
*MCPR values in Technical Specification 2.1.2 are applicable only for Cycle 12 operation.
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) BRUNSWICK - UNIT 1 2-1 Amendment No. j,4 P T5 BIO s e, . - ._+
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DISCUSSION OF CHANGES ITS: CHAPTER 2.0 - SAFETY LIMITS O v TECHNICAL CHANGES - MORE RESTRICTIVE M.3 restrictive Safety Limits for MCPR apply. As such, the Safety (cont'd) Limits for MCPR during high pressure and high flow conditions with only one recirculation loop in operation are added to ITS 2.1.1.2 to ensure that during single recirculation loop operation the more restrictive Safety Limits on MCPR are invoked. In addition, the
- Note to BNP Unit 1 CTS 2.1.1.2, which restricts the use of the MCPR Safety Limit values to BNP Unit 1 Cycle 12, is also applied to.the MCPR Safety Limit value for single recirculation loop b
operation in BNP Unit 1 ITS 2.1.1.2. TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic" LA.1 Not used. d LA.2 The requirement for notification of the Vice President-Brunswick Nuaaar Plant in the event of a Safety Limit Violation in CTS 6.7.1.b, the requirement for the Vice President-Brunswick Nuclear Plant to review the Safety Limit Violation Report in CTS 0.7.1.c and the requirement to submit the Safety Limit Violation Report to the Vice President-Brunswick Nuclear Plant and the Manager-Nuclear Assessment Section in CTS 6.7.1.d are to be O
V relocated to the UFSAR. Given that the notification occurs following the Safety Limit Violation and that the Safety Limit bi l Violation Report is an after-the-fact report, the relocated requirements are clearly not necessary to assure operation of the unit in a safe manner. Additionally, in the event of a Safety Limit Violation, 10 CFR 50.36(c)(1)(1)(A) does not allow operation of the unit to be resumed until authorization is received from the NRC. As such, these requirements are not required to be in Technical Specifications to provide adequate protection of the public health and safety. Changes to the UFSAR are controlled by M the provisions of 10 CFR 50.59. l I 4 l l l l l BNP UNITS 1 & 2 2 Revision 0
'SLs 2.0 CD / Doc 2.0 SAFETY LIMITS (SLs) 2.8/'
2.1. SLs [- pi~$fv'<au~,[~~ ,
* * "'/ 2.1.1 Reactor Core SL ((,1, sI[// N . h 2.1.1.1 With the reactor steam come pressu m < 785'psig or core 2'i'i /M'i flow < 10% rated core flow:
THEIDEL p0WER shall be 5 255 RTp. 2.1.1.2 With the reactor steam done pmssure 1 785 psig and core a'i*2/g,gg.3 3 flow t.105 rated core flow: kpR sha11 be 1i for two recirculation loop / operation or k operation.
, for single recirculation loop g
- 1. t D 2.1.1.3 Readtor vessel water level sha 1 be ' greater than the top p
- g
- qk * ' . of active irradiated fuel.
2.1.2 Reactor coolant system Pressure st 2.1.3/r. l [ Reactor steam done pressure shall be 51325 psig. 1stf-f 2.2 SL Violations gh .16]
", With any SL violation, the followine actions shall be complet .
2: An/ 0C .72 LA t
" h2/W) thing hop (s) f2.281 Restore compliance with all SLs; and TS TF - 6 2.2.@t Insert all insertable control rods.
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l I JUSTIFICATIONS FOR DEVIATIONS FRON NUREG-1433, REVISION 1 CHAPTER 2.0 - SAFETY LIMITS
- 1. The brackets are removed and the proper plant specific information/value is provided.
- 2. NUREG-1433 SL 2.1.1.2 is modified by a Note to reflect the current licensing basis for BNP Unit I approved in Amendment No. 194. d
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O J O BNP UNITS 1 & 2 1 Revision 0 .. I
I O h Reactor Core SLs B 2.1.1 BASES , i APPLICABLE 2.1.1.3 Reactor vessel Water Level (continued) SAFETY ANALYSES active irradiated fuel to provide a point that can be monitored and to also provide adequate margin for effective action. l SAFETY LIMITS r<e, ihe reactor core SLs are established t protec the g integrity.of the fuel clad barrier to he release of radioactive materials to the environs. SL 2.1.1.1 and SL 2.1.1.2 ensure that the core operates within the fuel design criteria. SL 2.1.1.3 ensures that the reactor vessel water level is greater than the top of the active irradiated fuel in order to prevent elevated clad temperatures and resultart clad perforations. APPLICABILITY SLs 2.1.1.1, 2.1.1.2, and 2.1.1.3 are applicable in all MODES. i i SAFETY LIMIT ' VIOLATIONS i If a . SL i violat , th RC Oper tons nter st O,r.5 { no led thin 1 our, accord ce wi 10 C
- 50. ]
I 1 I Exceeding an SL may cause fue ge and create a potential 1 for radioactive releases in xcess of 10 CFR 100, " Reactor ' SiteCriteria," limits (Ref. . Therefore, it is required ; to insert all insertable control rods and restore compliance i with the SLs within 2 hours. The 2 hour Completion Time ; ensures that the operators take prompt remedial action and also ensures that the probability of an accident occurring during this period is minimal.
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RPS Instrumentation 3.3.1.1 l ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions with RPS trip C.1 Restore RPS trip capability. I hour b capability not I maintained, b D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition A, Table 3.3.1.1-1 for 8, or C not met. the channel. E. As required by E.1 Reduce THERMAL POWER 4 hours i Required Action D.1 to < 30% RTP. and referenced in Table 3.3.1.1-1. O F. As required by F.1 Be in MODE 2. 6 hours Required Action D.1 and referenced in Table 3.3.1.1-1. l G. As required by G.1 Be in MODE 3. 12 hours Required Action D.1 and referenced in Table 3.3.1.1-1. (continued) l
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l Q l ! Brunswick Unit 1 3.3-2 Amendment No.
RPS Instrumentation B 3.3.1.1 BASES U ACTIONS B .1 -8 B . 2 (continued) Alternately, if it is not desired to place the inoperable channels (or r- trip system) in trip (e.g., as in the case . where placing th+. i.toperable channel or associated trip system in trip would result in a scram, Condition D must be entered and its Required Action taken. Required Action C.1 is intended to ensure that appropriate , actions are taken if multiple, inoperable, untripped channels within the same trip system for the same Function result in the Function not maintaining RPS trip capability. A Function is considered to be maintaining RPS trip g capability when sufficient channels are OPERABLE or in trip (or the associated trip system is in trip), cuch that both trip systems will generate a trip signal from the given Function on a valid signal. For the typical Function with one-out-of-two taken twice logic and the IRM and APRM Functions, this would require both trip systems to have one channel OPERA 8LE or in trip (or the associated trip system in trip). For Function 5 (Main Steam Isolation O Valve-Closure), this would require both trip systems to have each channel associated with the MSIVs in three main steam lines (not necessarily the same main steam lines for both trip systems) OPERABLE or in trip (or the associated trip system in trip). For Function 8 (Turbine Stop Valve-Closure), this would require both trip systems to have three channels, each OPERABLE or in trip (or the associated trip system in trip). For Function 10 (Reactor Mode Switch-Shutdown Position) and Function 11 (Manual Scram), this would require both trip systems to have one channel, each OPERABLE or in trip (or the associated trip b system in trip). The Completion Time is intended to allow the operator tir,e to evaluate and repair any discovered inoperabilities. The 1 hour Completion Time is acceptable because it minimizes i risk while allowing time for restoration or tripping of I channels. l 1 (continued) j l o Brunswick Unit I l B 3.3-25 Revision No.
'RPS Instrumentation B 3.3.1.1 BASES O ACTIONS M (continued)
Required Action D.1 directs entry into the appropriate Condition referenced in Table 3.3.1.1-1. The applicable Condition specified in the Table is function and MODE or other specified condition dependent and may change as the Required Action of a previous Condition is completed. Each time an inoperable channel has not met any Required Action of Condition A, B, or C and the associated Completion Time has expired, Condition D will be entered for that channel and provides for transfer to the appropriate subsequent Condition. E.1. F.1. and G.1 If the channel (s) is not restored to OPERABLE status or ] placed in trip (or the associated trip system placed in trip) within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply. The allowed Completion Times are i reasonable, based on operating experience, to reach the j specified condition from full power conditions in an orderly manner and without challenging plant systems. In addition, the Completion Time of Required Action E.1 is consistent 1 with the Completion Time provided in LC0 3.2.2, " MINIMUM I CRITICAL POWER RATIO (MCPR)." M If the channel (s) is not restored to OPERABLE status or placed in trip (or the associated trip system placed in trip) within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LC0 does not apply. This is done by immediately initiating , action to fully insert all insertable control rods in core I cells containing one or more fuel assemblies. Control rods in core cells containing no fuel assemblies do not affect the reactivity of the core and are, therefore, not. required to be inserted. Action must continue until all insertable control rods in core cells containing one or more fuel assemblies are fully inserted. SURVEILLANCE- As noted at the beginning of the SRs, the SRs for each RPS REQUIREMENTS instrumentation Function are located in the SRs column of Table 3.3.1.1-1. (continued) Brunswick Unit 1 B 3.3-26 Revision No.
I { . 1 RPS Instrumentation 3.3.1.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions with RPS trip C.1 Restore RPS trip capability. I hour b l- capability not i maintained. b D. ' Required Action and 0.1 Enter the Condition .Immediately associated Completion ' referenced,in
. Time of Condition A, Table 3.3.1.1-1 for 8, or C not met. the channel.
E. As required by E.1 Reduce THERMAL POWER 4 hours
. Required Action D.1 to < 30% RTP.
and referenced in Table 3.3.1.1-1. O F. As required by F.1 Be in MODE 2. 6 hours Recuired Action D.1 anc referenced in Table 3.3.1.1-1. G. As required by G.1 Be in MODE 3. 12 hours Required Action D.1 and referenced in i Table 3.3.1.1-1. (continued) 1 i i O l Brunswick Unit 2 3.3 Amendment.No.
RPS Instrumentation B 3.3.1.1-BASES O ACTIONS B.1 and B.2 (continued) Alternately, if it is not desired to place the inoperable channels (or one trip system) in trip (e.g., as in the case where placing the inoperable channel or associated trip I system in trip would result in a scram, Condition D must be entered and its Required Action taken. fr.d i Required Action C.1 is intended to ensure that appropriate I actions are taken if multiple, inoperable, untripped channels within the same trip system for the same Function result in the Function not maintaining RPS trip capability. A Function is considered to be maintaining RPS trip G capability when sufficient channels are OPERABLE or in trip (or the associated trip system is in trip), such that both trip systems will generate a trip signal from the givcn Function on a valid signal. For the typical Function with one-out-of-two taken twice logic and the IRM and APRM Functions, this would require both trip systems to have one channel OPERA 8LE or in trip (or the associated trip system in trip). For Function 5 (Main Steam Isolation Valve-Closure), this would require both trip systems to
\ have each channel associated with the MSIVs in three main steam lines (not necessarily the same main steam lines for both trip systems) OPERABLE or in trip (or the associated trip system in trip). For function 8 (Turbine Stop Valve-Closure), this would require both trip systems to have three channels, each OPERABLE or in trip (or the associated trip system in trip). For Function 10 (Reactor Mode Switch-Shutdown Position) and Function 11 (Manual Scram), this would require both trip systems to have one channel, each OPERABLE or in trip (or the associated trip system in. trip).
The Completion Time is intended to allow the operator time to evaluate and repair any discovered t r arabilities. The I hour Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels. (continued) O Brunswick Unit 2 B 3.3-25 Revision No.
RPS Instrumentation B 3.3.1.1 BASES O ACTIONS M (continued) Required Action D.1 directs entry into the appropriate Condition referenced in Table 3.3.1.1-1. The applicable Condition specified in the Table is Function and MODE or other specified condition dependent and may change as.the Required Action of a previous Condition is completed.- Each time an inoperable channel has not met any Required Action of Condition A, B, or C and the associated Completion Time has expired, Condition D will be entered for that channel and provides for transfer to the appropriate subsequent Condition. E.1. F.1. and G.1 If the channel (s) is not restored to OPERABLE status or
. placed in trip (or the associated trip system placed in trip) within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply. The allowed Completion Times are reasonable, based on operating experience, to reach the specified condition from full power conditions in an orderly manner and without challenging plant systems. In addition, 0
, the Completion Time of Required Action E.1 is consistent with the Completion Time provided in LCO 3.2.2, " MINIMUM CRITICAL POWER RATIO (MCPR)." M If the channel (s) is not restored to OPERABLE status or placed in trip (or the associated trip system placed in trip) within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply. This is done by immediately initiating action to fully insert all insertable control rods in core cells containing one or more fuel assemblies. Control rods in core cells containing no fuel assemblies do not affect the reactivity of the core and are, therefore, not required
'to~be inserted. Action must continue ur.til all insertable control rods in core cells containing one or more fuel assemblies are fully inserted.
SURVEILLANCE- As noted'at the beginning of the SRs, the SRs for each RPS REQUIREMENTS. - instrumentation Function are located in the SRs column of Table 3.3.1.1-1. (continued) Brunswick Unit 2 B 3.3 Revision No.
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O . 3.3 h IETRIMENTATION -
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( MITI COBOIT OR TION a minim a, the reactor protectiorLsystem instram edat<cn channels Leo .shrmir 3.34.1)n Table 8-9-id shall be OPERABLE. Get;oents am' omsWgivD M e 2 R - o y ,,,,,,. APPLICABILITY: As shown in Table .. . 1 g.g g EIIsm: e (Aid Acws W% e With one channel less than the Minime Number of OPERABLE Ciannels per Trip System required by Table 3.3.1-1 in one or more Functional Units. pA place system in the tripped c able channel @or that t [p,., .. . conditi in 12 y ,w
- 7 g y., a o , ,,)
**" channels less than the Minimum Number of OPERABLE YWithtwoor c.m 6 (i Channels Functionalper Trip System required by Table 3.3.1-1 in one or more -
Units: M A6* 6 @ Within one hour fv nneWhin.cbABlPtfr3 Mw=a inn
- mai oftrip capa)1lity in the
' Functiorsl Unit. and jcw g W in 6 hours. place the inoperable channel (s) i trip system
{L@ that trip systedSQn the tripped iti and ( pu A h Within 12 hours. restore the inoperable nnels in the other trip system to _an OPERABLE status or place them in the tripped
]
conditicrfr. @ Otherwise, take the ACTION required by Table'95;td for the Functional W 0 Unit. l (@) The i 4.co 1.o.3 CGOSTbsions 5. of Specification 3.0.3 are not applicable in OPERATIONAL , i tri $ where t ca p W CA 1f the lisGimi sule umimi is not fi5i.ored ! to s".a us w thin the required time, the ACTION required l gm o [L by Table 3.3 o tar the Functional Unit shall be taken. c2.s o.1 h
= This - applies to trip system most inoperab s: if both tr systems have ame nuud)er of 1 le .
1s the ACT can be applied either trip syst i LA . s-
.i BIR#lSWICK - LAi!T 1 3/4 3 1. Amerxhent No.175
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'f.J M INSTRUMENTATION f /4I2( REACRR PROTEWftW SYS3M INSTRIMDITATIOW I crwn1 .
tw _ ko3.3.11Asaminimum the reactor rotection estem instrumental' on channels s_hown in Table shall be ERABLE.(se1; pe+m.s anestec aus ar a: ;u;. : : 13 APPLICABILITY: As shown in Table A 'l L M k eCIlg(: AcrWaq f er With one channel less than the Minimum Number of OPERABLE Channels per i ' Aew A Trip System required by Table 3.3.1-1 in one or more Functional Units. place the i p c, able channel @ r that tri em in the tripped
. conditi in 12 hours p g y, ,, , , ,)
g,,,
. 4 With two or more channels less than the Minimum Number of OPERABLE i kw e.
- c.4 % 8 Channels
.Functiona Units:
Trip System required by Table 3.3.1-1 in one or more - k
@ Within one ho suffic channets rematanmm se-+rp
,i ' ,- tha.e h che
- to tainftrip capability in the gaw aC Functional unit, and M*d 8 g Within 6 hours. place the inoperable channel (s) in one trip system and/or that trip syst in the tri conditioy,and AndA @ Within 12 hours. restofe the inoperab e channels in the other trip system to an OPERABLE status or place them in the tripped condi'.1 WD Ot rwise, take the ACTION required by Table 3.3. I for the Functional
& ' f The provisions of Specification 3.0.3 are not applicable in OPERATIONAL g g,3,3 - ( CONDITION 5.
1 c ton th a T u nme in hxa e j f the inoperable Channel 15 not restored Mrva8 D. to OPERABLE status within the required tilde, the ACTION required by Table 3.3. g the Functional Unit shall be taken.
** Th ACTION a lies to that rip system ith the most i rable cha 15: if trip syst have the 5 number of i able cha , the AC can be a fed to ett trip system.
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DISCUSSION OF CHANGES ITS: 3.3.1.1 - RPS INSTRUMENTATION ADMINISTRATIVE (continued) A.15 The specific requirement for a quarterly CHANNEL FUNCTIONAL TEST for CTS Table 4.3.1-1 Functions 2.b (AFRM Flow-Biased Simulated Thermal Power-High) and 2.c (APRM Fixed Neutron Flux-High,120%) is deleted. The definition of CHANNEL CALIBRATION in ITS Chapter 1 includes the CHANNEL FUNCTIONAL TEST. Since the CHANNEL CALIBRATION is also required quarterly, a separate line item for the CHANNEL FUNCTIONAL TEST is not required. Therefore, the deletion of the CHANNEL-FUNCTIONAL TEST requirement is considered administrative.
'A.16 Function 13, Automatic Scram Contactors Function, of CTS Table 3.3.1-1 was added to the BNP CTS per TS Amendments 175 (Unit 1) and 206 (Unit 2) to allow certain Surveillance Frequency extensions to be made to the automatic RPS Functions. The only requirement associated with Function 13 of CTS Table 3.3.1-1 is a weekly functional test requirement. As such, ITS Table 3.3.1.1-1 does not include the RPS Automatic Scram Contactor Function.
, Rather, ITS SR 3.3.1.1.5 specifically requires the automatic scram contactors to be functionally tested weekly whenever the automatic RPS Functions are required to be OPERABLE. Since this change is a presentation preference and does not alter the requirement to
- functionally test the automatic scram contactors weekly, the
! change is considered administrative. TECHNICAL CHANGES - MORE RESTRICTIVE M.1 An Allowable Value is provided for ITS 3.3.1.1 Function 2.d, APRM Downscale, in CTS Table 3.3.1-1. The Allowable Value is based on ; ensuring that the APRMs are on scale when transfers are made j between the APRMs and the IRMs. Thf s Allowable Value has been i established consistent with the methods described in CP&L's c Instrument Setpoint Methodology (Design Guide DG-VIII.0050
" Instrument Setpoints" Rev. 5). The design limit, for the g ]
l OPERABILITY of the APRM Downscale Function, applied in the i methodology has been confirmed as ensuring that applicable design ! requirements of the associated system and equipment are maintained. This RPS Function ensures adequate Neutron Monitoring System protection if the reactor mode switch is placed in the run i position prior to APRMs coming on scale. Therefore, an Allowable l Value 'is needed to ensure OPERABILITY of this Function. Adding an Allowable Value for an RPS Function represents an additional restriction on_ plant operation. l I M.2 Wit' h one manual channel inoperable in each trip system, a manual RPS scram may not occur. Therefore, 12 hours (CTS 3.3.1 Action a) is reduced in ITS 3.3.1.1 Condition C. ITS 3.3.1.1 Condition C f
. limits the time to restore trip capability to I hour when
. -inoperability in one or both manual Functions (Manual Scram and Reactor Mode Switch-Shutdown Position) results in a loss'of RPS A l BNP UNITS 1 & 2 5 Revision 0
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DISCUSSION OF CHANGES ITS: 3.3.1.1 - RPS INSTRUMENTATION TECHNICAL CHANGES - MORE RESTRICTIVE M.2 trip capability (i.e., one or two channels inoperable in one or (cont'd) both Functions). This change is an additional restriction on plant operation necessary to achieve consistency with NUREG-1433. b M.3 A Surveillance is added (ITS SR 3.3.1.1.16) to verify the automatic enabling of the Turbine Stop Valve-Closure RPS Function and Turbine Control Valve Fast Closure, Control Oil Pressure-Low RPS Function at = 305 RTP. This Surveillance ensures that the associated RPS scram functions are not inadvertently bypassed with power a 305 RTP. This new Surveillance Requirement represents an additional restriction on plant operation. M.4 A Surveillance is added (ITS SR 3.3.1.1.7) to CTS Table 4.3.1-1 for the IRM Neutron Flux-High Function and the APRM Neutron Flux-High, Startup Function. This Surveillance verifies proper i overlap between the APRMs and IRMs when entering MODE 2 from MODE 1 (during a plant shutdown). This Surveillance ensures that no gaps in the neutron flux indication exists from power to subcritical operation for monitoring core reactivity status. The additional Surveillance Requirement is an additional restriction on plant operation. M.5 CTS Table 4.3.1-1 Notes (m) and (n) allow the reactor mode switch to be moved to another position without making a MODE change for O the purpose of performing Surveillance on the APRM Startup High Function (Function 2.a) and APRM Inoperative Function (Function 2.d). The notes were included per TS Amendments 96
.(Unit 1) and 121 (Unit 2). However, changing the position of the reactor mode switch is not necessary to perform these Surveillance. Since the option to change the reactor mode switch position without making a MODE change is eliminated, this change is considered a more restrictive change.
M.6 A Surveillance is added (ITS SR 3.3.1.1.14) to CTS Table 4.3.1-1 for the APRM Flow Biased Simulated Thermal Power-High Function (Function 2.b). This surveillance verifies the APRM filter time constant is :s; 7 seconds once per 24 months to ensure the APRM flow biased channel accurately reflects the desired parameter. The additional Surveillance Requirement is an additional restriction on plant operation. M.7 CTS Table 4.3.1-1 Note (c) requires IRM channels to be compared to the SRM instruments fo: 'erlap during each startup, if not performed within the 3r, ous 7 days. ITS SR 3.3.1.1.6 requires this same overlap to >e performed prior to withdrawing SRMs from the fully inserted position. Since the CTS requirement does not. b specifically identify when this requirement must be satisfied, it O BNP UNITS 1 & 2 6 Revision 0
DISCUSSION OF CHANGES I ITS: 3.3.1.1 - RPS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LF.1 used have been compared with the guidance of ISA Recommended. l (cont'd) Practice ISA-RP67.04 Part II, " Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation," - September 1994. Plant calibration procedures will ensure that the I assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Satpoints for each design or safety analysis limit have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well' as uncertainties related to process and primary element measurement accuracy using the CP&L Instrument Setpoint Methodology. The Allowable Values have been established from each design or safety analysis limit by combining the errors associated with c.hannel/ instrument calibration (e.g., device accuracy, setting tolerance, and drift) with the calculated - Nominal Trip Setpoint also using the CP&L Instrument Setpoint Methodology. Additionally, each channel / instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These evaluations and analyses have been performed utilizing the guidance provided in NEDC-31336P-A, " General Electric Instrument Setpoint Methodology." These evaluations and analyses were b performed using the GE Instrument Trending and Analysis (GEITAS) O Software tool. The GEITAS analyses are used to demonstrate that the data collected by the operating plant (from surveillance . testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints and analyzing channel / instrument performance ensure that the design basis and associated safety limits will not be exceeded during plant operation. These evaluations, determinations and. analyses now form a portion of the plants design bases.
" Specific" l L.1 In MODE 5, if a control rod is withdrawn such that positive reactivity is added, CTS Table 3.3.1-1 requires the IRM Neutron Flux - High Function, IRM Inoperative Function, Reactor Mode ,
Switch in Shutdown Position Function, and Manual Scram Function to l be OPERABLE. ITS 3.3.1.1 only requires these Functions to be l OPERABLE in MODE 5 when a control rod is withdrawn from a core cell containing one or more fuel assemblies (ITS Table 3.3.1.1-1 g ! Note (a)). Control rods withdrawn from or inserted into a core cell containing no fuel assemblies have a negligible impact 'on the
. reactivity of the core and therefore are not required to be ; .D OPERABLE with the' capability to scram. Provided all rods !
otherwise remain inserted, the RPS Functions serve no purpose and i are not required. In this condition the required shutdown margin BNP UNITS 1 & 2- 15- . Revision 0 1
DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LE.1 Function 3.d, HPCI - Condensate Storage Tank Level - Low (cont'd) This function is performed by Robertshaw Float Type Level Switches. These switches are mechanical devices that require mechanical adjustment only; drift is not applicable to these devices. Therefore, an increase in surveillance interval to accommodate a 24 month fuel cycle does not affect limit switches with respect to drift. Function 3.e, HPCI - Suppression Chamber Water Level - High b This function is performed by Robertshaw Float Type Level Switches. These switches are mechanical devices that require mechanical adjustment only; drift is not applicable to these devices. Therefore, an increase in surveillance interval to accommodate a 24 month fuel cycle does not affect limit switches with respect to drift. Function 4.a (5.a), ADS - Reactor Vessel Water Level - Low Level 3 This function is performed by a Rosemount 1153DB5 Transmitter and j 510DU Trip Units. .The Rosemount Trip Units are functionally I checked and setpoint verified more frequently, and if necessary, I recalibrates. These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate a 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift. The Rosemount 1153DB5' Transmitter drift was evaluated using the GE methodology. The results of the analysis indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. Function 4.b (5.b), ADS Initiation Timer This function is performed by Agastat 7012PEL series relays. The instrument's drift was evaluated using the GE methodology. The results of the analysis indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided for this function. It should be noted that for the 7012PEL relay, the data set used to complete the drift calculation was less than.30 points (does not provide a statistically significant sample size in accordance with the GE methodology). For this device, although the data set was less than 30 points, the overall data set for all BNP Agastat 7000 series relays is
.well. over 30 points and the GEITAS results, for this instrument, are consistent with the results of the other evaluated Agastat relays. Therefere, the combined results of these evaluations demonstrates the acceptability of extending the CHANNEL CALIBRATION interval to 24 months.
O
'BNP. UNITS l'& 2 14 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LE.1 Function 4.c (5.c), ADS Reactor Vessel Water Level - Low Level 1 (cont'd) This function is performed by a Rosemount 1153D84 Transmitter and 510DU Trip Units. The Rosemount Trip Units are functionally checked and setpoint verified more frequently, and if necessary, recalibrates. These more frequent testing requirements remain unchanged. Therefore, an increase in the surveillance interval to accommodate t 24 month fuel cycle does not affect the Rosemount Trip Units with respect to drift. The Rosemount 1153D84 Transmitter drift was evaluated using the GE methodology. The results of the analysis indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided in the setpoint calculation for this instrument. Fun'ction 4.d (5.d), ADS Core Spray Pump Discharge Pressure - High This function is performed by an ASCO SB12B pressure switch. The instrument's drift was evaiuated using the GE methodology. The results of the analysis indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided for this function. Function 4.e (5.e), ADS RHR (LPCI Mode) Pump Discharge Pressure - High This function is performed by an ASCO SB128 pressure switch. The instrument's drift was evaluated using the GE methodology. The results of the analysis indicated that the projected 30 month drift values for the instruments do not exceed the drift allowance provided for this function. Based on the design of the instrumentation and the drift evaluations, it is concluded that the impact, if any, on system availability is minimal as a result of the change in the surveillance test interval. A review of the surveillance test history was performed to validate the above conclusion. This review of the surveillance test history, demonstrates that there are no failures that would invalidate the conclusion that the impact, if any, on system availability is minimal from a change to a 24 month operating cycle. LF.1 This change revises the Current Technical Specifications (CTS) Allowable-Values for the Improved Technical Specifications (ITS). The BNP ITS Section 3.3 reflects Allowable Values consistent with the philosophy of NUREG-1433. These Allowable Values have been established consistent with the methods described in CP&L's
-Instrument Setpoint Methodology (Design Guide DG-VIII.0050 -O " Instrument Setpoints" Rev. 5). The Allowable Value V determinations were done using vendor documented performance specifications, where available and applicable. Where vendor BNP UNITS 1 & 2 15 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LF.I documented performance specifications for drift were not available (cont'd) or applicable,'the Allowable Value was determined using plant specific operating and surveillance trend data or an allowance as provided for by the CP&L's Instrument Setpoint Methodology. The Allowable Value verification used actual BNP operating and surveillance trend information to ensure the validity of the developed Allowable Value. All changes to safety analysis limits applied in the methodologies were evaluated and confirmed as ensuring safety analysis licensing acceptance limits are maintained. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ISA Recommended Practice ISA-RP67.04 Part II " Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation," September 1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for each design or safety analysis limit have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy using the CP&L Instrument n Setpoint Methodology. The Allowable Values have been established f.d from each design or safety analysis limit by combining the errors associated with channel / instrument calibration (e.g., device accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint also using the CP&L Instrument Setpoint Methodology. Additionally, each channel / instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These evaluations and analyses have been performed utilizing the guidance provided in NEDC-31336P-A, " General Electric Instrument Setpoint Methodology." These evaluations and analyses were b performed using the GE Instrument Trending and Analysis (GEITAS) Software tool. The GEITAS analyses are used to demonstrate that the data collected by the operating plant (from surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints and analyzing channel / instrument performance ensure that the design-basis and associated safety limits will not be exceeded during plant operation. These evaluations, determinations and analyses now form a portion of the plants design bases. O BNP UNITS I & 2 16 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS' RESTRICTIVE (continued) ~
" Specific" L.1 Note (a) is added to MODE 4 and 5 Applicability requirements of the Core Spray Functions (Reactor Vessel Water Level-Low Level 3, Reactor Steam Dome Pressure-Low, and CS Pump Start Time Delay Relay Functions) in CTS Table 3.3.3-1. Note (c) is added to the MODE 2 and 3 Applicability requirements of the HPCI Functions (Reactor Vessel Water Level-Low Level 2, Drywell Pressure-High, CST Level-Low, and Suppression Chamber Water Level-High Functions) and the ADS Functions (Reactor Vessel Water Level-Low Level 3, Reactor Vessel Water Level-Low Level 1, ADS Timer, Core Spray Pump Discharge Pressure-High and RHR (LPCI Mode) Pump Discharge Pressure-High) in CTS Table 3.3.3-1. These Notes require the associated ECCS Instrumentation Functions to be OPERABLE only when the associated supported system is required to be OPERABLE. This change is acceptable since the ECCS Functions serve no pur>ose when the associated supported feature is not required to >e OPERABLE. This change does not impact the ability of the ECCS instrumentation to perform its intended function which is to support ECCS in the performance of their safety function.
Additionally, this change is consistent with the CTS definition and ITS definition of OPERABILITY' requiring the associated ECCS instrumentation be OPERABLE when the ECCS are required to be O OPERABLE. The benefit of not requiring the ECCS instrumentation to be OPERABLE when its associated supported system is not required to be OPERABLE is that testing of the ECCS instrumentation is reduced and any needed maintenance may be perfomed, thereby increasing overall reliability. L.2 CTS Table 3.3.3-1 ACTION 31 requires the associated LPCI subsystem to be declarcd inoperable if one or more channels of the LPCI Reactor Vessel Shroud Level Function (CTS 3.3.3-1 Function 2.c) is inoperable. In the same condition, ITS 3.3.5.1 Required Action B.3 allows the inoperable channel (s) to be placed in a tripped condition within 24 hours. Tripping the affected channels l conservatively compensates for the inoperable status by restoring the single failure capability of the function and by accomplishing the safety function of the channel (preventing LPCI flow from being diverted from the reactor vessel when the reactor vessel L '~ water level is not at least 2/3 core height). Allowing continued operation for 24 hours with an untripped channel is acceptable since the additional time allowed to continue operation with an ECCS subsystem inoperable (as a result of the inoperabic channel being untripped) = is relatively small (8 days versus- 7 days) and the probability of an accident occurring during the additional i time period (24 hours) is low. Additionally, the Reactor Vessel l Shroud Level Function serves only as a backup to administrative controis to ensure operators do not divert LPCI flow during a LOCA. This change is consistent with NUREG-1433. I BNP UNITS.1 & 2 17 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION. TECHNICAL CHANGES - LESS RESTRICTIVE (continued) L.3 Note (b) is added to MODE 1, 2, and 3 Applicability requirements of the LPCI Reactor Steam Dome Pressure-Low Function associated with the Recirculation Pump Discharge Actuation Function in CTS Table 3.3.3-1. This change modifies the Applicability for the LPCI Function by requiring the Function to be OPERABLE in MODES 1, 2, and 3 only with the associated recirculation pump discharge valve open or recirculation pump discharge bypass valve open (in ITS Table 3.3.5.1-1, Function 2.d). This change is reasonable since this Function is only required to be OPERABLE when the recirculation valves are open which could hinder the coolant reaching the core. If.the recirculation valves are closed, the intended function is satisfied since the instrumentation's function is to close the recirculation valves. Re-opening of the valve (s) is a controlled evolution, and is not be performed without strict administrative controls. L.4 CTS Table 3.3.3-1 requires the LPCI Reactor Steam Dome Pressure-Low Function associated with the Recirculation Pump Discharge Valve Actuation (CTS Function 2.d.2) to be OPERABLE in MODES 1, 2, 3, 4, and 5. ITS Table 3.3.5.1-1 only requires this Function (ITS Function 2.d) to be OPERABLE in MODES 1, 2, and 3. In MODE 4 and 5, there is no significant reactor steam dome backpressure and the LPCI loop injection location is not critical.
- This change still ensures that the LPCI flow reaches the core during postulated events in MODE 4 or 5. As such, ITS i Table 3.3.5.1-1 Function 2.d is not required in MODE 4 or 5. j L.5 A Note (Note I to ITS 3.3.5.1 Required Actions B.1 and C.1) is added to waive CTS Table 3.3.3-1 ACTION 30 item a (which requires restoration or tripping of inoperable channels within I hour when automatic ECCS initiation capability is lost) during MODES 4 and 5. The Action to restore or trip the channel, as applicable, within 24 hours is maintained. Therefore, this change extends the allowable outage time from I hour to 24 hours in MODES 4 and 5 when ECCS initiation capability is lost. This change is acceptable since the specific initiation time of the ECCS is not assumed in MODE 4 or 5, the operator has the capability to manually initiate ECCS, and the probability of a LOCA occurring during the period (24 hours) automatic ECCS initiation capability is lost is low. This change is consistent with NUREG-1433.
L.6 CTS Table 3.3.3-1 ACTION 36 is revised to provide an alternative action to restoration when one or more inoperable ADS reactor vessel water level channel (s) exist (CTS Table 3.3.3-1 Function 4.b (Reactor Vessel Water Level-Low Level 3) and Function 4.c (Reactor Vessel Water Level-Low Level 1); ITS Table 3.3.5.1-1 Functions 4.a. 4.c, 5.a, and 5.c). This alternative action (in ITS 3.3.5.1 Required Action E.2) is to . place all inoperable channels in the tripped condition. This (] change conservatively compensates for the inoperable status, \s restores the single failure capability with regard to syste.m actuation, and provides the required initiation capability of the BNP UNITS 1-& 2 18 Revision 0
._-__________-_______-________~
-DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE L.6 ADS instrumentation. Therefore, providing this option does not (cont'd)' impact safety. However, if this. action would result in ADS timer actuation, declaring the system inoperable is the preferred action.
L.7 CTS Table 3.3.3-1 requires the LPCI Reactor Vessel Shroud Level Function (Function 2.c) to be OPERABLE in MODES 1, 2, 3, 4, and 5. ITS 3.3.5.1-1 only requires this Function (ITS Table 3.3.5.1-1 Function 2.e) to be OPERABLE in MODES 1, 2, and 3. In MODE 4 or 5, the specific initiation time of the ECCS is not assumed and the Function only serves as a backup to administrative controls to ensure operators do not divert LPCI flow during a LOCA. In MODE 4 or 5, the LPCI Functions (ITS Table 3.3.5.1-1 Functions 2.a, 2.b, and 2.c) that generate a LOCA signal ensure the associated containment spray valves automatically close during a LOCA. Additionally, the modes of the RHR System (drywell and suppression pool spray) that utilize this Function are not required to be OPERABLE in MODE 4 or 5 since primary containment is not required to be OPERABLE. As such, ITS Table 3.3.5.1-1 Function 2.e is not required in MODE 4 or 5. L.8 A new Required Action is added (ITS 3.3.5.1 Required Action D.2.2) to allow the HPCI pump suction to be aligned to the suppression l pool in lieu of tripping at least one inoperable HPCI suction swap j O- over channel (CTS Table 3.3.3-1 ACTION 33 and ITS 3.3.5.1 Required Action D.2.1), if a Condensate Sterage Tank (CST) Water Level-Low l (CTS Table 3.3.3-1 Function 3.c; ITS Table 3.3.5.1-1 Function 3.d) or Suppression Chamber Water Level-High (CTS Table 3.3.3-1 Function 3.d; ITS Table 3.3.5.1-1 Function 3.c) channel is inoperable. Since this action results in the same condition as if a channel were tripped (tripping one channel results in the HPCI pump suction being aligned to the suppression pool), the added action is functionally equivalent to the Condensate Storage Tank (CST) Water Level-Low Function and the Suppression Chamber Water Level-High Function and the ITS will allow continued operation in i an approved configuration. Therefore, this change does not have a ! significant effect on safe operation. l RELOCATED SPECIFICATIQHS, !
.R.1 The following ECCS instruments are to be relocated:
3/4.3.3.1.e Core Spray Bus Power Monitor 3/4.3.3.2.f LPCI Bus Power Monitor 3/4.3.3.3.e .HPCI Bus Power Monitor 1 O D 3/4.3.3.4.g ADS Bus Power Monitor BNP. UNITS.1 & 2 19 Revision 0 L - . - _ - - - _ - - _ _ _ - _ _ _ _ _
DISCUSSION OF CHANGES ITS: 3.3.5.1 - ECCS INSTRUMENTATION RELOCATED SPECIFICATIONS R.1 Discussion: (cont'd) The Bus Power Monitors for the RHR (LPCI), Core Spray, HPCI, and ADS' trip systems alarm if a fault is detected in the power system to the appropriate system's logic. No design basis accident (DBA) or transient analyses take credit for the Bus Power Monitors. This instrumentation provides a monitoring / alarm function only. Comparison to Screenina Criteria:
- 1. The Bus Power Monitors are'not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA.
- 2. The Bus Power Monitors are not process variables that are initial conditions of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
- 3. The Bus Power Monitors are not part of the primary success .
path that function or actuate to mitigate a DBA or transient I that either assumes the failure of or presents a challenge to the inteority of a fission product barrier.
- 4. As discussed in Sections 3.5 and 6 of NEDO-31466 and summarized in Table 4-1 (item 106) of NEDO-31466, Supplement 1, the loss of the RHR (LPCI), Core Spray, HPCI and ADS Bus Power Monitors was found to be a non-significant '
risk contributor to core damage frequency and offsite , releases. CP&L has reviewed this evaluation, considers it l applicable to BNP, and concurs with the assessment.
Conclusion:
Since the screening criteria have not been satisfied, the ECCS Actuation Instrumentation LC0 and Surveillance associated with the RHR (LPCI), Core Spray, HPCI, and ADS Bus Power Monitors may be relocated to other plant controlled documents outside the Technical Specifications (a Technical Requirements Manual). R.2 3/4.3.3.4.a ADS Inhibit Switch Discussion: The ADS ~ Inhibit Switch allows the operator to defeat ADS actuation as directed by the emergency operating procedures under conditions for which ADS would not be desirable. For example, during an ATWS event, low pressure ECCS system activation would dilute sodium V fi pentaborate injected by the Standby Liquid. Control-(SLC) System thereby reducing the effectiveness of the SLC System shutdown. BNP UNITS.1 &'2 - 20 Revision 0
9 DISCUSSION OF CHANGES ITS:.3.3.5.1 - ECCS INSTRUMENTATION RELOCATED SPECIFICATIONS R.2 Comparison to Deterministic Screenina Criteria: (cont'd)
- 1. The ADS Inhibit Switch is not an instrument used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a design basis accident (DBA).
- 2. The ADS Inhibit Switch is not used for, nor capable of, -J monitoring a process variable that is an initial condition of a DBA or transient analysis.
- 3. The ADS Inhibit Switch is not used as part of a primary success path in the mitigation of a DBA or transient. The inhibit feature was added to mitigate the consequences of an ATWS event, which is not a design basis accident or transient.
- 4. As discussed in Sections 3.5 and 6, and summarized in Table 4-1 (item 1128) of NED0-31466, the loss of the ADS Inhibit Switch was found to be a non-significant risk contributor to core damage frequency and offsite releases.
CP&L has reviewed this evaluation, considers it applicable to BNP, and concurs with the assessment. j
-(
Conclusion:
Since the screening criteria have not been satisfied, the portions l of the LCO and Surveillance applicable to the ADS Inhibit Switch may be relocated to other plant controlled documents outside the Technical Specifications (a Technical Requirements Manual). O
' BNP UNITS.1112.
21 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (continued) LF.1 This change revises the Current Technical Specifications (CTS) Allowable Values for the Improved Technical Specifications (ITS). The BNP ITS Section 3.3 reflects Allowable Values consistent with the philosophy of NUREG-1433. These Allowable Values have been established consistent with the methods described in CP&L's Instrument Setpoint Methodology (Design Guide DG-VIII.0050
" Instrument Setpoints" Rev. 5). The Allowable Value determinations were done using vendor documented performance specifications, where available and applicable. Where vendor documented performance specifications for drift were not available or applicable, the Allowable Value was determined using plant specific operating and surveillance trend data or an allowance as provided for by the CP&L's Instrument Setpoint Methodology. The Allowable Value verification used actual BNP operating and surveillance trend information to ensure the validity of the developed Allowable Value. All changes to safety analysis limits applied in the methodologies were evaluated and confirmed as ensuring safety analysis licensing acceptance limits are maintained. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ISA Recommended Practice ISA-RP67.04 Part II, " Methodologies for the Determination of Set >oints for Nuclear Safety-Related Instrumentation,"
O Septem>er 1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for es:h design or safety analysis limit have been established by accounting for the applicable instrument accuracy, , calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary Element measurement accuracy using the CP&L Instrument Setpoint Methodology. The Allowable Values have been established from each design or safety analysts limit by combining the errors associated with channel / instrument calibration (e.g., device accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint also using the CP&L Instrument Setpoint Methodology. Additionally, each channel / instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These evaluations and analyses have been performed utilizing the guidance provided in NEDC-31336P-A, " General Electric Instrument t Setpoint Methodology." These evaluations and analyses were performed using the GE Instrument Trending and Analysis (GEITAS) Software tool. The GEITAS analyses are used to demonstrate that the data collected by the operating plant (from surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. D O : i BNP UNITS.1 & 2 23 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.6.2 - SECONDARY CONTAINMENT ISOLATION INS ~...dMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LF.1 associated with channel / instrument calibration (e.g., device (cont'd) accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint also using the CP&L Instrument Setpoint Methodology. Additionally, each channel / instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These evaluations and analyses have been performed utilizing the guidance provided in NEDC-31336P-A, " General Electric Instrument Setpoint Methodology." These evaluations and analyses were 8 performed using the GE Instrument Tronding and Analysis (GEITAS) Software tool. The GEITAS analyses are used to demonstrate that the data collected by the operating plant (from surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints and analyzing channel / instrument performance ensure that the design basis and associated safety limits will not be exceeded during plant operation. These evaluations, determinations and analyses now form a portion of the plants design bases.
" Specific" L.1 The Applicability of the Reactor Building Exhaust Radiation-High Function of CTS Table 3.3.2-1 and Table 4.3.2-1 is revised from "0PERATIONAL CONDITIONS 1, 2, 3, 5, and when irradiated fuel is being handled in secondary containment" to " MODES 1, 2, 3, during movement of irradiated fuel assemblies in secondary containment, during CORE ALTERATIONS, and during operations with the potential for draining the reactor vessel (0PDRVs)" in ITS 3.3.6.2, Secondary Containment Isolation Instrumentation. The Reactor Building Exhaust Radiation-High function is required to support the OPERABILITY of secondary containment isolation dampers and the Standby Gas Treatment System to ensure fission products entrapped within secondary containment are treated prior to discharge to the environment. When the plant is in MODE 4 or 5, the probability and consequences of a design basis accident that is postulated to leak fission products into snondary containment are reduced due to the temperature and pressure limitations in these MODES.
However, in MODE 4 or 5, activities are conducted for which significant releases of radioactivity are postulated. Therefore, Reactor Building Exhaust Radiation-High function is only required to be OPERABLE in MODE 4 or 5, when activities are in progress which could, if an event occurs, result in significant releases of radioactivity (during movement of irradiated fuel assemblies in secondary containment, during CORE ALTERATIONS, or during OPDRVs). O This change alters the Applicability of the Reactor Building Exhaust Radiation-High function of CTS Table 3.3.2-1 and Table 4.3.2-1 to only include these activities. This is BNP UNITS 1 & 2 8 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.7.1 - CREV SYSTEM INSTRUMENTAL 1oN TECHNICAL CHANGES - LESS RESTRICTIVE i LF.1 ensuring safety analysis licensing acceptance limits are (cont'd) maintained. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equi ment are maintained. The methodologies used have been compared witi the guidance of ISA Recommended Practice ISA-RP67.04 Part II, " Methodologies for the Determination of Setsoints for Nuclear Safety-Related Instrumentation," Septeumr 1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for each design or safety analysis limit have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process i and primary element measurement accuracy using the CP&L Instrument Setpoint Methodology. The Allowable Values have been established from each design or safety analysis limit by combining the errors associated with channel / instrument calibration (e.g., device accuracy, setting tolerance, and drift) with the calculated l Nominal Trip Setpoint also using the CP&L Instrument Setpoint Methodology. Additionally, each channel / instrument has been evaluated and analped to support a fuel cycle extension to a 24 month interval. O These evaluations and analyses have been performed utilizing the guidance provided in NEDC-31336P-A, " General Electric Instrument Setpoint Methodology." These evaluations and analyses were ( perforined using the SE Instrument Trending and Analysis (GEITAS) Software tool. The GEITAS analyses are used to demonstrate that the data collected by the operating plant (from surveillance testing) has remained acceptibic and reasonable with regard to the manufacturers design specifications. Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints and analyzing channel / instrument performance ensure that the design basis and associated safety limits will not be exceeded during plant operation. These evaluations, determinations and analyses now form a portion of the plants design bases. I
" Specific" i L.1 The Applicability of CTS 3.3.5.5, Control Room Emergency Ventilation System Instrumentation, is revised from Operational i Conditions 1, 2, 3, 4, 5, and when irradiated fuel is being handled in secondary containment to MODES 1, 2, and 3, during !
movement of irradiated fuel assemblies in secondary containment, , during CORE ALTERATIONS, and during operations with the potential ! for draining _the reactor vessel (0PDRVs) in ITS 3.3.7.1, Control O. Room Emergency Ventilation (CREV) System Instrumentation. CREV System 1:: required to be OPERABLE to control operator The l BNP UNITS 1 & 2 6 Revision 0
DISCUSSION OF CHANGES ITS: 3.3.8.1 - LOSS OF POWER INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LE.1 . A review of the surveillance test history was performsd to (cont'd) validate the above conclusion. This review of the surveillance test history, demonstrates that there are no failures that would invalidate' the conclusion that the impact, if any, on system availability is minimal from a change to a 24 month operating . cycle. ' LF.1 This change revises the Current Technical Specifications (CTS) Allowable Values for the Improved Technical Specifications (ITS). The BNP ITS Section 3.3 reflects Allowable Values consistent with the philosophy of NUREG-1433. These Allowable Values have been established consistent with the methods described in CP&L's Instrument Setpoint Methodology (Design Guide DG-VIII.0050
" Instrument Setpoints" Rev. 5). The Allowable Value determinations were done using vendor documented performance specifications, where available and applicable. Where vendor documented performance specifications for drift were not available or applicable, the Allowable Value was determined using plant specific operating and surveillance trend data or an allowance as provided for by the CP&L's Instrument Setpoint Methodology. The Allowable Value verification used actual BNP operating and surveillance trend information to ensure the validity of the developed Allowable Value. All changes to safety analysis limits applied in the methodologies were evaluated and confirmed as
( ensuring safety analysis licensing acceptance limits are maintained. All design limits applied in the methodologies were confirmed as ensuring that applicable design requirements of the associated systems and equipment are maintained. The methodologies used have been compared with the guidance of ISA Recommended Practice ISA-RP67.04 Part II, " Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentht'~.," September 1994. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance are maintained. Setpoints for each design or safety analysis limit have been established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy using the CP&L Instrument Setpoint Methodology. The Allowable Values have been established from each design or safety analysis limit by combining the errors associated with channel / instrument calibration (e.g., device j accuracy, setting tolerance, and drift) with the calculated i Nominal Trip Setpoint also using the CP&L Instrument Setpoint ! Methodology. l Additionally, each channel / instrument has been evaluated and ! analyzed to support a fuel cycle extension to a 24 month interval. These evaluations and analyses have been performed utilizing the f' guidance provided in NEDC-31336P-A, " General Electric Instrument Setpoint Methodology." These evaluations and analyses were b ; performed using the GE Instrriment Trending and Analysis (GEITAS) BNP. UNITS 1 & 2 6 Revision O'
DISCUSSION OF CHANGES ITS: 3.3.8.1 - LOSS OF POWER INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE LF.1 Software tool. The GEITAS analyses are used to demonstrate that (cont'd) the data collected by the operating plant (from surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints and analyzing channel / instrument performance ensure that the design basis and associated safety limits will not be exceeded during plant operation. These evaluations, determinations and analyses now form a portion of the plants design bases.
" Specific" L.1 In the event one or more 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) channels are inoperable, the CTS Table 3.3.3-1 ACTION 34 would require the associated emergency diesel generator (s) to be declared inoperable immediately. ITS 3.3.8.1 Required Action A.1 provides I hour for this condition to attempt to evaluate and repair any discovered inoperabilities. This I hour time period is considered to be acceptable because it minimizes risk while providing time for restoration or tripping of I hour time period provided in ITS 3.0.3. The levels of C-)' degradation represented by the inoperability of one or more 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) channels would be no more severe than the levels of degradation that would require entry into ITS 3.0.3. The change will provide consistency in ACTIONS for this level of degradation.
L.2 An additional Required Action is provided (ITS 3.3.8.1 Required Action B.1) to require declaring the DG inoperable and taking the appropriate actions in the associated DG Specification if a channel is not tripped within 1 hour. Currently, CTS l Table 3.3.3-1 ACTION 35 appears to require a CTS 3.0.3 entry if l the channel is not tripped, which would result in an immediate shutdown. Since this instrument is the start signal for the DGs (i.e., it supports DG OPERABILITY), the appropriate action would be to declare the DG inoperable. The current requirements are overly restrictive, in that if the diesel were inoperable for other reasons, a 7 day restoration time is provided; yet currently if an instrument is inoperable but the diesel is otherwise fully OPERABLE, an immediate shutdown is required. L.3 This change adds a Note (Note 2) to the Surveillance Requirements of CTS 3/4.3.3 that will allow a 2 hour delay from entering into the associated Conditions and Required Actions for a channel placed in an inoperable status solely for performance of required f Surveillance provided: (a) the 4.16 kV Emergency Bus Undervoltage ( (Loss of Voltage) Function (ITS Table 3.3.8.1-1 Function 1) maintains initiation capability for three DGs bhp UNITS 1 & 2 7 Revision 0 l
a DISCUSSION OF CHANGES ITS: 3.3.8.2 - RPS ELECTRIC POWER MONITORING l TECHNICAL CHANGES - LESS RESTRICTIVE LF.1 supply fluctuations, as well as uncertainties related to process (cont'd) and primary element measurement accuracy using the CP&L Instrument Setpoint Methodology. The Allowable Values have been e.=tablished from each design or safety analysis limit by combining the errors associated with channel / instrument calibration (e.g., device accuracy, setting tolerance, and drift) with the calculated Nominal Trip Setpoint also using the CP&L Instrument Setpoint-Methodology. Additionally, each channel / instrument has been evaluated and analyzed to support a fuel cycle extension to a 24 month interval. These evaluations and analyses have been performed utilizing the guidance provided in NEDC-31336P-A, " General Electric Instrument Setpoint Methodology." These evaluations and analyses were g l performed using the GE Instrument Trending and Analysis (GEITAS) Software tool. The GEITAS analyses are used to demonstrate that the data collected by the operating plant (from surveillance testing) has remained acceptable and reasonable with regard to the manufacturers design specifications. Use of the previously discussed methodologies for determining Allowable Values, instrument setpoints and analyzing channel / instrument performance ensure that the design basis and associated safety limits will not be exceeded during plant O operation. These evaluations, determinations and analyses now form a portion of '.he plants design bases.
" Specific" L.1 The Applicability for CTS 3.8.2.5 is whenever the respective power supply is supplying power to the RPS bus. The Applicability of ITS 3.3.8.2 is specified as MODES 1 and 2 and MODES 3, 4, and 5 c with any control rod withdrawn from a core cell containing one or more fuel assemblies. In MODE 3, 4 or 5 with no control rods withdrawn from core cells containing fuel assemblies or when the unit is defueled, there is no need for the RPS to perform its function and therefore, there is no need to require the protectbn provided by the RPS electric power monitoring assemblies.
Therefore, the Applicability is changed to only include those E MODES or Conditions when the RPS is requfred. In addition, this change _is consistent with the NRC Safet/ Evaluation for d Amendment 64 (Unit 1) and Amendment 89 pnit 2) which added the CTS requirements for the RPS electric power monitoring assemblies. This NRC SER states "The change is intended to assure that the power produced by the RPS motor-generator sets is of a quality acceptable to the RPS." l O ; BNP UNITS 1 & 2 5 Revision 0
O RPS Instrumentation 3.3.1.1 i 3.3 INSTRUMENTATION I 3.3.1.1 Reactor Protection System (RPS) Instrumentation l
- 2. 2. I ' LC0 3.3.1.1 The RPS instrumentation for each Function in Table 3.3.1.1-1
/A.2,c.* t shall be OPERA 8LE.
1,.si/t4.t APPLICA8ILITY: According to Table 3.3.1.1-1.
/c. 'z ACTIONS l
NOTE
/A,3 Separate Condition entry is allowed for each channel.
CONDITION RE511 RED ACTION COMPLETION TIME 2.2.s A. One or more required A. ' Place channel in 12 hours 4cmo channels inoperable. trip. ) ca.i v sa. d'"
- A.2 Place associated trip 12 hours
^ *4 system in trip.
31: Acn*4 b 3 "
/L44 1
- 8. One or more Functions 8.1 Place channel in one 6 hours 7 ^*'
"*# with one or more trip system in trip.
required channels
/'"*** inoperable in both QB 7.s trip systems.
Ame8 b.2 8.2 Place one trip system 6 hours
/t a. 5 in trip.
9.s., C. One or more Functions C.1 Restore RPS trip 1 hour b a tm.; with RPS trip capability.
/u.g capability not 33 , maintained.
A. a 4. 6
. (continued)
/p4.'Z EN 3.3-1 - L e 1, Ot/07/05 g
I N' *E " ' hnsubmt &, '; 40 oil hbc.R Pf5 l
--__ ________-__a
JUSTIFICATION FOR DEVIATIONS FRON NUREG-1433, REVISION 1 SECTION 3.3 - INSTRUMENTATION
- 1. Not used.
O
- 2. The brackets are removed and the proper plant specific information/value is provided.
BNP UNITS I & 2 1 Revision 0
9-RPS Instrumentation B 3.3.1.1 BASES ACTIONS B.1 and B.2 (continued) system in trip would result in a ser , I Condition D aust be entered and its Requireu action taken. ! u Required Action C.1 is in{ ended to ensure that appropriate actions are taken if multiple, inoperable, untripped [ ' channels within the same trip system for the same Function result in the Function not maintaining RPS tr'p capability. A Function is considered to be maintaining RPS trip capability when sufficient channels are ADERABLE or in trip (or the associated trip system is in trip), such that both trip systems will generate a trip signal from the given Function on a valid signal. For the typical Function with one-out-of-two taken twice logic and the IRM and APRM Functions, this would require both trip systems to have one channel OPERABLE or in trip (or the associated trip system in trip). For Function 5 (Main Steam Isolation A Valve-Closure), this would require both trip systems to Q have each channel associated with the MSIVs in three main steam lines (not necessarily the same main steam lines for both trip systems) OPERABLE or in trip (or the associated tripsystemintrip).3 (For Function 8 (Turbine Stop Valve-Closure), this would require both tr:p systems to have three channels, each PERABLE or in trip (or the associated trip system in trip). The Completion Time is intended to allow the operator tiac to evaluate and repair any discovered inoperabilities. The I hour Completion Time is accepteble because it minimizes risk while allowing time for restoration or tripping of channels. M Required Action D.1 directs entry into the appropriate . Condition referenced in Table 3.3.1.1-1. The applicable l Condition specified in the Table is Functicn and H00E or l other specified condition dependent and may change as the Required Action of a previous Condition is completed. Each time an inoperable channel has not met any Required Action (continued) . 1 0 -tMtit 573^ - B 3.3-21 ng , , ,3 A Q g For k% t o (%4 t%&<. S.dhA - SG%m ga N:A J
)..0 r
f: A bA u has dry qs% 4,y /u,. h m I h c % d g uire, a orckste ,, ;,, 4;( (,, L (nu<:J!d +:( yh .in +g ). -
RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the. reactor coolant shall be liefted to DOSE EQUIVALENT.!-131 specific activity s 0.2 pCi/ge. APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant -------------NOTE----------- specific activity LCO 3.0.4 is not applicable.
> 0.2 pCi/gm and ----------------------------
s 4.0 C1/gm DOSE E EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours EQUIVALENT I-131. O = A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. M 93 B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity QB
> 4.0 pCi/gm DOSE f:
EQUIVALENT I-131. g (continued) Brunswick Unit 1 3.4-12 Amendment No.
Recirculatten Loops Operating ) B 3.4.1 BASES APPLICABLE A plant specific LOCA analysis has been performed assuming SAFETY ANALYSES only one operating recirculation loop. This analysis has (continued) demonstrated that, in the event of a LOCA caused by a pipe break in the operating recirculation loop, the Emergency Core Cooling System response will provide adequate core cooling, without the requirement to modify the APLHGR i requirements (Ref. 3). j The transient analyses of Chapter 15 of the UFSAR have also been performed for single recirculation loop operation (Ref. 3) and demonstrate sufficient flow coastdown , characteristics to maintain fuel thermal margins during the
#9rmal operational transients analyzed without the requirement to modify the MCPR requirements. During single recirculation loop operation, modification to the Reactor Protection System (RPS) average power range monitor (APRM) instrument setpoints may be required to account for the different relationships between recirculation drive flow and reactor core flow by depressing a switch on the flow control trip reference cards of the APRM Flow Biased Simulated Thermal Power-High instrumentation. This manual action will adjust the flow control trip reference card to the setpoint map for single recirculation loop operation.
hd However, in accordance with Reference 3, no modifications to the APRM Flow Biased Simulated Therral Power-High setpoint b are currently required. Recirculation loops operating satisfies Criterion 2 of Reference 4. LC0 Two recirculation loops are normally required to be in operation with their recirculation pump speeds matched within the limits specified in SR 3.4.1.1 to ensure that during a LOCA caused by a break of the piping of one recirculation loop the assumptions of the LOCA analysis are satisfied. Alternately, with only one recirculation loop in operation, modifications to the required APLHGR limits (LCO 3.2.1, " AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)"), MCPR limits (LC0 3.2.2, " MINIMUM CRITICAL POWER RATIO (MCPR)"), and APRM Flow Biased Simulated Thermal Power-High setpoint (LCO 3.3.1.1), as applicable, must be applied to allow continued operation. However, based on the analyses in Reference 3, no modifications to the APLHGR limits, MCPR limits, or APRM Flow Biased Simulated Thermal b Power-High setpoint are required for the current operating cycle. O (continued) b Brunswick Unit 1 B 3.4-3 Revision No.
l l RCS Sp;cific Activity B 3.4.6 i (O U BASES : l l APPLICABLE that the 2 hour thyroid and whole body doses at the site ! SAFETY ANALYSES boundary, resulting from an MSLB outside containment during (continued) steady state operation, will not exceed 10% of the dose guidelines of 10 CFR 100. RCS specific activity satisfies Criterion 2 of Reference 4. LCO The specific iodine activity is limited to s 0.2 pCi/gm DOSE EQUIVALENT I-131. This limit ensures t'ne se'Jrce terP assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 100 limits. APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment. In MODES 2 and 3 with the main steam lines isolated, such (' limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced. ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LC0 t DOSE EQUIVALENT I-131 limit, but is s 4.0 C1/gm, samples f must be analyzed for DOSE EQUIVALENT I-131 at least once l every 4 hours. In addition, the specific activity must be restored to the LCO limit within 48 hours. The Completion Time of once every 4 hours is based on the time needed to take and analyze a sample. The 48 hour Completion Time to ; restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems. The upper limit of 4.0 Ci/gm ensures that the thyroid dose from an MSLB will not exceed the dose guidelines of 10 CFR 100 or control room operator dose limits specified in GDC 19 of 10 CFR 50, Appendix A (Ref. 5). g (continued) g Brunswick Unit 1 B 3.4-26 Revision No. l
i RCS Sp:cific Activity ! B 3.4.6 , j l BASES
' ACTIONS -
A.1 and A.2 (continued) A Note to the Required Actions of Condition A excludes the MODE change restriction of LCO 3.0.4. This exception allows entry into the applicable MODE (S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation. B.I. B.2.1. B.2.2.1. and B.2.2.2 l l If the DOSE EQUIVALENT I-131 cannot be restored to s 0.2 pCi/gm within 48 hours, or if at any time it_is > 4.0 E pCi/ge, it must be determined at least once every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the j environment in an amount that is more than a small fraction ' O of the requirements of 10 CFR 100 during a postulated MSLB accident. Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is l provided for those instances when isolation of main steam l L '~ lines is not desired (e.g., due to the decay heat loads). ' In MODE 4, the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is the time needed l to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without , challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. ! (continued) ; i l' O
-Brunswick. Unit 1 B 3.4-27 Revision No. l C '
z
i RCS Specific Activity 3.4.6 I l 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity s 0.2 pC1/ge. APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. t ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME l A. Reactor coolant -------------N0TE----------- I specific activity LCO 3.0.4 is not applicable. l > 0.2 pCi/gm and ---------------------------- s 4.0 pCi/gm DOSE 6 EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours EQUIVALENT I-131. O = A.2 Restore DOSE 48. hours EQUIVALENT I-131 to within limits. B. Required Action and 8.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. AND M B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity M i > 4.0 Ci/gm DOSE E lA I EQUIVALENT I-131. (continued) Brunswick Unit 2 3.4-12 Amendment No.
1 ) Recirculation Lo ps Operating B 3.4.1 BASES APPLICABLE A plant specific LOCA analysis has been performed assuming , SAFETY ANALYSES only one operating recirculation loop. This analysis has (continued) demonstrated that, in the event of a LOCA caused by a pipe break in the operating recirculation loop, the Emergency Core Cooling System response will provide adequate core !. cooling, without the requirement to modify the APLHGR requirements (Ref. 3). The transient analyses of Chapter 15 of the UFSAR have also been performed for single recirculation loop operation 1 (Ref. 3) and demonstrate sufficient flow coastdown characteristics to maintain fuel thermal margins during the abnormal operational transients analyzed without the requirement to modify the MCPR requirements. During single recirculation loop operation, modification to the Reactor Protection System (RPS) average power range monitor (APRM) instrument setpoints may be required to account for the different relationships between recirculation drive flow and reactor core flow by depressing a switch on the flow control trip reference cards of the APRM Flow Biased Simulated Thermal Power-High instrumentation. This manual action will adjust the flow control trip reference card to the setpoint map for single recirculation loop operation. However, in accordance with Reference 3 no modifications to the APRM Flow Biased Simulated Thermal Power-High setpoint bj i are currently required. ' Recirculation loops operating satisfies Criterion 2 of l Reference 4. l LCO Two re:irculation loops are normally required to be in operation with their recirculation pump speeds matched within the limits specified in SR 3.4.1.1 to ensure that during a LOCA caused by a break of the piping of one recirculation loop the assumptions of the LOCA analysis are satisfied. Alternately, with only one recirculation loop in operation, modifications to the required APLHGR limits ; (LCO 3.2.1, " AVERAGE PLANAR LINEAR HEAT GENERATION RATE ! , (APLHGR)"), MCPR limits (LC0 3.2.2, " MINIMUM CRITICAL POWER i RATIO (MCPR)"), and APRM Flow Biased Simulated Thermal ! Power-High setpoint (LC0 3.3.1.1), as applicable, must be ' applied to allow continued operation. However, based on the analyses in Reference 3, no modifications to the APLHGR limits, MCPR limits, or APRM Flow Biased Simulated Thermal h Power-High setpoint are required for the current operating cycle. (continued) Brunswick' Unit 2 B 3.4-3 Revision No.
(- I RCS Sp:;cific Activity B 3.4.6 BASES ( .. . h APPLICA8LE 'that the 2 hour thyroid and whole body doses at the site SAFETY ANALYSES boundary, resulting from an MSLB outside containment during (continued) steady state operation, will not exceed 10% of the dose guidelines of 10 CFR 100. RCS specific activity satisfies Criterion 2 of Reference 4. l LCO The' specific iodine activity is limited to-s 0.2 pCi/gm DOSE EQUIVALENT I-131. This limit ensures the source. term
. assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 100 limits.
APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment. In MODES 2 and 3 with the main steam lines isolated, such O limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced. l ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LC0 DOSE EQUIVALENT I-131 limit, but is s 4.0 C1/ge, samples must be analyzed for DOSE ECUIVALENT I-131 at least once b every 4 hours. In addition, the specific activity must be restored to the LC0 limit within 48 hours. The Completion Time of once every 4 hours is based on the time needed to take and analyze a sample. The 48 hour Completion Time to restore the activity level provides a reasonable time for temporary coolant. activity increases.(iodine spikes or crud i bursts) to be cleaned up with the normal processing systems. A The upper limit of 4.0 pCi/gm ensures that the thyroid dose (B from an'MSLB will not exceed the dose guidelines of l 10 CFR 100 or control room operator dose limits specified in /A GDC 19 of 10 CFR 50, Appendix A (Ref. 5). G' (continued) i O ! ! . Brunswick' Unit 2 B 3.4-26 Revision No.. .I
RCS Specific Activity B 3.4.6 j i BASES ACTIONS A.1 and A.2 (continued) A Note to the Required Actions of Condition A excludes the MODE change restriction of LC0 3.0.4. This exception allows entry into the applicable MODE (S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the { i plant remains at, or proceeds to power operation. B.I. B.2.1. B.2.2.1 and B.2.2.2 If the DOSE EQUIVALENT I-131 cannot be restored to s 0.2 pCi/gm within 48 hours, or if at any time it is > 4.0 Ci/gs, it must be determined at least once every 4 hours b and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the q environ.nent in an amount that is more than a small fraction Q of the requirements of 10 CFR 100 during a postulated MSLB accioent. l Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). , In MODE 4, the requirements of the LC0 are no longer l applicable. The Completion Time of once every 4 hours is the time needed l to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without l challenging plant systems. i (continued)
/O V
Brunswick Unit 2 B 3.4-27 Revision No.
l 4
. . .ir." ' - -
., 7 '
S.>g eh e Sw S.Y b , ,9 A. ( I
\yl )
f 3 Q EACTOR CC01. ANT SYSTEM 3/T/.5 #ECIFIVACTIVITY' IT COE ON F PERA LN MG @ The specific activity of the reactor coolant shall be limited to: less than or equal to 0.2 pCI/ gram COSE EQUIVALENT I-131@ l h[1/s' thkor 9 egal to L86/E 9Cl/ Afa l APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3 4 l 2-ACTION:
*I* ' *
- 3 * * '* N**
l.1
,( with the specific activity of
$ In OPERATIONAL. CONDITION the reactor coolants h l Creater than 0.2 pCi/ gram DOSE EQUIVALENT I-131 but less than or l
[@ equal to.4.0 DC1/ gram, operation may continue for up to 48 hours provfi ed thy operayatn unpr Enese j conittjens sn 11 f.3 o es ed lv pereedt of the unit',( total fearly abt 4 bWod 0 me .The previsions og specification 3.0.4 are not applicable. h Creater than 0.2 pC1/ gram Dose EQUIVALENT I-131 for more than k g- ' ((D 48 hours during one continuous time interval or greater than ( 4.0 uC1/ ramL npe in at teast nut SHUTDOWN with the main stes L.t ACNdB ilfre'"Tsolation valves closed within 12 hours.j { t
'd7MCITgr "iiI,lTITE~leastl0T S DOWN wit ~ l
/. Cre er than th main et m line iso clon val s clospf with COLD SN DOWN with the nex 24 houci.
12 hour nd I8 h In OPERATIONAL CONDITION 1, , 44
@ With the specific activity a the primary coolant greater than 0.2 uC1/ gram _ DOSE EQUIVALENT I-13 lap' grotter/theVQ
" * j 6087E A iMreaffiertorm ine sampling and analysts requirements A._
,'6 of Item 4b of Table 4.4.5-1 at least once per 4 hours until the A.1 a B.I specific activity of the primary coolant is restored __to within
( its limits. Jn ieu og a License vent Repo t, prepare no bel to the mmissi n within days, p suant to T f,tl Spec ficatto 6.9.2, Special sport tha' defines t. results of he spec it ac vity anal ses and th time dura son when e s ecific civity f the co ant excee d 0.2 uCl/ ram DOSE l VALE I-131 & - "trh eb blau mMition 1 informa ion w
% iRn5;ICx - UNIT 1 m 4-10 meneent No. n wm
..;; . 's -
- r. f,; U ..
A.\ ke&cdw ~5. 4, c O COOLANT SYSTEM
, 3/4 4 SPECIFIC ACTIVITY ITI COND ON FOR OPERATIO 4 Co 3. al,6 @ The spee.lfic activity of the reactor coolant shall be limited tot h less than or equal to 0.2 pCi/ gram DOSE EQUIVALENT I-13 g l han or / qual / 100/E uCFIgr l
((les APPLICA8ILITY: OPERATIONAL CONDITIONS 2,, 3 ACTION 8
"*J A83 sb l c wI itelJ p , and 3) with the specific activity of In OPERATIONAL CONDITION the teactor coolants h
p creater than 0.2 pCi/ gram DOSE EQUIVALENT I-131 but less than or equtL_to bD pC! /***=; anarmelan may continue for to 48 houra)lirovped that 3peration upder these nettron 1 pt egleed HI percent gf the uniz"s total arly op stipf b3 "O O a pr,ovisions of Specificatico 7.0.4 are not appticavis. (l
- Cp Crescer than 0.2 pCi/ gram DOSE EQUIVALENT I-131 for more than k 48 hours during one continuous time interval or greater than Q
\g
( 4.0 uci/ gram,fliE'in at least NOT SHUTDOWN with the main steam g"g
/t.no4 0 dTne isotmeinn vaivas cle.md wichtn 12 hours. {
. ester an 100/E Ci/ gram, e in at ast HOT UTDOWN with l
. he ma steam e isolat n valves Losed w n 12 hour ad E./
in SHUTD@di within e next 2 hours. In OPERATIONAL CONDITION 1, ,3
@ L.L G1 With the specific activity the primary coolant gre er than 0.2 pCi/ gram DOSE EQUIVALENT I-13JJpegegaterAhga 4.s 7Q "g Ach ,q L (00/F"urAI====spersors sne sampatas and analysis ce of item 4b of Table 4.4.5-1 at least once per 4 hours until the rements specific activity of the primary coolant is restored t.o within .
b.Ii 3 I i ( its ilmits. [In lie of a icensee vent Repo s, prep e sud teston ithin 3 days, pu uant to l Dat to p ic ion .2, a pecial port tha defines he ces ts [A f he pecif e acti ty anal es and t time dt/ stion gram en the SE /, 1 I spec ic ac vity the co ant esce ed 0.2 AL I-131 ogether th the ow addi onal 'l orma[on.l {EQU __} 1 i BRUNSWICK - UNIT 2 3/4 6-10 Amendment No. 110 _p N of h
) 1 l I RCS Specific Activi 3.47, crsik 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4 CS Specific Activity I LCO The specific activity of the reactor coolant shall be 8,##/4.l 32 [0 limited to DOSE EQUIVALENT I-131 cpecific activity 5J(0.2}r.,_/ pC1/ga.
/4.2. APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated.
/4.1,4 4/, ACTIONS b CONDITION REQUIRED ACTION COMPLETION TIME 7d>f A. Reactor coolant NOTE A4 specific activity LC0 3.0.4 is not applicable.
e.lgg > (0.2) pC1/gm and g 4.0 pC1/gm DOSE i EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours g EQUIVALENT I-131. 3 Y m A I A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. 3 .d. f B. Required Action and 8.1 Detemine DOSE Once per 4 hours j 4 a.2/ . associated Completion Time of Condition A EQUIVALENT I-131. i LL not met. M E B.2.1 Isolate all main 12 hours steam lines. Reactor /oolant specific activi E
-131. .h
{4.0FpC1/ h{> EQUIVALENT g (continued) ! D /4-ST [ 3.4-16 M cv 1, O'/07/9 6
JUSTIFICATION FOR DEVIATIONS FROM NUREG-1433, REVISION 1 l SECTION 3.4 - REACTOR COOLANT SYSTEM
\
17 'he Frequency of NUREG-1433 SRs 3.4.10.3. and 3.4.10.4 states "Once within 15 minutes prior to each startup of a recirculation pump." The 15 minute time period in these SRs is revised in BNP ITS SR 3.4.9.4 and SR 3.4.9.5 to "Once within 30 minutes prior to each startup of a recirculation pump" consistent with the current BNP licensing basis. I 18. TSTF-60 revisions are not incorporated in BNP ITS 3.4.5 (NUREG-1433 l Specification 3.4.6) since BNP ITS 3.4.5 Required Action D.1 (NUREG-1433 1 Specification 3.4.6, Required Action F.1) does not allow continued operation when all required leakage detection systems are inoperable.
- 19. Typographical error corrected.
I 20. Not used. 1 k I O i O BNP UNITS 1 & 2 3 Revision 0 i l
f \ RCS Specific Activit B 3.4 6/ BASES APPLICA8LE outside containment during steady state operation, will not . SAFETY ANALYSES exceed 105 of the dose guidelines of 10 CFR 100. (continued) Ahe Yi ts on s fic act ty are val from a par t ' feva ion o ypical s locations s se limi I servat becaus e evaluati conside re restri ve par rs than fo specific e, such as loc on of th its bounda and the orological conditions o the site. RCS specific activity satisfies Criterion 2 of @ d>T1cm4tatemen&.<e-e a. 4D LCO The specific iodine activity is limited to s40.2DC1/gm DOSE EQUIVALENT I-131. This limit ensures the source ters assumed in the safety analysis for the MSL8 is not exceeded, so any release of radioactivity to the environment during an MSL8 is less than a small fraction of the 10 CFR 100 limits.
% APPLICA8ILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated limits on the primary coolant radioactivity are 3 applicable since there is an escape path for release of I radioactive material from the primary coolant to the environment in the event of an MSL8 outside of primary containment.
In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced. ACTIONS AJ and A.2 h When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT I-131 limit, but is s 4.0 pC1/ge, samples must be analyzed for DOSE EQUIVALENT I-131 at least once every 4 hours. In addition, the specific activity must be restored to the LC0 limit within 48 hours. The Completion (continued) N/4 .O- - 8 3.4-34 2
" 1, e4/e?l05 t
h_e uppr - li d <d 4.07 Ci/p e w,,, -; Q tW.e ui.\i ~ 4 e xcerA L -th red dese L a-3 s o ent too or < ~4<. I
% % close fel: clue es .cL-: 45 sp,,m,J RCS Specific Activit r o. e- . pe r.,&
*^ G tz. t <1 4 gocn go , Ag:, 4 ,
g 3,4 b J 8ASES '(Re4.5)./. ACTIONS A.] and A.2 (continued) Time of once every 4 hours is based on the time needed to ' take and analyze a sample. The 48 hour Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud ( bursts) to be cleaned up with the normal processing systems.] A Note to the MODE change reRequired striction ActionsThis of LCO 3.0.4. of Condition A excludes the exception allows entry into the applicable MODE (S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation. B.1. B.2.1. B.2.2.1. and B.2.2.2 h A If the DOSE EQUIVALENT I-131 cannot be restored to s 0.2 pCl/gm within 48 hours, or if at any time it is > 4.0 pCi/ge, it must be determined at least once every 4 hours i and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident. Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is p;ovided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LC0 are no longer applicable. The Completion Time of once every 4 hours is the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating (continued) M/ B 3.4-35 "lEvt, M/07/M %. 1
ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required core spray (CS) 12 hours subsystem, the:
- a. Suppression pool water level is 2 -31 inches; or
- b. -----------------NOTE-----------------
Only one required CS subsystem may take credit for this option during OPDRVs. Condensate storage tank water volume is 2 228,200 gallons. d SR 3.5.2.3 Verify, for each required ECCS injection / 31 days spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve. SR 3.5.2.4 -------------------NOTE-------------------- One LPCI subsystem may be considered l OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable. Verify each required ECCS injection / spray 31 days subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. (continued) Brunswick Unit 1 3.5-10 Amendment No.
o ) L ECCS-Shutdown B 3.5.2 i i
- BASES SURVEILLANCE SR '3.5.2.1'and SR 3.5.2.2 (continued) j REQUIREMENTS that either the suppression pool water level is a -31 inches or that the CS pump is aligned to take suction from the CST a i
and the CST contains a total volume, which includes both. gl l usable and unusable volumes, of a 228,200 gallons of water, ensures that the CS System can supply at least ! 50,000 gallons of makeup water to the RPV. CS System air ' ingestion is expected to occur at the level which corresponds to a CST volume of 178,200 gallons. However, as 81 noted, only one required CS subsystem may take credit for the CST option during OPDRVs. During OPDRVs, the volume in the CST may not provide adequate makeup.if the RPV was completely drained. Therefore, only one CS subsystem is I allowed to use the CST. This ensures the other required ECCS subsystem has adequate makeup volume.
]
The 12 hour Frequency of these SRs was developed considering operating experience related to suppression pool water level and CST water level variations. Furthermore, the 12 hour Frequency.is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool or CST O water level condition. SR 3.5.2.3. SR 3.5.2.5. SR 3.5.2.6. and SR 3.5.2.7 The Bases provided for SR 3.5.1.1, SR 3.5.1.6, SR 3.5.1.9, and SR 3.5.1.12 are applicable to SR 3.5.2.3, SR 3.5.2.5, SR 3.5.2.6, and SR 3.5.2.7, respectively. SR 3.5.2.4 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths exist for ECCS operation. -This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve that (continued) , I O '
. Brunswick. Unit'l -B 3.5-22 Revision No.
_-____.__.__._..________.._.._..i...
1 ECCS-Shutdown B 3.5.2 -) BASES SURVEILLANCE SR 3.5.2.4 (continued) REQUIREMENTS receives an initiation signal is allowed to be in a j nonaccident position provided the valve will automatically l reposition'to the accident position in the proper stroke l time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that i cannot be inadvertently misaligned, such as check valves. The 31 day Frequency is appropriate because the valves are operated under procedural control and the probability of l their being mispositioned during this time period is low. l In MODES 4 and 5, the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Therefore, this SR is i modified by a Note that allows one LPCI subsystem to be l considered OPERABLE if it is capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes the period when the required RHR pump is not operating and the period when the system is being Oe realigned to or from the RHR shutdown cooling mode. Because U of the low pressure and low temperature conditions in MODES 4 and 5, sufficient time is available to manually align and initiate LPCI subsystem operation to provide core cooling prior to postulated fuel uncovery. This will ensure , adequate core cooling if an inadvertent RPV draindown should i occur. l REFERENCES 1. NED0-20566A; General Electric Company Analytical Model for Loss-of-Coolant Analysis in Accordance with 1 L 10 CFR 50 Appendix K, Vols. 1, 2, and 3; September 1986.
- 2. 10 CFR 50.36(c)(2)(ii).
l i i
' Brunswick Unit 1 B 3.5-23 Revision No. !
I-
R ECCS-Shutdown 3.5.2 l i I SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required core spray (CS) 12 hours subsystem, the:
- a. Suppression pool water level is 2 -31 inches; or
- b. -----------------NOTE-----------------
Only one required CS subsystem may take credit for this option during OPDRVs. Condensate storage tank water volume is 2 228,200 gallons. b SR 3.5.2.3 Verify, for each required ECCS injection / 31 days spray subsystem, the piping is filled with water from the pump discharge valve to the p injection valve. b SR 3.5.2.4 --
----------------NOTE--------------------
One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable. Verify each required ECCS injection / spray 31 days i subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. (continued) O (_/ Brunswick Unit 2 3.5-10 Amendment No.
i ECCS-Shutdown l B 3.5.2 ' BASES l l . SURVEILLANCE SR- 3.5.2.1 and SR 3.5.2.2 (continued)-
-REQUIREMENTS
- that either the suppression pool water level is 2 -31 inches or that the CS pump is aligned to take' suction from the CST and the CST contains a total volume, which includes both usable and unusable volumes, of. 2 228,200 gallons of water, 8
ensures that the CS System can supply at least 50,000 gallons of makeup water to the. RPV. CS System air ingestion is expected to occur at the level which corresponds to a CST volume of 178,200. gallons. However, as b noted, only one required CS subsystem may take credit for the CST option during OPDRVs. During OPDRVs, the volume in the CST may not provide adequate makeup if the RPV was completely drained.. Therefore, only one CS subsystem is allowed to use the CST. This ensures the other required ECCS subsystem has adequate makeup volume. The 12 hour Frequency of these SRs was developed considering operating experience related to suppression pool water level and CST water level variations. . Furthermore, the 12 hour Frequency is considered adequate in view of other indications available in the control room, including alarms, to' alert the operator to an abnormal suppression pool or CST water level condition. l O> SR 3.5.2.3. SR 3.5.2.5. SR 3.5.2.5. and SR 3.5.2.7 The Bases provided for SR 3.5.1.1, SR 3.5.1.6, SR 3.5.1.9, and SR 3.5.1.12 are applicable to SR 3.5.2.3, SR 3.5.2.5, l .SR 3.5.2.6, and SR 3.5.2.7, respectively. SR 3.5.2.4 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since 1 these valves are verified to be in the correct position ! prior to locking, . sealing, or securing. A valve that l-(continued) l l 1' 1 Brunswick Unit 7 B 3.5-22 . Revision No. l l _________._-__-_-___-_________-__D
ECCS-Shutdown B 3.5.2 BASES 1 1 SURVEILLANCE SR 3.5.2.4 (continued) REQUIREMENTS receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition tc the accident position in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The 31 day Frequency is appropriate because the valves are l operated under procedural control and the probability of their being mispositioned during this time period is low. In MODES 4 and 5, the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Therefore, this SR is modified by a Note that allows one LPCI subsystem to be considered OPERABLE if it is capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. Alignment and operation for decay heat removal includes the period when the required RHR pump is not operating and the period when the systtu is being O realigned to or from the RHR shutdown cooling mode. Because of the low pressure and low temperature conditions in MODES 4 and 5, sufficient time is available to manually u align and initiate LPCI subsystem operation to provide core l cooling prior to postulated fuel uncovery. This will ensure adequate core cooling if an inadvertent RPV draindown should occur. 1 REFERENCES 1. NED0-20566A; General Electric Company Analytical Model for Loss-of-Coolant Analysis in Accordance with 10 CFR 50 Appendix K. Vols. 1, 2, and 3; September 1986. l
- 2. 10 CFri 50.36(c)(2)(ii).
l l l O V Brunswick Unit 2 B 3.5-23 Revision No. I
I
$>ecEicosn f E.S~2 O CT 005K C00LINC SYSTDC R U cr M c.coti nou no*J 3 .3 (c mupJcr yeog)5ygf(q a
~
3/4 ,$.3 14W PRESSURE Coot,INC SYSTDtB g SY q, 8 l LIMITINC ITI FOR 0 ERA ON tco I.5".s 3.0.0.5 Two O f- M [ re Spray' System (CSS) 's'ubsystems Shall be OPERASLE with ch subsystem comprasee oss } dee.,M a. pump and
- b. An 0 LE f1 path ca le of takin suction fr at.less one of the 11owing PERASLE urces and tr eferring t water t rough
, spra sparse to the r ctor vessel
- 1. In OPERATIONAL CONDITION 1, 2, or 3, from the suppression po l In OPERATIONAL CONDITION 4 or $*l I
@ go a) From the a rossion pool, o W D,%
b) he suppression L is inoperable com th ensate storage k containlag at east C ons AFpLICASILITY OPERATIONALCONDITIONSf,2,3)4, ands *. l ACTION: ,y,y, g
- a. In OPERATIONAL CONDITION 1, 2, or 38 - -
l
- 1. With one CSS subsystem looperable, POWER OPERATION esy continue provided both LPCI subsysteme are OPERASLE restore the inoperable CSS subsystem to OPERASLE status within 7 days or be ,
la at least NOT SNUTDOWN within the next 12 hours and i.a COLD ! SNUTDOWN within the following 24 hours.
- 2. With both CSS subsystems inoperable, be in at least NOT SNUTDOWN within 12 hours and la COLD SNUTDOWN within the neat 24 hours.
4A h eerf $ . a-. g,5,
- w ... ...., .,. _ u = ...... ..
.s f
. c ha u e t r-Mar vtse(L heeqE r---M d be catief t edgThe spent fue MI pool Sates @ removed 3 andh water levelC, s wames.with g*7 p t.obll4) @ =i- -^ r- l^1- ons e r and YD g
% w p.5..e -><J
-, b -fb _,.
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O >c->>> ><4 >-4 4e ent No. - ya
bCAbc LC 2, 6 M A0fE C00dWC SYSTb($ M , y LLIN ON OF ION )' ACTION (Continued)
- 3. In the event the CSS is actuates and injects water into the -
reactor coolant system, a Special Report shall be prepared and dee M5h submitted to the Coassissio. pursuant to Specification 6.9.2 7* g, g , within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.
%. In 6PERATIONRYCONDITIOtt 4 or 5* 5 ;p,9
,S. With one es inoperable peration any continue provided that at least one subsystem is OPERABLE within 4 40 j) -
hoursljtherwise,4uspend_ all operations that have potential for AcvwJ 6 - draining t actor _vesset. g44 s;% oega LI l
't With both bsyst le, operation may continue
- provided that at least on subsystem is OPERABLE and both *
$ 4 LICI subsystems are OPERABLE within 4 h jours.therwies,'Wouspend
[* att operations that have a potentisi for draining the reactor Scma t. vessel and @E187"EEED t least one @ subsystem M y within 4 hours. ec.c.s iajec%pg b . provjefo'as of Seselficatlog#.T.3 are,,,,,mdf applica,,)1d. h-V SURVEILLANCE REQUIRDtENTS Eac CSS subsystem shall be demonstrated OPERA 8LE: l f} 3 D. ' (g) At least ones rer 12 hours @ verify (ED che condensate storage tank
'<difna,ausr1~ eeestilb volune e wh,en the condensate storage tank is required L g g.f.2.2.b to be OPERABLE. @ 222( 9 16s]
k At least once pir 31 days by: , 3
% Verifying that the ystem piping fres the pump discharge valve 4* f g f,.f,2. 3 to theqrtgDesMTet35F8D valve is filled with water.
$35.tl e m- r . .. ... - E ret - g d ;,; 6 ;,,; -_ gr ed thee thd l 38*1 '-
e[#vesset heet is remoWand the cameo is E ed.J he spent fuel j h oot. 5" S& 1 gates @ removed, and QG water leve16s mR9staineuw-ithin%A map-m spec,puhttons 3 Ave and Jh.9_D [ h2.th.10IA.8ve N k N
~K & ens f reneI 1 44.$e.. J l
SEUNSWICE - UNIT 1 3/4 5-5 Amendment No. 98 O t
( C hCdoh 3,C 2 F " 9 :V Cott C001.INC SYSTEM @ b Y z y -~~- Wp t_f g av==_ og pos PERA OM/ 1 I#* E 4.".3.^ Two([nde@seden[ Core Spray System (CSS) subsystems shall be OPERABLE wit each sub ystem c- eased ora p.I a One , and -
- b. An 0F LE flow th capabi of takin suction os at less one of the fo11 og 0F LE source and tran erring t water the the spray a ser to th reactor esels h.TT5:
~ *' 1. In OPERATIONAL CONDITION 1r 2,or3,fromthesuppressionpoo13 l
.l
@ In OPERATIONAL CONDITION A or 5* @ 200]
k Pr suppressi pool, or
~
~
cts k p.l b) the sup selon pool i noperable ros th condensate orage tar.k ejMhtaining at east Lons of water O APPLICABILITY ACTION: OPERATIONAL CONDITIONS 1, 2, 3 4, and $*. Ice _T75' 3,3,i
- a. In OPERATIONAL CONDITION 1, 2, or 3
- 1. With one CSS subsystem inoperable, POWER GPERATION may continue provided both LPCI subsystems are OPERABLEI restore the inoperable CSS subsystem to CPERA&LE status within 7 days or be in at least NOT SNUTDONN within the nest 12 hours and in COLD SNUTDOWN within the follotring 24 hours.
- 2. With both C&$ subsystems inoperable, be in at least NOT SNUTDOWN )
within 12 hoors and in COLD SNUTDOWN within the nest 24 hours. j 07cepi u)
~
- S: "a-a :r ; :;;;=g __'; -'..,. .J ;;
ve n g _ Ahttj@)
. E73 -- % e caerty 4 he spent fuel yg,g r g Mt vaseet == - in -
1 setes hromoved. --' <sKh water _ level (asylatsipeMthiM M00ig ,ggggg,,,y,g g 3,gy,-) f f h tty. loin oe:s* & & S N 4er- Pessu re. vusel Se. y
~
0 . >c- 1' - >< -- >>> pge.9 o& l6 l
- , - u .;
~
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. k.M Cott.JOtO NG M
/_CIMIUmr T=TITION ryrpERATI0ll.lrContiadfdI)
A. TION (Continued)- bene event ene c5s is actuated and injects water into the g yj- 3f reactor coolant system, a Special Report shall be prepared and 3,C / submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total acw laced actuation evelas to date.
)G In OPERATIONAL CONDITION 4 or $*3 jggy With one ubsystem inoperable, operation may continue ,l ubsystem is OPERABLE within 4-provided that at'least one Md A bonestft'Eerwise,puspend t all o rations media* t have a potential 4 ely ini+iale. ebnvo Action B-[ for draining eactor vesset.. -
j dec+w/1froy) _
. A;( With both systions ino cante operation may continue u system is OPERABLE and both s
- ha A .,dprov.ded that at least oneL LPCI subsystems are OPERABLE within i
a 1. operations that have a potential for eraaning subsystem Na-arradacza the reactor
/O.I ga g vessel and(GMTy JEEh at least one 5/,qecWsprwg within 4 hours.
D, g rovis g ef Sp fe6catio [n.3 are,mrt applicpirt) SURVEILLANCE sj siigEMENTS g3 - 4seetri CSS subsystem shall be demonstrated OPERABLE At least once per 12 hou verify @ the condensate storage tank p.D g the condensate storage tank is required (minimum - ---@ volume W IS*2A*O Eo be OFEEAELE. g g urp jg
)t At least once per 31 days by:
- A, Verifying that the kstem piping from the pump discharge valve
! to the esism-iso.Aserosp valve is filled with water. f( i,5. L3 0^5t'$ (eycef i hA et.atretshJ n: .e.. . .e7 .;n = n = . a;i_;" a ;,.Msit -Tflo-fr.d dthe fn cav spent _tuel y,g reager-vessee w ___._ A.7.- took gates (19tremoved, and@ water level (isY.etlid wtQin %e p gammt saporticapairs JJG ad43JD ElEloia.ovt/~ k k o hb .
\
450 etahr frenu4 p.. veese.A &!9 I
!! 3/4 5-5 Amendment No. 127 BRUNSWICK - UNIT 2 y lo 0% %
1 1
.1
i DISCUSSION OF CHANGES ITS: 3.5.2 - ECCS-SHUTDOWN ADMINISTRATE 1y1 (continued) A.6 CTS 4.5.3.1.a requires verifying the CST volume is above the minimum required volume. ITS SR 3.5.2.2.b includes the acceptance criteria (a: 228.200 gallons) consistent with the limit stated in b the CTS 3.5.3.1.b.2.b). Since this change is an enhanced presentation of existing intent, the change is considered l administrative. A.7 Not used. l l I A O A.0 CTS 4.5.4.2 requires periodic verification that the specified applicable conditions of CTS 3.5.4 are met when the suppre r, ion pool is ino>erable. Periodic verification that the unit condition remains witiin the Applicability and that entry into an ACTION has not occurred is not used in the BWR Standard Technical Specifications, NUREG-1433 (and not typically found in current Technical Specifications). In general, this type of requirement is addressed by plant specific processes which continuously monitor plant conditions to ensure changes in MODES or specified applicable conditions are performed in accordance with Technical Specifications and that changes in the status of that plant that ; require entry into ACTIONS are identified in a timely manner. As i a result, CTS 4.5.4.2 serves no safety purpose and is not included in ITS 3.5.2. Since this change is an enhanced presentation of existing intent, the change is considered administrative. BNP UNITS l i 2 2 Revision 0 l l l
L ECCS-Shutdown 3.5.2 C T5 /bOC. -
- /4. 7 SURVEILLANCE RE0UIRENENTS (continued)
SURVEILLANCE FREQUENCY
/A.3 3R 3.5.2.2 Verify, for each required core spray (CS) 12 hours subsystem, the:
- a. Suppression pool water level is agrMgnches); org b STE
/ A 2- Only one required CS subsystem may take credit for this option during OPNVs. I l
4
- b' E I " Condensate storage tank water is I
uf,% bh p 4 g SR 3.5.2.3 Verify, for each required ECCS injection / 31 days 4 53.1.6.i spray subsystem, the piping is filled with
/A 1 - water from the pump discharge valve to the 4,9 3, 2 , ,,, ' injection valve.
/A 5 SR 3.5.2.4 STE
/t..G One LPCI subsystem may be c'onsidered OPERABLE during alignment and operation for decay heat removal if capat 1 of being l manually realigned and not otherwise I inoperable.
l (. 4.5 h ...t. Verify each required ECCS injection / spray 31 days !
/A 3 subsystem manual, power operated, and
- 4. 5. 3.1. h 2. automatic valve in the flow path, that is fa.3 not locked, sealed, or otherwise secured in position, is in the correct position.
(continued) l A .
. .,.- ..i-q . _JP -
EwaN m 3.5 ,v rnu 4 n
- o. ,
4
. 4 .:. .
ECCS-Shutdown 8 3.5.2 BASES ACTIONS C.1. C.2. D.I. D.2. and D 3 (continued) necessary to perfom the Surveillance needed to demonstrate the OPERABILITY of the components. If, however, any required component is inoperable, then it must be restored to OPERABLE status. In this case, the Surveillance may need ) to be performed to restore the component to OPERABLE status. Actions must continue untti all required components are OPERABLE. M.* * \ [The 4 hour Completion Time to restore at least one low paws mst./ pressure ECCS injection / spray subsystem to OPERABLE status
, ensures that prompt action will be taken to provide the required cooling capacity or to initiate actione to place the plant in a condition that minimizes any potential fission product release to the environment. j SURVEILLANCE SR 3.5.2.1 and SR 3.E.2.2 7
~3 REQUIREMENTS . _ _2 The sinteum water level of inchest required for the suppression pool is periodic verified to ensure that'the k suppression pool will provide adequate net positive suction head (NPSH) for the CS Systes and LPCI subsystes pumps, recirculation volume, and vortex prevention. With the ,
suppassion pool water level less than the required limit, all ECCS injection / spray subsystems are inoperable unless they are aligned to an OPERABLE CST. _ When suppression pool level is < KWCsa inchesh the CS System is considered OPERABLE only f ut can take suction from the CST, and the CST water level is aufficient to provide the required NPSH for the CS pump. Therefore, a r' - ve fication that either the suppression pool water level is 2( a4sr@9nchest or thath n ananaa to ma - ttan et Ml wku.w%h
- i. m. we m and the m wnd unst $ES9"DBOL callons o water Jan vusm ta 47 J5b ensures that the'CS system can jupoo
@P iui.L., A susolyat'eastf54,000$gallonsofmakeupwatertotheRPV. I ussWg. amef Khe A.3 -- -- - --- -- -- JI Ene M UU . ---_BallnWle W uusdie ' ver -as noted, only one required CS;siosystem may take }
*b *7 credit for the CST option during OPDRVs A During OPDRVs, the s
. volume in the CST may not provide adequate makeup if the RPV A m completely drained. Therefore, only one CS subsystes &d s allowed to use the CST. This ensures the'other required ECCS subsystem has adequate sakeup volume.
cs r uh .: , ; % h n < , ,,d el 4 . .c M. (continued)
,wk <.%.a s
- i csr v.t. ef /
M Ni,ni'.280 d**8f 8 3.5-20 a= !. ^"n7/ed K) i a , a
RHR Suppression Pcol Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression ------------NOTE------------- pool cooling subsystem LCO 3.0.4 is not applicable. inoperable. ----------------------------- A.1 Restore RHR 7 days suppression pool cooling subsystem to ,Q OPERABLE status. (_./ B. Two RHR suppression B.1 Restore one RHR 8 hours pool cooling subsystems inoperable. suppression pool cooling subsystem to 8 OPERABLE status. 1 C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. AN_D C.2 Be in MODE 4. 36 hours o Brunswick Unit 1 3.6-24 Amendment No.
CAD System 3.6.3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify 2: 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 b) 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 O l l l l b i i Brunswick Unit 1 3.6-28 Amendment No.
I PCIVs I B 3.6.1.3 -l BASES SURVEILLANCE SR 3.6.1.3.3 (continued) REQUIREMENTS administrative controls, such as those that limit the shelf life of the explosive charges, must be followed. The 31 day Frequency is based on operating experience that has i demonstrated the reliability of the explosive charge ! continuity. SR 3.6.1.3.4 l Verifying the isolation time of each power operated and each l automatic PCIV is within limits is required to demonstrate 1 OPERA 8ILITY. MSIVs may be excluded from this SR since MSIV-full closure isolation time is demonstrated by SR 3.6.1.3.5. The isolation time test ensures that each valve will isolate l in a time period less than or equal to that assumed in the
- safety analyses. The isolation time and Frequency of this 1
SR are in accordance with the requirements of the Inservice 3' Testing Program. SR 3.6.1.3.5 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA and transient analyses. This ensures that the calculated radiological consequences of these events remain within 10 CFR 100 limits. The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program. SR 3.6.1.3.6 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. This SR includes ; verifying that each automatic PCIV in the Containment l Atmosphere Dilution System flow path will actuate to its isolation position on the associated Group 2 and 6 primary b= containment-isolation signals. The LOGIC SYSTEM FUNCTIONAL 1 TEST in LCO 3.3.6.1, " Primary Containment Isolation ' I (continued) Brunswick Unit 1 B 3.6-26 Revision No.
h PCIVs B 3.6.1.3 BASES SURVEILLANCE -SR 3.6.1.3.6 (continued) REQUIREMENTS Instrumentation," overlaps this SR to provide complete testing of the safety function. The 24 month Frequency was developed considering it is prudent that this Surveillance be performed only during a unit outage since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components. 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 3.6.1.3.7 This SR requires a demonstration that each reactor instrumentation line excess flow check valve (EFCV) is OPERABLE by verifying that the valve actuates to the isolation position on an actual or simulated instrument line break signal. This may be accomplished by cycling the EFCV through one complete' cycle of full travel. This SR provides assurance that the instrumentation line EFCVs will perform O so that predicted radiological consequences will not be exceeded during a postulated instrument line break event. 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 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 3.6.1.3.8 The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired cr from another batch that has been certified by having one of the batch successfully fired. The Frequency of this SR 1 is in accordance with the requirements of the Inservice l Testing _ Program. (continued) Brunswick Unit 1 B 3.6-27 Revision No. i
CAD System B 3.6.3.2 i I) 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 3.6.3.2.3 g 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 l will pass this Surveillance when performed at the 24 month i Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. p lb O REFERENCES 1. Safety Guide 7 March 1971. i l
- 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.
f'\
'd Brunswick Unit 1- B 3.6-67 Revision No.
Seccndary Containment B 3.6.4.1 B 3.6 CONTAll# LENT SYSTEMS B 3.6.4.1 Secondary Containment BASES BACKGROUND The function of tho' 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 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 t a e 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 for the pressure in the O 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 volume pressure at less thar. the external pressure. Requirements for these 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 environment. Secondary containment satisfies Criterion 3 of-10 CFR 50.36(c)(2)(ii) (Ref. 4). (continued) Brunswick Unit 1: B 3.6 Revision No.
Secondary Containment B 3.6.4.1 BASES (continued) 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 i 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 consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining
>t 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 l be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE . ALTERATIONS, or during movement of irradiated fuel j assemblies in the secondary containment. ACTIONS- A.1 ! If secondary containment is inoperable, it must be restored i to OPERABLE status within 8 hours. The 8 hour Completion l 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 i' ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods i where secondary containment is inoperable is minimal. (continued) l 1 Brunswick Unit- 1 B 3.6-69 Revision No. ___=
S:cendary 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 hours and to MODE 4 within 36' hours. 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 L challenging plant systems. l 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 inoperable. Suspension of these O 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 0PORVs 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 , stating that LC0 3.0.3 is not applicable. If moving l 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 l case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. (continued) l I 1 f((
- 8r'unswick Unit 1 B 3.6-70 Revision No.
l __a__ - _ _ _ _ _ - -
Secondary Containment l B 3.6.4.1 BASES (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 requires 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. O To ensure that fission products are treated, SR 3.6.4.1.3 verifies that the SGT System will establish and maintain a h 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 l 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 l 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) l l l I Brunswick Unit 1- B 3.6-71 Revision No. l l
S cendary Containment B 3.6.4.1 e BASES (continued) REFERENCES 1. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.
- 2. UFSAR, Section 15.6.4.
- 3. 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.
t l l
,a l U
Brunswick UnitII' B 3.6-72 Revision No. iT
SCIDs B 3.6.4.2 8 3.6 CONTAINMENT SYSTENS B 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs) BASES I 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 OPERA 8LE or take place outside primary containment, are maintained within the secondary containment boundary. l 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 signal to establish a boundary for untreated radioactive material within secondary containment following a DBA or other accidents. l 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 l 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. (continued) O Brunswick Unit 1 B 3.6-73 Revision No. I
SCIDs B 3.6.4.2 O =a s APPLICA8tE 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 10 CFR 50.36(c)(2)(ii) (Ref. 4). LC0 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 8 l times are within limits, and the dampers are capable of I 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 e release to the primary containment that leaks to.the 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 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)
L Brunswick Unit 1 B 3.6 Revision No. __m_u_-..._.am____-_.--__.m_ u
1 SCIDs B 3.6.4.2 j 1 T BASES l (G 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 t 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. The third Note ensures appropriate remedial actions are taken, if necessary, if the affected system (s) are rendered inoperable by an inoperable SCID. A.I and A.2 In the event that there are one or more penetration flow j paths with one SCID inoperable, the affected penetration i 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. I n Isolation barriers that meet this criterion are a closed and l (j 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 hour Completion Time. The specified time period is reasonable considering the time required to isolate the penetration, and the probability of a DBli, which 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. [i q) (continued) Brunswick Unit 1 8 3.6-75 Revision No.
l. ' .SCIDs l B 3.6.4.2 BASES ACTIONS A.] and A.2 (continued) l l Required Action A.2 is modified by a Note that applies to l devices located in high radiation areas and allows them to l be verified closed by use of administrative controls. 1- 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. Ad With two SCIDs in one or more penetration flow paths inoperable, the affected penetration flow patii must be isolated within 4 hours. 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 hour 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 beer, modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation da.pers. This clarifies that only Condition A is entered if one SCID is. inoperable in each of two penetrations. 1. 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 1 MODE in which the LCO does not apply. To achieve this ' status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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) g b Brunswick Unit 1 B 3.6-76 Revision No. L l-
. _ _ _ _ _-_________--- _ _--___.-_---__--_-_---- - - - - Q
SCIDs B 3.6.4.2 BASES ACTIONS D.I. 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 i 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 componer.t 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 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 fuel while in MODF. 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either crte, inability to suspend movement of irradiated fuel assemblies would not be a l sufficient reason to require a reactor shutdown. l SURVEILLANCE SR 3.6.4.2.1 REQUIREMENTS Verifying that the isolation time of each automatic SCID is within limits, by cycling each SCID through one complete b 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. l Operating experience has demonstrated these components will l usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. j i SR 3.6.4.2.2
- Verifying that each automatic SCID closes on a secondary containment isolation signal is required to minimize leakage -l of radioactive material from secondary containment following l (continued)
O Brunswick Unit 1 B 3.6-77 Revision No.
I SCIDs B 3.6.4.2 BASES SURVEILLANCE SR 3.6.4.2.2 (continued) REQUIREMENTS 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 l FUNCTIONAL TEST in LC0 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 ) i the potential for an unplanned transient if the Surveillance l 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 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.
- 2. UFSAR, Section 15.6.4.
- 3. UFSAR, Section 15.7.1.
- 4. 10 CFR 50.36(c)(2)(ii).
- 5. Technical Requirements Manual.
I f3 ! V ! Brunswick Unit 1 B 3.6-78 Revision No.
I SGT System B 3.6.4.3
, 8 3.6 CONTAINMENT SYSTEMS B 3.6.4.3 Standby Gas Treatment'(SGT) System.
BASES i- 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 suctica duct, two parallel and l 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): i
- 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
' profilter removes large particulate matter, while the HEPA ~
L (continued) Brunswick Unit 1- B 3.6-79 Revision No. a___l _ _ __x _ = _
SGT System B 3.6.4.3 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 adsortier. 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 10 CFR 50.36(c)(2)(ii) (Ref. 5). O 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 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 (0PDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment. (continued) Brunswick Unit 1 B 3.6-80 Revision No. l f
SGT System B 3.6.4.3 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
- 7. days. In this condition, the. remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a 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 LC0 does not apply. To achieve this status, the plant must be brought to at least 1 MODE 3 within 12 hours and to MODE 4 within 36 hours. 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. L.d With one SGT subsystem inoperable during movement of irradiated fuel assemblies in secondary containment, during CORE ALTERATIONS, or during OPDRVs, the inoperable subsystem l 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) - 11]g ) Brnswick Unit 1 B 3.6-81 Revision No.
I-SGT System ( B 3.6.4.3 i BASES , 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'0PERABLE 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
- p subsequent potential for fission product release. Actions iy must continue until OPDRVs are suspended.
LCO 3.0.3 is not applicable in MODE 4 or S. 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. i l Suspension of these activities shall not preclude completion i of movement of.a component to a safe position. Also, if (continued) ;
-Brunswick Unit 1- B 3.6-82 Revision No.
l i 4 L_________ _ _ _ ____--_-__________-_______-_-__--_.-___ .________ .
SGT System B 3.6.4.3 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 untti 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 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 ara 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 control _for a 10 continuous hours every 31 days eliminates g moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan 4otors and controls and the redundancy available in tha ; tem. SR 3.6.4.3.1 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6), except as specified in Specification 5.5.7, " Ventilation Filter Testing Program (VFTP)". The VFTP includes testing HEPA (continued) O Brunswick Unit 1 B 3.6-83 Revision No.
SGT System B 3.6.4.3 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 activated 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 pass 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-32466r, Pot 1er 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. bll l
l Brunswick Unit 1 0 3.6-84 Revision No. l L__-____--_______-____ - _ _ _ _ _
RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression ------------NOTE------------- pool cooling subsystem LC0 3.0.4 is not applicable. inoperable. ----------------------------- A.1 Restore RHR 7 days suppression pool cooling subsystem to OPERABLE status. L B. Two RHR suppression B.1 Restore one RHR 8 hours pool cooling subsystems inoperable. suppression pool cooling subsystsa to b OPERABLE status. C. Required Action and C.! Be in MODE 3. 12 hours associated Completion Time not met. AND C.2 Be in MODE 4. 36 hours O Brunswick Unit 2 3.6-24 Amendment No.
CAD System 3.6.3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify 2: 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 44 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 O a l b V Brunswick Unit 2 3.6-28 Amendment No.
o PCIVs B 3.6.1.3 BASES
~ SURVEILLANCE SR 3.6.1.3.3 (contnued)
REQUIREMENTS administrative controls, such as those that limit the shelf life-of the explosive charges, must be followed. . The 31 day Frequency is based on operating experience that has demonstrated the reliability of the explosive charge continuity. SR 3.6.1.3.4 1 Verifying the isolation time of each power operated and each automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.5. The isolation time test ensures that each valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the requirements of the Inservice Testing Program. SR 3.6.1.30 Verifying that the isolation time of each MSIV is within the - specified limits is required to demonstrate OPERABILITY. The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA and transient analyses. This ensures that the calculated radiolog: cal consequences of thase events remain within 10 CFR 100 limits. The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program. SR 3.6.1.3.6 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. This SR includes verifying that each automatic PCIV in the Containment
. Atmosphere Dilution System flow path will actuate to its isolation position on the associated Group 2 and 6 primary d containment . isolation signals. The LOGIC SYSTEM FUNCTIONAL '
TEST.in LCO 3.3.6.1, " Primary Containment Isolation (continued) IBrunswick Unit 2 B 3.6-26' ' Revision Nc. n____-----------------------.-
-- -)
PCIVs B 3.6.1.3 BASES SURVEILLANCE- SR 3.6.1.3.6 (continued) REQUIREMENTS Instrumentation," overlaps this SR to provide complete testing of the safety function. The 24 month Frequency was developed considering it is prudent that this Surveillance be performed only during a unit outage since isolation of penetrations would eliminate cooling water flow and disrupt the nonsal operation of many critical components. 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 3.6.1.3.7 This SR requires a demonstration that each reactor instrumentation line excess flow check valve (EFCV) is OPERA 8LE by verifying that the valve actuates to the isolation position on an actual or simulated instrument line break signal. This may be accomplished by cycling the EFCV through one complete cycle of full travel. This SR provides assurance that the instrumentation line EFCVs will perform O so that predicted radiological consequences will not be exceeded during a postulated instrument line break event. 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 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 3.6.1.3.8 The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib I shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program. (continued) Brunswick Unit 2- B 3.6-27 Revision No. I
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 3.6.3.2.3 d 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. b 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.
b l O ! .. Brunswick Unit 2 B 3.6-67 Revision No. I I
Secondary Containment B 3.6.4.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.4.1 Secondary Containment 3ASES 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 i 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 for the pressure in the O 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 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 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. 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 10 CFR 50.36(c)(2)(ii) (Ref. 4). (continued) Brunswick Unit 2 8 3.6-68 Revision No.
Sscendary Containment B 3.6.4.1 BASES (continued) LC0- 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 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 a require primary containment OPERABILITY. In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining O secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except fcr 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)3 during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment. ACTIONS Ad If secondary containment is inoperable, it must be restored to OPERABLE status within 8 hours. The 8 hour 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) O Bruttswick Unit 2 B 3.6-69 Revision No.
S:cendary Containment B 3.6.4.1 BASES ('~} U 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 hours and to MODE 4 within 36 hours. 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.l. 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 [s 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 ainimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPORVs 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 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. (continuedi d(~h Brunswick Unit 2 B 3.6-70 Revision No.
Seccndary Containment B 3.6.4.1 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 I 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 /A leak tightness. Maintaining secondary containment W 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. l 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 b O: verifies that the SGT System will establish and maintain a 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 ai the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. (continued) O 1 Brunswick Unit 2 B 3.6-71 Revision No. f
-l Stcondary Containment i B 3.6.4.1 l
-( BASEE (continued) REFERENCES 1. NEDC-32466? 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). q l
'l O
i O ; Brunswick Unit 2 B'3.6-72 Revision No.
1 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 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. G Q Automatic SCIDs close on a secondary containment isolation signal to establish a boundary for untreated radioactive 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 to ensure that leakage from the primary containment is processed by the Standby Gas Treatment (SGT) System before being released to the environment. (continued) O(~'N Brunswick Unit 2 B 3.6-73 Revision No.
SCIDs. B 3.6.4.2 l BASES APPLICA8LE 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 10 CFR 50.36(c)(2)(11) (Ref. 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 lend to a fission product release to the primary containment that leaks to the (, secondary containment. Therefore, the OPERABILITY of SCIDs l ' 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 ) 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. (~Y (continued) V , i Brunswick Unit 2 B 3.6-74 Revision No.
3CIDs 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 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. The third Hote ensures appropriate remedial actions are taken, if necessary, if the affected system (s) are rendered inoperable by an inoperable SCID. j s 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 mest 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 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 l secondary containment. The Required Action must be l~ completed within the 8 hour Completion Time. The specified time period 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. For affected penetrations that have been isolated in accordance with Required Action-A.1, the affected
)enetration must'be verified to be isolated on a periodic sasis. 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 2 B 3.6-75 Revision No.
I
1 l SCIDs B 3.6.4.2 O BASES U ACTIONS A.] and A.2 (continued) Required Action A.2 is modified by a Note that applies to I devices located in high radiation areas and allows them to I 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, lLd With two SCIDs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active tailure. Isolation barriers that meet this criterion are a closed and de-activated automatic damper, a closed manual damper, and a blind flange. The 4 hour Completion Time is reasonable g- considering the time required to isolate the penetration and the probability of a DBA, which requires the SCIDs to close, iY occurring during this short time, is very low. i 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 i 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 MODE in which the LC0 does.not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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. l (continued) O
\._)
Brunswick Unit 2 B 3.6-76 Revision No. l l
l SCIDs ! B 3.6.4.2 l 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 LC0 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 j 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 LCO 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 movement of irradiated fuel assemblies would not be a O 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 A 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) Brunswick Unit 2 8 3.6-77 Revision No.
SCIDs-B 3.6.4.2 BASES-SURVEILLANCE SR 3.6.4.2.2(continued) REQUIREMENTS 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 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. 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. Technical Requirements Manual.
O Brunswick Unit'2- B 3.6-78 Revision No.
SGT System B 3.6.4.3 B 3.6 CONTAINMENT SYSTEMS ('] B 3.6.4.3 Standby Gas Treatment (SGT) System 8ASES 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. l 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; p 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 I containment at a negative pressure of at least 0.25 inches l' 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) LJ Brunswick Unit 2 B 3.6-79 Revision No.
SGT System B 3.6.4.3 C BASES k 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 10 CFR 50.36(c)(2)(ii) (Ref. 5). , i 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 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 release to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES. I 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) l Brunswick Unit 2 B 3.6-80 Revision No. l
L SGT System B 3.6.4.3 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 7 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a 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 LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MCDE 4 within 36 hours. The O 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. 1
.G.d 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 conditic,, the retaining 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 b Brunswick Unit 2 B 3.6-81 Revision No.
l SGT System L B 3.6.4.3 BASES ACTIONS -D.1.'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 0PDRVs, 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 l 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 applic.able, )
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 l 3, the Required Actions of Condition D have been modified by l a Note stating that LCO 3.0.3 is not applicable. If moving I 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 i case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a L reactor shutdown. i E.1. E.2. and E.3 L > 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 i
. Brunswick Unit 2 B 3.6-82 Revision No.
( - ! SGT System B 3.5.4.3 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, l 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 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. SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem, by initiating (from the (q v; control room) flow through the HEPA filters and charcoal adsorbers, for 2 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 control for a 10 continuous hours every 31 days eliminates g 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 Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6), except as I specified in Specification 5.5.7, " Ventilation Filter A l Testing Program (VFTP)". The VFTP includes testing HEPA (continued) Brunswick Unit 2 B 3.6-83 Revision No. 1 i
F [ SGT System B 3.6.4.3 BASESL SURVEILLANCE SR 3.6.4.3.2 (continued) REQUIREMENTS filter performance, charcok1 adsorber efficiency, minimum system flow rate, and the physical properties of the activated 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 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 testf ng 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. d Brunswick Unit 2 B 3.6-84 Revision No.
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CONTAI) MENT STSTEMS - CONTAllHENT ATH05 FRERE DIIDTION SYSTEM LIMITING C0KDITION FOR OPERATION 3.6.6.2 The containment atmosphere dilution (CAD) system shall be OPERABLE with
. a. . An OPERABLE flow path capable of supplying nitrogen to the drywel,1, and ,
- b. A minimum supply of 4350 gallons of liquid nitrogen.
_AFFLICABILITY: CDNDITIDN 1*. ACTIONS With the CAD system inoperable, restore the CAD system to OPERABLE status within 31 days or be in at least STARIUF within the next 8 hours. The provisions of Specification 3.0.4 are not applicable. SURVIILLANG REQUIRDENTS 4.6.6.2 The CAD system shall be demonstrated to be OPERAliZs O a. Ac least once per 31 days by verifying thats h
- 1. The system contains'a minimum of 4350 gallons of liquid nitrogen, and
- 2. Each valve (manual, power-operated, or automatic) in the flow path not locked, sealed, or otherwise secured in positien, is in its correct position.
h At least once pe by
. Cyc u ng .. ,.-.. .,. sated (exclu11ng automatic) valve in the flow path through at least one complete cycle of full travel, end - l g g g, g , 3 g @ Verify 1 that each automatic valva in the flow path actuates to l its E _, position on a Q % 2 p } isolationgtest signal.
i s.t.bn O ( u. ( 5, rrs : Lr..u) r QWhen oxygen concentration is required to be < 4% per Specification 3.6.6'. l BRUNSWICK - UNII 1 3/4 6-28 Amendment No. 59 yua
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- 3. 6. 3. 2.
CDNTAI1 MENT SYSTEMS CONTAI) MENT ATHOSFEERE DITETION SYSTFM LDtITING CONDITION FOR OPERATION 3.6.6.2 2e containment atmosphere dilution (CAD) system shall be OFF.RABLE withs
- a.
- An OPERABLE flow path capable of supplying nitrogen to the drywell, and .
- b. A minimum supply of 4350 gallons of liquid nitrogen.
AFFLICABILITTs CDNDITID5 1*. ACTION: With the CAD system inoperable, restore the CAD system to 0FEIAB12 status within 31 days or be in at least STARIUF within the next 8 hours. The provisions of Specification 3.0.4 are not applicable. SURVIILIANG REQLf!1ENENf3 4.6.6.2 he CAD systes shall be demonstrated to be OPERAB128 O a. At least once per'31 days by verifying that:
- 1. The sysres contains a minimum of 4350 gallons of liquid nitrogen, and
- 2. Each valsa (manual, power-operated, or automatic) in the flow path nos locked, saaled, or otherwise secured in position, is in ha correct position.
- b. At least onca aths bys b.
. Cycling escu -operated (excluding automatic) valve in the flow path through at least one complete cycle of full travel, l
- 2. Verifyi that each automatic valve in the flow path actuates to N 3 b'I 3* b its position on a (ro g 2 god 6] isolation est signal.
LA.2. GN$ y L.b (s_ zrs u.J
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DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic" LA.1 CTS 4.6.3.4 requires each excess flow check valve (EFCV) to cycle through at least one complete cycle of full travel. ITS SR 3.6.1.3.7 requires the EFCVs to actuate to their isolation position (i.e., closed) on an actual or simulated instrument line break signal. The method of simulating the instrument line break inherently cycles the EFCV. The method of performing ITS SR 3.6.1.3.7 is relocated to the Bases for ITS SR 3.6.1.3.7. The ITS Surveillance Requirement is adequate for ensuring each required EFCV is maintained OPERABLE. As such, the details of performing the SR are not required to be in the BNP Technical Specifications to provide adequate protection of the public health and safety. Changes to the ITS Bases are controlled by the provisions of the ITS Bases Control Program described in ITS Chapter 5.
LA.2 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 PCIVs. The requirements of ITS 3.6.1.3 and the associated Surveillance Requirements are adequate to ensure the PCIVs are maintained OPERABLE. As a result, the methods of performing Surveillance are not necessary to ensure the PCIVs can perform their 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 4.6.3.2 and 4.6.6.2.b.2 specify the frequency for primary containment isolation valve functional testing as once every h 18 months. In ITS SR 3.6.1.3.6, the frequency for the 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 24 months for a maximum interval of 30 months including the 25% grace period. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. Some 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: l 1 O O l l BNP UNITS 1 & 2 5 Revision 0 l L j
DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES TECHNICAL CHANGES - LESS RESTRICTIVE LD.I' " Industry reliability studies for boiling water reactors
~(cont'd) (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, increasing the logic system functional test interval represents no significant change in the overall safety system unavailability." Based on the above discussion, the impact, if any, of this change 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, documented in "24 Month Surveillance Test History Study," demonstrates that there are no failures that would invalidate the conclusion that the impact on system availability, if any, is minimal. LD.2 CTS 4.6.3.4 specifies the frequency for excess flow check valves (EFCV) testing as once every 18 months. In ITS SR 3.6.1.3.7, the O frequency for the EFCV 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 24 months for a maximum interval of 30 months including the 25% grace period. This SR ensures that each EFCV will check excess flow and limit the total leakage from the EFCV to provide assurance that predicted radiological consequences will not be exceeded during a postulated instrument line break. EFCVs are designed with a restricting orifice, that, in the event of the failure of the check valve to function, will significantly limit line flow during a postulated instrument line break. Furthermore, instrument lines are seismically mounted and evaluated to withstand a design basis seismic event. Based on the design of the EFCV providing a passive limit to the amount of flow from an instrument line break-and the design of the instrumentation line tubing, the impact, if any, of this change 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, documented in 24 Month Surveillance Test History Study, demonstrates that there are no failures that would invalidate the conclusion that the impact on system availability, if any, is minimal. LD.3 CTS 4.6.1.2.2 requires that the Main Steam Isolation Valves O (MSIVs) be leak tested every 18 months. In ITS SR 3.6.1.3.9, the frequency is now defined as in accordance with the Primary Containment Leakage Rate Testing Program. With the change to a
. BNP UNITS'l & 2- 6 Revision 0
DISCUSSION OF EHANGES
-ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES TECHNICAL CHANGES - LESS RESTRICTIVE LO.3 24 month operating cycle, the surveillance interval of this SR is (cont'd) being increased from once every 18 months to once every 24 months
. for a maximum interval of 30 months including the 25% grace period. This SR ensures that the MSIVs are capable of maintaining an essentially leak tight barrier. As described in BNP UFSAR Section 3.9.3.2, the McIVs were designed and tested for closure in the event of a mal' asan line break and to provide an isolation barrier to maintain primary containment following a design basis accident. As such, the valves were designed to close during emergency steam flow conditions following rupture of the main steam line downstream of the valve. Furthermore, the valves were designed for the limiting BNP system pressure and temperature and designed to be capable of actuatirsg 50 to 400 cycles per year (full open-to-full-closed-and-return). Finally, BNP is designed with two MSIVs per main steam line which ensure no active single failure wili *esult in a loss of component capability. Based on
.the redundant de.ign the MSIVs, the impact, if any, from this l
change on componert and 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' nistory demonstrates that there are no failures l that would invalidate the conclusion that the impact on system availability, if any, is minimal.
" Specific" L.1 ITS 3.6.1.3 ACTIONS, Note 1, SR 3.6.1.3.1, Note 2, and SR 3.6.1.3.2, Note 2 contain an allowance for intermittently opening, under administrative control, closed primary containment isolation valves. Opening of primary containment penetrations on
! an intermittent basis is required for performing surveillance, repairs, routine evolutions, etc. Intermittently opening closed PCIVs is acceptable due to the low probability of an event that could pressurize the primary containraent during the short time in l- which the PCIV is open and the administrative controls established i to ensure the affected penetration can be isolated when a need for , ( primary containment isolation is indicated. I l l L.2 CTS 3.6.3 Action a, CTS 3.4.7 Action 2, and CTS 4.6.1.1.a list some, but not all, possible acceptable isolation devices that may be used to satisfy the need to isolate a penetration with an inoperable isolation valve. ITS 3.6.1.3 ACTIONS provide a complete list of acceptable isolation devices. Since the result of the ACTIONS continues to acceptably isolate the penetration to allow continued operation, the change does not adversely affect safe operation. Many penetrations are designed with check valves as acceptable isolation barriers. With a higher pressure in the line downstream of the check valve, the check valve is seated and O is essentially equivalent to a closed manual valve. For those penetrations designed with check valves as acceptable isolation BNP UNITS 1 & 2 7 Revision 0
DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES TECMICAL CHANGES - LESS RESTRICTIVE L.2- devices ~, ITS provide an equivalent. level of safety by allowing (cont'd)' these valves to be used as isolating devices. For penetrations not designed with check valves for isolation, ITS does not affect the requirement to isolate the penetration with a closed
' deactivated automatic valve, a closed manual valve, or a blind flange. ITS ACTIONS allowing closed manual valves or check valves with flow secured to satisfy the requirement of isolating an inoperable penetration also apply to isolating main steam lines, even though the BNP design does not provide for these type of isolation devices. This change to CTS 3.4.7 Action 2 simply provides a consistent presentation for all penetrations. While this apparent flexibility does not result in any actual technical change in the BNP Technical Specifications, it is listed here for comp'eteness.
L.3 In the event both valves in a penetration are inoperable, CTS 3.6.3, Action a, which requires maintaining one isolation I valve OPERA 8LE, would not be met and an immediate shutdown would J be required. ITS 3.6.1.3, ACTION B provides 2 hours prior to commencing a required shutdown. This 2 hour period is consistent with the existing time allowed for conditions when the primary containment'is inoperable. This change will provide consistency 1 in ITS ACTIONS for these various primary containment degradations. Since the capability to isolate a primary containment penetration O is lost, the risk associated with continued operation for a short period of time could be less than that associated with an immediate plant shutdown. This change to CTS 3.6.3 is acceptable due to the low probability of an event that could pressurize the primary containment during the short time in which continued operation is allowed and the capability to isolate a primary containment penetration is lost. In addition, a clarifying Note A is added to ITS 3.6.1.3 Condition B which states, "Only applicable au to penetration flow paths with two PCIVs. L.4 In the event an excess flow check valve (EFCV) is inoperable, the time to allow for restoration prior to requiring a shutdown in ITS 3.6.1.3 (ACTION C) is 12 hours versus the 8 hour time period allowed by CTS 3.6.3 Action b, In this event, a limiting event would still be assumed to be with',n the bounds of the safety analysis (the excess flow lines contain orifices. and are i approximately 1 inch in diameter ) Allowing an extended restoration period (4 additional hours), to potentially avoid a plant transient caused by the frsrced shutdown, is reasonable based on the low probability of a EFCV line break event occurring while the E RV is inoperable and doet not result in a significant decrease in safety. L.5 Any time the OPERABILITY of a system or component has been 1 affected by repair, maintenance, or replacement of a component,
/G. . post maintenance testing is required to demonstrate OPERABILITY of V the system or component. After restoration of a component that
. caused a required SR to be.Ialled, ITS SR 3.0.1 requires the
_BNP. UNITS 1 & 2 8 Revision 0
7 DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES Q V TECHNICAL CHANGES - LESS RESTRICTIVE L.5 appropriate SRs (in this case ITS SR 3.6.1.3.4 and SR 3.6.1.3.5, (cont'd) as applicable) to be performed to demonstrate OPERABILITY of the affected components. Therefore, explicit post maintenance Surveillance Requirements (CTS 4.6.3.1) are not required and are not included in the BNP ITS. L.6 The phrase " actual or," in reference to the automatic isolation signal, is added to the Surveillance Requirements (ITS SRs 3.6.1.3.6 and 3.6.1.3.7) for verifying that each PCIV actuates on an automatic isolation signal and EFCVs isolate on an instrument line break signal. This allows satisfactory PCIV isolations for other than Surveillance purposes to be used to fulfill the Surveillance Requirements. OPERABILITY is adequately demonstrated in either case since the PCIV or EFCV itself cannot discriminate between " actual" or " simulated" signals. L.7 Note 1 is added to ITS SR 3.6.1.3.1 and SR 3.6.1.3.2 to allow verification of valves and blind flanges by administrative means when the isolation device is located in a high radiation area. A Note is also added to ITS 3.6.1.3 Required Actions A.2 and C.2 to allow verification of isolation devices by administrative means when the isolation devices are located in a high radiation area. These allowances are acceptable since access to high radiation A areas is restricted and the probability of valve, flange, or isolation device misalignment, once it has been verified to be in Im)
' the proper position, is small. Eliminating the physical verification in areas of high radiation reduces exposure to plant personnel and is consistent with the As-Low-As-Reasonably-Achievable (ALARA) concept.
L.8 In the event a primary containment isolation valve in a single isolation valve penetration (other than one associated with the reactor instrumentation system) is inoperable, CTS 3.6.3 Action a g , (which requires maintaining one isolation valve OPERABLE) would ) not be met and an immediate shutdown would be required. Penetrations with only a single primary containment isolation valve include those associated with closed systems and those provided with a water seal, which are discussed in UFSAR 8 Section 3.1.2.5.8, Criterion 57-Closed system isolation valves. , for this type of penetration, the time allowed for isolation of ! the affected penetration by a closed and de-activated valve, A l closed manual valve, or blind flange prior to requiring a shutdown in ITS 3.6.1.3 (Required Action C.1) is 8 hours. In this condition, the closed system or water seal acts as the penetration d i isolation barrier and (nsures that the primary containment boundary is maintained intact until another barrier can be established to isolate the penetration. Allowing a period (8 hours) to establish another isolation barrier, to potentially b avoid a plant transient caused by the forced shutdown, is l(7 reasonable based on the low probability of event occurring while lV the affected isolation valve is inoperable and the mitigating effects of the closed system or water seal. Therefore, the change g j BNP UNITS 1 & 2 9 Revision 0 l t
I ( DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES TECHNICAL CHANGES - LESS RESTRICTIVE L.8 does not result in a significant decrease in safety. In addition, (cont'd) to ensure that the additional isolation barrier is maintained, ITS 3.6.1.3 Required Action C,,2 will require verification that the l affected flow path is isolated once per 31 days. For isolation devices in high radiation areas, verification may be performed by the use of administrative means. Since ITS 3.6.1.3 is only intended to apply to single isolation valve penetrations, a clarifying Note is added to ITS 3.6.1.3 Condition C which states, "Only applicable to penetration flow pcths with only one PCIV " L.9 The requirements of CTS 4.6.1.1.a. related to verification of the position of primary containment isolation manual valves and blind flanges, are revised (in ITS SR 3.6.1.3.1 and SR 3.6.1.3.2) to exclude verification of manual valves and blind flanges that are locked, sealed, or otherwise secured in the correct position. The purpose of CTS 4.6.1.1.a is to ensure that manual primary containment isolation devices that may be misaligned are in the correct position to help ensure that post accident leakage of radioactive fluids or gases outside the primary containment g boundary is within design and analysis limits. For manual valves or blind flanges that are locked, sealed, or otherwise secured in the correct position, the potential of these devices to be inadvertently misaligned is low. In addition, manual valves and blind flanges that are locked, sealed, or otherwise secured in the O correct position are verified to be in the correct position prior to locking, sealing, or securing. As a result'of this control of i the position of these manual primary containment isolation devices, the periodic Surveillance of these devices in ) CTS 4.6.1.1.a is not required to help ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is maintained within design and analysis limits. This change also provides the benefit of reduced radiation exposure to plant personnel through the elimination of the requirement to check the position of manual valves and blind flanges, located in radiation areas, that are locked, sealed, or otherwise secured in the correct position. L.10 In the ITS presentation, MSIV leakage discovered outside the acceptance criteria will result in entering ACTIONS for inoperable primary containment isolation valves. The ITS 3.6.1.3 ACTIONS for this condition will require restoration of leakage to within limits within 8 hours. CTS 3.6.1.2 ACTIONS only restrict heating up the reactor coolant above 212*F (i.e., entry into MODE 3). With MSIV leakage outside of limits, discovered while operating in MODE 1,.2, or 3, CTS 3.6.1.2 does not provide actions. Since the MSIV leakage limit is an attribute of maintaining MSIV OPERABILITY for the primary containment isolation valve function, an 8 hour b allowed outage time is provided for this condition consistent with the existing time allowed for other conditions when primary O containment isolation valves or MSIVs are inoperable. This change V provides consistency in ITS ACTIONS for the various MSIV inoperabilities. With MSIV leakage not within required limits, l BNP UNITS 1 & 2 10 Revision 0
DISCUSSION OF CHANGES ITS: 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES TECHNICAL CHANGES - LESS RESTRICTIVE L.10 the risk associated with continued operation for a short period of (cont'd) time could be less than that associated with an immediate plant shutdown since the change provides time to restore MSIV leakage. This change to CTS 3.6.1.2 is acceptable due to the low probability of an event that would require MSIV leakage to be within limits during the short time in which continued operation is allowed and MSIV leakage is not within limits. In addition, Note 4 to the ACTIONS of ITS 3.6.1.3 will require immediately taking the ACTIONS of ITS 3.6.1.1 (which reducu the time allowed 8 l to restore the leakage to 2 hours in accordance with ITS 3.6.1.1 l Required Action A.1) if MSIV leakage results in the overall ! primary containment leakage rate acceptance criteria being exceeded. Therefore, assurance is provided that MSIV leakage will not adverstly impact primary containment OPERABILITY during the 8 hour time period. RELOCATED SPECIFICATIONS None O O BNP UNITS 1 & 2 11 Revision 0
c'Me dh % +3.'Z. A.i O. T ( wu=.Ams-w masswear ama DINTION STumani
'T EDR _r p5 EAT g
Leo g 3,*), the sentaiammat atmosphere dilution (C&D) system shall be OpIRABM
. OFEBABM path ble of a ing mit to the d[11, LA./
$L '$(,.3.2 l @p A minimum supply of 4350 gallons of liquid nitroges.
Ary!.IC&BILRY: {uDRIDEle h Acr1DNs DN O f=WiththeCADe
.gg < **= 31 dar= tembe inopershle, is at leastrestore St&RIUF the CAD withissystem the mest to OPER&BM status 8 hours. The
. provisions aflecification 3.0.4 are not applicable.
~~
N A. W.44. gpIFEILIMNE REWIREMENES g the C&D systen shall be demonstrated to be OPERABLE:
@ At least oaos poi 31 days by verifying thats g.3j, g QQ The mystem contains a minimum of 4350 gallons of liquid g M .1.2.7 @ Each valve (manual, power-operated, or automatic) la the flov l path not locked, sealed, or otherwise secured is position, is in i its correct positi a w o. g gg 4 4 by: & u u.11.s
<@ At least ones per uma
$f, %.'3,t,3 h Gyaling eask pose rated (escluding automatic) valva in the flow path through at least oes complete cycle KJat11 %
LA.2 A ! g . E < b/%.A D . Verif its dr.pedrepe hat each automatic valve in the flow path actuates t sition on a Group 2 and 6 isolation test signal. l
- 4. . ,
~
(25'5.6.s.1 A.4 is W u ., Al (. ao .. co. centr.u.a is re,. ire. to ,e or ,er s,.cm..uon 3.... 3. 4.z. g' sensuzcz - una i 3/1 6-Is Am.adment so. 59 v., , .a
hcNedn D. 4. 3,2-O.~ . 3 (, 00NEADBEENT SYSTEMS
= DIsTION JTSr f---M--- m-k1 m
DIG NDEr 10 N do 3,c,3,7. The coarai===st atmosphere dilut40s (CAD) system shall be OPERA 54 OPERAB ow path his of a altros the d , LA.I g g ,3 L,1 $ A minimus supply of 4350 galloss of liquid nitrogen. AFFLIC&BILITY: $5DETIDN1* AU44 A
.C.
th the CAD s tem inoperable, restare the CAD system to 0FEIABM status 3 AmodB withia 31 da e be is at least 3rARIUF withis the next 8 hours. The .
. ggg revisions of cification 3.0.4 are not applicable.
EsDETEILIAIKg REggramaturs
@ 1he CAD systes shall be demonstrated to be OPERABLE:
@ At least once per 31 days by verifytag thats g .j, ,3,g @ The system contains a minimum of 4350, gallons of liquid microgen, and Sig, g, y *g p Each valve (manual, power-operated, or automatic) in the flow path not locked, sealed, or otherwise secured in position, is in its correct positionF Coe ca- me- W-..A A A w< A @m A,$
$ At least once per ao by: D. I < 52. M .5.2.1 g g* g* g 3 p Cycling each pose rated (excluding automatici valve in the f ow path through at Isaat one complete cycle ( fyli ty6ve j l . Verif i hat each automatic valve in the flow path actuaces c g its r position os a Croup 2 and 6 isolation test signal.
(TT5*,3.f J 3) fr la b A.4 h I l f" l en oxygen concentration is required to be < 4% per Specification 3.6.6.3. 2. hi haussurcx - Unn 2 3/4 6-2s amendment no. 85 g 1.o U_-----__-_____._-__
1 DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT MM0 SPHERE DILUTION (CAD) SYSTEM /O O ADMINISTRATIVE A.1 In the conversion of the Brunswick Nuclear Plant (BNP) current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, 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 l 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 j within 24 hours after THERMAL POWER > 15% RATED THERMAL POWER to within 24 hours 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 hours after THERMAL POWER is > 15% RTP following startup to 24 hours prior to a scheduled reduction of THERMAL POWER to < 15% RATED THERMAL POWER. Since the change involves no technicr*, changes and is a presentation preference only, it is considsred to be administrative.
'A A.3 The CAD System is manually actuated (requiring repositioning of valves by the operator). In CTS, this is recognized and 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 N Group 2 and 6 isolation test signal. On Group 2 and 6 primary N\ 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 containment isolation signals are primary containment isolation valves (PCIVs) as identified in UFSAR Table 6.2.4-1. UFSAR d BNP UNITS 1 & 2 1 Revision 0 I
DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM ~ ADMINISTRATIVE 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 valves, in response to Group 2 and 6 primary containment isolation signals, is the isolated position. CTS 4.6.3.2 (ITS SR 3.6.1.3.6) requires verifying that each primary containment isolation valve. actuates to its isolation position on an isolation signal. Since the requirements of CTS 4.6.6.2.b.2 are covered by ITS SR 3.6.1.3.6, they are moved to ITS 3.6.1.3, Primary Containment 8 Isolation Valves (PCIVs) in accordance with the format of the BWR Standard Technical Specifications, NUREG-1433. ^1nce the change involves no technical changes and is a presert c:. ion preference only, it is considered to be administrative. TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES - LESS 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 d
to the Bases. 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
>ublic health and safety. Changes to the Bases will be controlled
)y the provisions of the proposed Bases Control Program described in Chapter 5 of the ITS.
LA.2 The details relating to methods 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 '
"of full travel") are to be relocated to the Bases. These details are not necessary to ensure the OPERABILITY of the CAD System.
lb 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 Surveillance are not necessary to ensure the CAD System can perform its intended safety function and the details are not required to be in 1
. 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.
l BNP UNITS 1 & 2 2 Revision 0 L
DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE (continued) 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 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 24 months.for a maximum interval of 30 months including the 25% grace period. ITS SR 3.6.3.2.3, cycling of each CAD System power operated (excluding automatic) valve in the flow path through at least 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 z\ failure of an active component (e.g., a power operated valve in dB 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 durity the operating cycle in accordance with the Inservice Testing Program. A review of the surveillance test history for this Surveillance Requirement was performed to validate the above conclusion. This historical review of the surveillance test history demonstrates O that there are no failures that would invalioate the conclusion that the impact of this change, if any, on system availability is minimal. LD.2 Not used. b O bNP UNITS 1 & 2 3 Revision 0 L - - - _ - - _ - - - - _ - _ . _ _ _ _
DISCUSSION OF CHANGES ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE LD.2 Not used. (cont'd) s "Speci fic" d L.1 Not used. t O a i l 1 i O BNP UNITS 1 & 2 4 Revision 0
DISCUSSION OF CHANGES I ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Not used. (cont'd) l' b O L.2 Not used. ? RELOCATED SPECIFICATIONS None
, BNP UNITS 1 & 2 5 Revision 0
I RHR Suppression Pool Cooling 3.6.2.3 Cu /ce<- 3.6 CONTAllMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LC0 3.6.2.3 Two RHR suppression pool cooling subsystems shall be 3.t. 2/t OPERABLE.
/L A. I APPLICA81LITY: MODES 1, 2. and 3. - 9076 - - - ,
L.c o 3.o.tl is " A 'g lic* '~L!r . gc3gyg
,! R IRED ACTION ' COMPLETION TIME CONDITION M
3.6.7.t. A. One RHR suppression A.1 Restore RHR 7 days A m" . pool cooling subsystem suppression pool. inoperable. cooling subsystem to OPERABLE status. 12 hours f').2.1 Required Action and ! Be in MODE 3. 'i"' !!?' Me"d 2 Be in MODE 4. 36 hours C Two RHR suppression pool cooling 7~9 subsystems inoperable. 1 1 14.t. L f>.8 h44. e a e. 2 k-s g g, k"" h PttR spp m:, (..I ca.t: $ sas O- += OPC AdtE Sk L- - L;/4 aia ^- 3.6-35 !L" ! . ^t/^7/M^ G(~N l
C75/px.$ CAD Syst l 3.6.3r, p SURVEILLANCE REQUIREMENTS
. SURVEll. LANCE FREQUENCY Qhl 46,4,.7,4.) SR 3.6 3.f.1 Verify 2d al of liquid nitrogen 31 days are contt the CAD Systm.
SR . . Verify each CAD subsystes manual, r 31 days 46.4 2.a.2/ operated, and autoratic valve in flow 4,3 path that is not tocked, sealed, or othentise securr.s in position is in the correct positt'a or can be aligned to the correct position. 1 I r s'3 i 4" 2 h' sg. 34 3.2.3 Cy da. e<al W <- o p = <*f < 6 24
- d5
$** e u.Ldia we*44 , valvo in of 4 <_.
o.= 1 i 1 b
...r
=/' O 3.6-46 L :, c'/07/e5 %
A V e g . 4 4A
l JUSTIFICATION FOR DEVIATIONS FRON NUREG-1433, REVISION 1 SECTION 3.6 - CONTAINMENT SYSTENS
- 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 k licensing basis. In addition, 18 month Surveillance are extended to 24 months to be consistent with the BNP cycle length. g
- 34. NUREG-1433 Surveillance Requirement 3.6.4.1.1 (verification that secondary containment is at a negative pressure) is not included in the 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 surveillance 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 isolation valves and blind flanges are closed. This SR is not included O in the BNP ITS since the BNP current licensing basis does not include secondary containment manual isolation valves and blind flanges. As a result, the subsequent NUREG-1433 surveillance 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 restors 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. I O
1 BNP UNITS 1 & 2 6 Revision 0
hts SR. i+ Mas VeA ing -hd hhs% ed au.M*c pct i4 %. J.ll Ahde. c A4~a
- 4. ;+s is.e.Am l
Ap p pe',4 ionon -N y, 8 O- f'D # s B 3.6.1.3 Y}T5* # BASES SURVEILLANCE st 3.5.1.3 J REQUIREMENTS . Automatic PCIVs close en a primary containment isolation (continued) - signal to prevent leakase of radioactive material fres primary contalement following a DBA. This SR ensures that (i each automatic pCIV will actuate to its isolation positi 1.co 3.3.f.1, en a primarLcentainment 1selrien signal.K4N4 LosIc aisiEM FIAICTIONA. TE T inn 3 overlaps this to provide ng eTthe safety function. The th wP % 6A.~ 4 - compiete wst Frequency was developed considering it is p at this gg*^ Surveillance be perfereed only during a unit estage since Lt+w4 isolatten of trations useld" Eliminate coolg water flow/
/C J and disrupt normal operation of
'f eg l
ug_n components. s ting experience has these pass this Surveillance when performed at een Frequency. Therefom the Frequency was cane to be acceptable from a reliability standpoint. SR 3.8.1.3. 3W siy,4 This SR requires a demonstration t each reactor ocL6 4.44e instrumentation line oss fl wet valve (EFCV) is is w D4 O e. OPFAABLE by verifyina that the h;v;ppen pro ides$8ficulated assurance that inst enn- _ : = r_ ine crea s. tThis SR the instrumentation line ucis will 'g."*) k NM 6) perfem so that prodjeted radiological consequences will not by 'cje,1:34 e en E cy is Io^8co-flek.)k
- 5 Wen the need to perfem this Sur lance under the conditions that apply during a plant eutage and the cUele, d Q[
potential for an unplanned transient if the Surveillance J (bh were perfomed with the reactor at power. Operati experience has A that these c ts ass this uM Surve111ance when performed at the th Frequency. Therefore, the Frequency was conc 1 to be acceptable from a reliability standpoint. SR 3. 6.1.3 M The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when (continued) M 8 3.6-29 -;t., ', O'/0 /;st O V
1 Insert B 3.6.3.2-3 SR 3.6.3.2.3 t Cycling each power operated valve, excluding automatic valves, in the CAD System flow path ough one complete cycle of full travel demonstrates that the valves are L .anica11y OPERABLE and will function when required. While this Surveillance may be performed with the reactor at power, the 24 month d 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 1 o i
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM L.1 CHANGE Not used.-
^
O l O
, BNP UNITS I & 2- 1 Revision 0
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEN L.I CHANGE (continued) Not used. i i b O O BNP UNITS I & 2 2 Revision 0
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.6.3.2 - CONTAINMENT ATMOSPHERE DILUTION (CAD) SYSTEM L.2 CHANGE Not used. O a o ! BNP UNITS 1 & 2 3 Revision 0
SW System and UHS 3.7.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action C.1 0.1 Restore required CSW 72 hours b and associated pump to OPERABLE Completion Time not status. met. g E. Two required CSW pumps inoperable. E.1 --------NOTE--------- Enter applicable b l Conditions and Required Actions of LC0 3.7.1, "Recidual Heat Removal Service Water (RHRSW) System," for RHRSW subsystems made inoperable by CSW. s Restore one required CSW pump to OPERABLE 72 hours 8 status. M 14 days from discovery of failure to meet LC0 l l F. One required NSW pump F.1 Restore required NSW 72 hours l inoperable. pump to OPERABLE E status. g DB One~ required CSW pump inoperable. F.2 Restore required CSW 72 hours
~~
pump to OPERABLE status. (continued) J
. Brunswick Unit:1 3.7-6 Amendment No.
SW System and UHS 3.7.2 _ ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME G.. One required NSW pump G.1 V'erify by Immediately /A D inoperable. administrative means that two Unit 1 NSW Ngl pumps are OPERABLE. Two required CSW pumps Ng} inoperable. A G.2.1 Restore required NSW 72 hours D-pump to OPERABLE status. 93 G.2.2 Restore one required CSW pump to OPERABLE 72 hours h status. H. Water temperature of H.1 Verify water Once per hour b the UHS > 89'F and temperature of the O- s 92*F. UHS is s 89'F averaged over previous 24 hour period. (continued) .//~)'N t, Brunswick Unit 1. 3.7-7 Amendment No.
= _ - _ _ _ _ _
SW Systea and UHS 3.7.2
' ACTIONS (continued)-
CONDITION REQUIRED ACTION . COMPLETION TIME I. -Required Action and I.I Be in MDDE 3. 12 hours b associated Completion Time of Condition A, NE B, D, E, F, G, or H not met. I.2 .Be in MODE 4. 36 hours g
'E Required Action C.2 and associated Completion Time not met.
E Two or more required NSW pumps inoperable.
.E j SW System inoperable O for reasons other than Conditions A, B, C,-D, 6 E, F, and G.
E UHS inoperable for reasons other than Condition H. f -Af. Brunswick Unit I 3.7-8 Amendment No. __-=_:_
~
i l l SW System and UHS 3 ' 3.7.2 l SURVEILLANCE REQUIREMENTS 1 l SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the water level in the SW pump 24 hours l ! suction bay of the intake structure is l 2: -6 ft mean sea level . SR 3.7.2.2 Verify the water temperature of UHS is 24 hours s 89'F. SR 3.7.2.3 -------------------NOTE-------------------- Isolation of flow to individual components does not render SW System inoperable. Verify each SW System manual, power 31 days operated, and automatic valve in the flow paths servicing safety related systems or o components, that is not locked, sealed, or
'j s otherwise secured in position, is in the correct position.
SR 3.7.2.4 -------------------NOTES-------------------
- 1. A single test at the specified Frequency will satisfy this Surveillance for both units.
- 2. Isolation of flow to individual components does not render SW System inoperable.
Verify automatic transfer of each DG 92 days cooling water supply from the normal SW supply to the alternate SW supply on low DG jacket cooling water supply pressure. (continued) J b) v Brunswick Unit 1 3.7-9 Amendment No.
SW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.7.2.5 6TE-------------------- Isolation of flow to individual components does not render SW System inoperable. Verify each required SW System automatic 24 months component actuates on an actual or simulated initiation signal. l l l 1 l O l l O Brunswick Unit 1 3.7-10 Amendment No.
RHRSW System B 3.7.1 BASES-(continued) APPLICA8LE The RHRSW System removes heat from the suppression pool to SAFETY ANALYSES limit the suppression pool temperature and primary containment pressure following a LOCA. This ensures that the primary containment can perform its function of limiting the release of radioactive materials to the environment following a LOCA. The ability of the RHRSW System to support long term cooling of the reactor or primary containment is discussed in Reference 2. These analyses explicitly assume that the RHRSW System will provide adequate cooling support to the equipment required for safe. shutdown. These analyses include the evaluation of the long tem primary containment respo'ise after a design basis LOCA. The safety analyses for long term cooling were performed for various combinations of RHR System failures. The worst case single failure that would affect the performance of the 1 RHRSW System is any failure that would disable one subsystem
- 1. of the RHRSW System. As discussed in the UFSAR (Ref. 2) for these analyses, manual initiation of the OPERABLE RHRSW subsystem and the associated RHR System is assumed to occur 10 minutes after a DBA. The RHRSW flow assumed in the analyses is 4500 gpm from two pumps operating in one loop.
In this case, the maximum suppression chamber water h O3 temperature and pressure are 189.4*F and 14.0 psig, respectively, well below the design temperature of 220*F and d maximum allowable pressure of 62 psig (Refs. 3 and 4). The RHRSW System satisfies Criterion 3 of Reference 5. LCO Two independent RHRSW subsystems are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power. An RHRSW subsystem is considered OPERABLE when:
- a. Two pumps are OPERABLE; and
- b. An OPERABLE flow path is capable of taking suction from the intake canal via the SW System and transferring the water through the RHR heat exchangers at the assumed flow rate. Additionally, the RHRSW cross tie valve (which allows the suction headers of !
the two RHRSW loops to be connected) must be available to provide the ability to isolate one subsystem from ' . (continued) l l L frunswick Unit 1 B 3.7-2 Revision No. L l I l Q__ __-_ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ - - _ _ _ _ - _ _
SW System and UHS B 3.7.2 BASES (continued) APPLICABILITY In MODES 1, 2, and 3, the SW System and UHS are required to be OPERA 8LE to support OPERABILITY of the equipment serviced i by the SW System. Therefore, the SW System and UHS are required to be OPERABLE in these MODES. In MODES 4 and 5, the OPERABILITY requirements of the SW System and UHS are determined by the systems they support. ACTIONS A_d The normal cooling water supply for two DGs and the alternate cooling water supply for two DGs are provided by the opposite unit NSW pumps via the associated NSW header. Therefore, this Required Action provides a 14 day period to perform maintenance on the opposite unit NSW header and associated NSW pumps. This is acceptable because performing i maintenance on the opposite unit NSW header and NSW pumps I will increase the reliability of the DGs cooling water i supply. -However, if this condition results in two required site NSW pumps being incapable of providing cooling water to n the DGs, Condition I is entered. /fG The 14 day Completion Time takes into account the capacity and capability of the remaining NSW pumps to supply cooling to all four DGs and a reasonable time for performance of maintenance. 4 The Note to Condition A only allows the 14 day Completion Time to apply when the opposite unit is in MODE 4 or 5. When a required NSW pump becomes inoperable or incapable of providing cooling water to the DGs while Unit 2 is in MODE 1, 2, or 3, Condition B or I of Unit I Specification 3.7.2 must be entered, as applicable, and the g associated Required Action (s) performed. Pursuant to LC0 3.0.6, the AC Sources-Operating ACTIONS would not be entered even if cooling capability were lost to the DGs, resulting in one or more inoperable DGs. Therefore, Required Action A.1 is modified by a Note to indicate that when Condition A is entered and NSW cooling capability is unavailable to one or more DGs, ACTIONS for LCO 3.8.1, "AC Sources-Operating," must be immediately entered. This allows Condition A to provide requirements (continued) /~N ' O Brunswick Unit 1 B 3.7-10 Revision No.
SW System and UHS B 3.7.2 BASES 1 ACTIONS M (continued)- for an inoperable NSW pump without regard to whether a cooling water supply is available to the DGs. LCO 3.8.1 provides the appropriate restrictions for one or more
. inoperable DGs.
M With one required NSW pump inoperable for reasons other than Condition A, one inoperable pump must be restored to OPERABLE status within 7 days and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the remaining OPERABLE NSW and CSW pumps are adequate to perform the SW heat removal function. However, the overall reliability is reduced. The 7 day Completion Time is based ; on the remaining SW heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during this time period requiring the SW System. The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of required NSW and CSW pumps to be inoperable O- during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, a required CSW pump is inoperable, and that CSW pump is subsequently returned OPERABLE, the LC0 may already have been not met for up to 7 days. This situation could lead to a total of 14 days, since initial failure to meet the LCO, to restore the NSW pump. At this time, a required CSW pump could again become inoperable, the NSW pump restored OPEPABLE, and an additional 7 days (for a total of 21 days) allowed prior to complete restoration of the LCO. The 14 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions B and C or Conditions B and D are entered concurrently. The "ANj" connector between the 7 day h and the 14 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive ! Completion Time must be met. The second Completion Time l allows for an exception to the normal " time zero" for ! beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the time LCO 3.7.2 was _ initially not met, instead of at the time that ; Condition B was entered. _{ (continued) Brunswick Unit 1 B 3.7-11 Revision No.
SW Systc3 and UHS B 3.7.2 i BASES ACTIONS jld (continued) Pursuant to LCO 3.0.6, the AC Sources-Operating ACTIONS would not be entered even if cooling capability were lost to the DGs, resulting in one or more inoperable DGs. Therefore, Required Action 8.1 is modified by a Note to indicate that when Condition B is entered and NSW cooling capability is unavailable to one or more DGs, ACTIONS for LCO 3.8.1, "AC Sources-Operating," must be immediately entered. This allows Condition B to provide requirements for an inoperable NSW pump without regard to whether a cooling water supply is available to the DGs. LC0 3.8.1 provides the appropriate restrictions for one or more inoperable DGs. C.1 and CJ With one required CSW pump inoperable, the inoperable pump b must be restored to OPERABLE status within 7 days and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the OPERABLE CSW pump and NSW pumps are adequate to perform the heat removal function. However, h the :,verall reliability is reduced. The 7 day Completion
;ime is based on the availability of two Unit 1 SW pumps (an OPERABLE CSW pump and an OPERABLE Unit 1 NSW pump), each powered from separate 4.16 kV emergency buses, to support A the unit's service water loads. Immediate verification that 2B the OPERABLE CSW pump and one OPERABLE Unit 1 NSW pump are powered from separate emergency buses is therefore required when one required CSW pump is inoperable. If the OPERABLE
!- CSW pump and ona Unit 1 NSW pump can not be immediately verified to be powered from separate 4.16 kV emergency buses, Condition E must be immediately entered. The 7 day Completion Time is based on the remaining SW heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during this time period requiring the SW System. The second Completion Time for P.equired Action C.1 establishes a limit on the maximum time allowed for any combination of required NSW and CSW pumps to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, a required NSW pump is inoperable, and that NSW pump is subsequently returned OPERABLE, the LCO may already have (continued) Brunswick Unit 1 B 3.7-12 Revision No.
i SW System and UHS B 3.7.2
' BASES ACTIONS. C.1 and C.2 (continued) been not met for'up to 7 days. This situation could lead to l a total of 14 days, since initial failure to meet the LCO,-
L to restore the CSW pump. At this time, a required NSW pump could again become inoperable, the CSW pump restored OPERABLE, and an additional 7 days (for a total of 21 days) , allowed prior.to complete restoration of the LCO. The 14 day Completion Time provides a limit on the time allowed in a 'specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions B and C are entered concurrently. The "Ng!" connector between-the 7 day and the 14 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. The second Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
Th5s exception results in establishing the " time zero" at the time LC0 3.7.2 was initially not met, instead of at the l time that Condition C was entered. If Required Action C.1 cannot be completed within the b associated Completion Time or if the status of the Unit 1 SW t pumps changes after Required Action C.1 is initially met, one required CSW pump must be restored to OPERABLE status A within 72 hours. With the unit in this condition, the S OPERABLE SW pumps are adequate to ' perform the heat. removal function. However, overall relia'oility is reduced as compared to Condition C and a reduced Completion Time of 72 hours is provided. The 72 hour Complet' >n Time is based on the remaining SW System heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during the time period requiring the SW j System. 1 1 L.1 1 With two required CSW pumps inoperable, the one required b inoperable pump must be restored to OPERABLE status within 72 hours and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the OPERABLE NSW A pumps are adequate' to perform the heat removal function. E (continued) Brunswick Unit'l' B 3.7-13 Revision No.
SW Systea and UHS B 3.7.2 BASES ACTIONS L 1 (continued) The 72 hour Completion Time is based on the availability of tN remaining NSW pumps to support the unit's service water loads. The 72 hour Completion Time is based on the b remaining SW System heat-removal capability, a reasonable time for repairs, and the low probability of an event A occurring during this time period requiring the SW System. O
-The second Completion Time for Required Action E.1 establishes a limit on the maximum time allowed for any h
combination of required NSW and CSW pumps to be inoperable during any single contiguous occurrence of failing to meet g the LCO. If Condition E is entered while, for instance, a required NSW pump is inoperable, and that NSW pump is subsequently returned OPERABLE, the LCO may already have been not met for up to 7 days. This situation could lead to a total of 14 days, since initial failure to meet the LCO, to restore the CSW pump. At this time, a required NSW pump could again become inoperable, the CSW pump restored OPERABLE, and an additional 7 days (for a total of 21 days) ba allowed prior to complete restoration of the LCO. The ; 14 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions B and E are entered concurrently. The "8lg!" connector between the 7 day and the 14 day Completion lb Times means that both Completion Times aoply simultaneously, and the more restrictive Completion Time must be met. The second Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock." d This exception results in establishing the " time zero" at .
the time LCO 3.7.2 was initially not met, instead of at the time that Condition E was entered. Pursuant to LCO 3.0.6, the RHRSW ACTIONS would not be entered even if cooling capability were lost to the RHRSW heat exchangers, resulting in one or more inoperable RHRSW b subsystems. Therefore, Required Action E.1 is modified by a /A ! Note to indicate that when Condition E is entered and C ! cooling capability is unavailable to one or more RHRSW J subsystems, ACTIONS for LCO 3.7.1, " Residual Heat Removal Service Water (RHRSW) System," must be immediately entered. gl (continuedl O l l Brunswick Unit 1- B 3.7-14 Revision No. i l- , i l 1
SW System and UHS B 3.7.2 () BASES ACTIONS L 1 (continued) This allows Condition E to provide requirements for one or b more required inoperable CSW pumps without regard to whether. I a cooling water supply is available to the RHRSW heat exchangers. LCO 3.7.1 provides the appropriate restrictions for one or more inoperable RHRSW subsystems. d L1_and F.2 b If one required CSW pump and one required NSW pump are concurrently inoperable, one of the inoperable pumps must be g restored to OPERABLE status within 72 hours. With the unit in this condition, the OPERABLE SW pumps are adequate to perform the heat removal function. The 72 hour Completion g Time is based on the remaining SW System heat removal capability, a reasonable time for repairs, and the low A probability of an event occurring during this time period C i requiring the SW System. G.I. G.2.1. and G.2.2 b n (") If two required CSW pumps are inoperable concurrent with one required NSW pump inoperable and both Unit 1 NSW pumps are verified OPERABLE, one of the required CSW pumps must be h restored to OPERABLE status within 72 hours or the required NSW pump must be returned to OPERABLE status within 72 hours. Since loss of the two required CSW pumps and one required NSW pump could result in a loss of cooling capability to the vital and RHRSW headers, immediate verification that two Unit 1 NSW pumps are OPERABLE is required to ensure cooling capcbility to the vital and RHRSW d headers is maintained. This may be performed av an administrative check by examining logs or other information to determine if one or both Unit 1 NSW pumps are out of service for maintenance or other reasons. It does not mean h. to perform the Surveillance needed to demonstrate the OPERABILITY of the NSW pumps. However, if the OPERABILITY g, ' of both Unit 1 NSW pumps cannot be verified, cooling capability to the ECCS loads cannot be assured. As such, Condition I must be immediately entered. With two required CSW pumps inoperable concurrent with one required NSW pump bA inoperable and both Unit 1 NSW pumps are OPERABLE, adequate LG heat removal capability is ensured by the OPERABILITY of the (continued) V Brunswick Unit 1 B 3.7-15 Revision No. I
SW System and UHS B 3.7.2 BASES ACTIONS G.I. G.2.1. and G.2.2 (continued) h remaining OPERABLE SW pumps. However, the overall SW Systea reliability is significantly reduced because of the reduction in SW pump redundancy and operational diversity l such that the SW System may not be able to perform its I required support function. Therefore, a more restrictive Completion Time of 72 hours is required to restore at least one required CSW pump or the required NSW pump to OPERABLE status. M With water temperature of the UHS > 89'F and s 92*F, the design basis assumption associated with initial UHS temperature are bounded provided the temperature of the UHS averaged over the previous 24 hour period is s 89'F. With the water temperature of the UHS > 89'F, long term cooling capability of the ECCS loads and DGs may be affected. Therefore, to ensure long term cooling capability is provided to the ECCS loads when water temperature of the UHS pg is > 89'F, Required Action H.1 is provided to more V frequently monitor the water temperature of the UHS and verify the temperature is s 89'F when averaged over the previous 24 hour period. The once per hour Completion' Time ; takes into consideration UHS temperature variations and the l increased monitoring frequency needed to ensure design basis assumptions are not exceeded in this condition. If the water temperature of the UHS exceeds 89'F when averaged over the previous 24 hour period or the water temperature of the VHS exceeds 92*F, Condition I must be entered immediately. 8 1.1 and '. 2 If Required Actions cannot be completed within the associated Completion Time of Condition A, B, D, E, F, G, and H; Required Action C.2 cannot be completed within the 8 associated Completion Time; two or more required NSW pumps are inoperable; the SW System is inoperable for reasons other than Conditions A, B, C, D, E, F, and G; or the UHS is inoperable for reasons other than Condition H (e.g., low water level); the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must (continued) _q Brunswick Unit l- B 3.7-16 Revision No.
SW System and UHS' E B 3.7.2 BASES
' ACTIONS- I.1'and I.2 (continued) be placed in at least MODE 3 within'12 hours and in MODE 4 within 36 hours.. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies the water level in the SW pump suction bay of the intake structure to be sufficient for the proper operation of the SW pumps (net positive suction head and pump vortexing are considered in determining this limit). This SR may be accomplished by measuring intake canal water level provided the deviation in water level between the intake canal and the pump suction bay due to the differential pressure of the traveling screens is taken into account. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. j SR 3.7.2,1 Verification of the UHS temperature ensures that the heat removal capability of the SW System is within the assumptions of the DBA analysis. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. SR 3.7.2.3 Verifying the correct alignment for each manual, power operated, and automatic valve in the SW System flow paths provide assurance.that the proper flow paths will exist for SW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also , allowed to be in the nonaccident position, and yet j considered in the correct position, provided it can be automatically realigned to its accident position within the (continued) O V Brunswick Unit'l. B 3.7-17 Revision No. l - = _ _ __:___ - - _ - - .
l SW System and UHS B 3.7.2 BASES SURVEILLANCE SR 3.7.2.3 (continued) REQUIREMENTS. required time. This SR does not require testing or valve manipulation; rather, it involves verification that those . valves capable of being_ mispositioned are in the correct position. This SR does'not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR is modified by a Note-indicating that isolation of' the SW System to components or systems may render those
.. components or systems inoperable, but does not affect the OPERABILITY of the SW System. As such, when all SW pumps, valves, and piping are OPERABLE, but a branch connection off the NSW or CSW header is isolated, the SW System is still OPERABLE.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. SR 3.7.2.4 The dominant contributor to a loss of DG cooling is a failure of the normal and alternate cooling water supply valves to open on demand from their normally closed position. As a result, since only three site NSW pumps are required to be OPERABLE, the capability to automatically transfer the cooling water supply.to the DG jacket water coolers from the NSW header of one unit to the NSW header of ; the opposite unit is necessary to meet single failure crit 2ria. The 92 day Frequency was chosen to provide additional i assurance that the capability to provide cooling water to ' each DG under accident conditions is maintained. The 92 day .l Frequency is consistent with the Inservice Testing Program I Frequency for testing of valves. ' l :
-To minimize testing of the cooling water supply valves to i each DG, Note 1 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main' purpose of the surveillance can be met by performing the test on either unit. Note 2 indicates that isolation of the SW System to a i
(continued) l O '
. Brunswick Unit 1 B 3.7-18 Revision No. ...m...._...
SW Systa and UHS - B 3.7.2
- BASES SURVEILLANCE. SR 3.7.2.4 (continued)
REQUIREMENTS DG renders the DG inoperable but does not affect the OPERABILITY of the SW System. As such, if the automatic transfer of the cooling water supply valves associated with a DG fails this Surveillance, the DG should be considered inoperable. However, the SW System is still OPERABLE. g SR 3.7.2.5 This SR verifies that the automatic isolation valves of the SW System will automatically align to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the required NSW pumps. Operating experience has demonstrated that these components will usually pass the SR when performed at the 24 month Frequency. Therefore, this Frequency is concluded to be ' acceptable from a reliability standpoint. A Note indicates that the isolation of the SW System to individual components (e.g., an RBCCW heat exchanger) does not affect the OPERABILITY of the SW System. Isolation of SW System flow to an individual component must be performed ' such that an active component-failure will not result in diverting SW System flow from the safety related components. REFERENCES 1. BNP Calculation PCN G0050A-10, BSEP Unit No.1 Service Water System Hydraulic Analysis, Revision 6,7/29/93.
- 2. BNP Calculation PCN G0050A-12, BSEP Unit No. 2 Service Water System Hydraulic Analysis, Revision 5, 8/11/92.
- 3. UFSAR, Chapter 6.2.
- 4. 10 CFR 50.36(c)(2)(ii).
l Brunswick Unit 1 B 3.7-19 Revision No.
1 SW System and UHS 3.7.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action C.1 D.1 Restore required CSW 72 hours b and associated pump to OPERABLE Completion Ti-e not :tatus. met. g E. Two required CSW pumps E.1 --------NOTE--------- inoperable. Enter applicable Conditions and Required Actions of l LCO 3.7.1, " Residual i Heat Removal Service Water (RHRSW) System,' for RHRSW subsystems made inoperable by CSW. O Restore one required CSW pump to OPERABLE 72 hours b V status. AND 14 days from discovery of I failure to meet LC0 F. One required NSW pump F.1 Restore required NSW 72 hours inoperable. pump to OPERABLE AND status. 8 l 98 One required CSW pump inoperable. F.2 Restore required CSW pump to OPERABLE 72 hours [b status, g (continued) O Brunswick Unit 2 3.7-6 Amendment No. l
SW System and UHS 3.7.2 i ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME G. One required NSW pump G.1 Verify by Immediately inoperable. administrative means a , that two Unit 2 NSW D l A_NQ pumps are OPERABLE. Two required CSW pumps AND G.2.1 Restore required NSW 72 hours pump to OPERABLE status. 9E G.2.2 Restore one required CSW pump to OPERABLE 72 hours b status.
=
H. Water temperature of H.1 Verify water Once per hour b 0 the UHS > 89'F and s 92*F. temperature of the UHS is s 89'F averaged over 1 previous 24 hour period. . l (continued) i i O Brunswick Unit 2 3.7-7 Amendment No.
SW System and UHS 3.7.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME I. Required Action and I.1 Be in MODE 3. 12 hours b associated Completion Time of Condition A, Ngl B, D, E, F, G, or H not met. I.2 Be in MODE 4. 36 hours g QE Required Action C.2 and associated Completion Time not met. 8-98 Two or more required NSW pumps inoperable. DE SW System inoperable O for reasons other than Conditions A, B, C, D, g E, F, and G. DE UHS inoperable for reasons other than Condition H. 6 l lD l. l l Brunswick Unit 2 3.7-8 Amendment No. l
SW System and UHS 3.7.2 I ( SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.7.2.1 Verify the water level in the SW pump 24 hours suction bay of the intake structure is 2: -6 ft mean sea level. SR 3.7.2.2 Verify the water temperature of UHS is 24 hours
- s; 89'F.
SR 3.7.2.3 -------------------NOTE-------------------- Isolation of flow to individual components does not render SW System inoperable. Verify each SW System manual, power 31 days operated, and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the
/ correct position.
SR 3.7.2.4 -------------------NOTES-------------------
- 1. A single test at the specified Frequency will satisfy this Surveillance for both units.
- 2. Isolation of flow to individual components does not render SW System inoperable.
Verify automatic transfer of each DG 92 days cooling water supply from the normal SW supply to the alternate SW supply on low DG , jacket cooling water supply pressure. ' (continued) O V Brunswick Unit 2 3.7-9 Amendment No.
SW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.7.2.5 -------------------NOTE-------------------- Isolation of flow to individual components does not render SW System inoperable. Verify each required SW System automatic 24 months component actuates on an actual or simulated initiation signal. O i 1 O Brunswick Unit 2 3.7-10 Amendment No.
, RHRSW System B 3.7.1 BASES (continued)
APPLICABLE The RHRSW System removes heat from the suppression pool to SAFETY ANALYSES limit the suppression pool temperature and primary containment pressure following a LOCA. This ensures that the primary containment can perform its function of limiting the release of radioactive materials to the environment following a LOCA. The ability of the RHRSW System to support long term cooling of the reactor or primary containment is discussed in Reference 2. These analyses explicitly assume that the RHRSW System will provide adequate cooling support to the equipment required for safe shutdown. These analyses include the evaluation of the long term primary containment response after a design basis LOCA. The safety analyses for long term cooling were performed for various combinations of RHR System failures. The worst case single failure that would affect the performance of the RHRSW System is any failure that would disable one subsystem ' of the RHRSW System. As discussed in the UFSAR (Ref. 2) for these analyses, manual initiation of the OPERABLE RHRSW subsystem and the associated RHR System is assumed to occur 10 minutes after a DBA. The RHRSW flow assumed in the analyses is 4500 gpm from two pumps operating in one loop. In this case, the maximum suppression chamber water lb O temperature and pressure are 189.4*F and 14.0 psig, respectively, well below the design temperature of 220*F and d maximum allowable pressure of 62 psig (Refs. 3 and 4). The RHRSW System satisfies Criterion 3 of Reference 5. LCO Two independent RHRSW subsystems are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power. An RHRSW subsystem is considered OPERABLE when:
- a. Two pumps are OPERABLE; and
- b. An OPERABLE flow path is capable of taking suction from the intake canal via the SW System and transferring the water through the RHR heat exchangers at the assumed flow rate. Additionally, the RHRSW cross tie valve (which allows the suction headers of the two RHRSW loops to be connected) must be available to provide the ability to isolate one subsystem from -
(continued) . Brunswick Unit 2 B 3.7-2 Revision No.
1 SW System and UHS B 3.7.2 BASES (continued) l APPLICABILITY In MODES 1, 2, and 3, the SW System and UHS are required to
- l. be OPERABLE to support OPERABILITY of the equipment serviced by the SW System. Therefore, the SW System and UHS are required to be OPERABLE in these MODES.
In MODES 4 and 5, the OPERABILITY requirements of the SW , System and UHS are determined by the systems they support. i ACTIONS A,.1 The normal cooling water supply for two DGs and the alternate cooling water supply for two DGs are provided by the opposite unit NSW pumps via the associated NSW header. Therefore, this Required Action provides a 14 day period to perform maintenance on the opposite unit NSW header and associated NSW pumps. This is acceptable because performing maintenance on the opposite unit NSW header and NSW pumps will increase the reliability of the DGs cooling water supply. However, if this condition results in two required site NSW pumps being incapable of providing cooling water to the DGs, Condition I is entered. h The 14 day Completion Time takes into account the capacity and capability of the remaining NSW pumps to supply cooling to all four DGs and a reasonable time for performance of maintenance. The Note to Condition A only allows the 14 day Completion Time to apply when the opposite unit is in MODE 4 or 5. When a required NSW pump becomes inoperable or incapable of providing cooling water to the DGs while Unit 1 is in ! MODE 1, 2, or 3, Condition B or I of Unit 2 Specification 3.7.2 must be entered, as applicable, and the 8 associated Required Action (s) performed. Pursuant to LC0 3.0.6, the AC Sources-0perating ACTIONS would not be entered even if cooling capability were lost to the DGs, resulting in one or more inoperable DGs. Therefore, Required Action A.1 is modified by a Note to indicate that when Condition A is entered and NSW cooling capability is unavailable to one or more DGs, ACTIONS for LC0 3.8.1, "AC Sources-Operating," must be immediately entered. This allows Condition A to provide requirements (continued) G V Brunswick Unit 2 B 3.7-10 Revision No.
SW System and UHS
'B 3.7.2 BASES
' ACTIONS M (continued)_
for an inoperable NSW pump without regard to whether a cooling water supply is available to the DGs. LCO 3.8.1 provides the appropriate restrictions for one or more. inoperable DGs. M With one required NSW pump inoperable for reasons other than Condition A, one inoperable pump must be restored to OPERABLE status within 7 days and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the remaining OPERABLE NSW and CSW-pumps are adequate to perform the SW heat removal function. However, -the overall reliability is reduced. The 7 day Completion Time is based on the remaining SW heat removal capability, a reasonable ,
' time for repairs, and the low probability of an event I occurring during this time period requiring the SW System.
The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any O- combination of required NSW and CSW pumps to be-inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, a required CSW pump is inoperable, and that CSW pump'is subsequently returned OPERABLE, the LCO may already have been not met for up to 7 days. This situation could lead to a total of 14 days, since initial failure to meet the LCO, to restore the NSW pump. At this time, a required CSW pump-could again become inoperable, the NSW pump restored OPERABLE, and an additional 7 days (for a total of 21 days) allowed prior to complete restoration of.the LCO. The 14 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions B and C or Conditions B and D are entered concurrently. The "ANQ"N connector between the 7 day and the 14 day Completion Times means that both Completion Times apply simultaneously, and the' more restrictive Completion Time must be met. The second Completion Time allows for an exception to the normal " time zero" for. beginning the allowed outage time " clock." This exception results'in establishing the " time zero" at the time LCO 3.7.2 was initially not met, instead of at the time that Condition B was entered. ! (continued) Brunswick Unit 2' B 3.7-11. Revision No. 2____-_:_____-.
SW System and UHS B 3.7.2 BASES ACTIONS R J (continued) Pursuant to LC0 3.0.6, the AC Sources-Operating ACTIONS would not be entered even if cooling capability were lost to the DGs, resulting in one or more inoperable DGs. Therefore, Required Action B.1 is modified by a Note to indicate that when Condition B is entered and NSW cooling capability is unavailable to one or more DGs, ACTIONS for LC0 3.8.1, "AC Sources-0perating," must be immediately entered. This allows Condition B to provide requirements
)
i for an inoperable NSW pump without regard to whether a i cooling water supply is available to the DGs. LCO 3.8.1 provides the appropriate restrictions for one or more inoperable DGs. C.1 and C.2 With one required CSW pump inoperable, the inoperable pump g! must be restored to OPERABLE status within 7 days and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the OPERABLE CSW pump and NSW pumps are adequate to perform the heat removal function. However, kj ' the overall reliability is reduced. The 7 day Completion
~
Time is based on the availability of two Unit 2 SW pumps (an OPERABLE CSW pump and an OPERABLE Unit 2 NSW pump), each powered from separate 4.16 kV emergency buses, to support the unit's service water loads. Immediate verification that the OPERABLE CSW pump and one OPERABLE Unit 2 NSW pump are powered from separate emergency buses is therefore required when one required CSW pump is inoperable. If the OPERABLE g CSW pump and one Unit 2 NSW pump can not be immediately verified to be powered from separate 4.16 kV emergency buses, Condition E must be immediately entered. The 7 day Completion Time is based on the remaining SW heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during this time period requiring the SW System. The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required NSW and CSW pumps to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, a required NSW pump is inoperable, and that NSW pump is subsequently returned OPERABLE, the LC0 may already have p m.. (continued) Brunswick Unit 2 B 3.7-12 Revision No. . 1
SW System and UHS B 3.7.2
;a - BASES ACTIONS C.1 and C.2 (continued) been not met for up to 7 days. This situation could lead to
,a total of 14 days, since initial failure to meet the LCO, to restore the CSW pump. At this time, a required NSW pump could again become inoperable, the CSW pump restored OPERABLE, and an additional 7 days (for a total of 21 days) allowed prior to complete restoration of the LCO. The 14 day Completion Time provides a limit on the time allowed in a specified condition.after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions B and C are entered concurrently. The "6N_Q" connector between the 7 day and the 14 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. The second Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This exception results in establishing the " time zero" at the time LC0 3.7.2 was initially not met, instead of at the time that Condition C was entered. D.1 If Required Action C.1 cannot be completed within the associated Completion Time or if the status of the Unit 2 SW 8 pumps changes after Required Action C.1 is initially met, one required CSW pump must be restored to OPERABLE status within 72 hours. With the unit in this condition, the A C OPERABLE SW pumps are adequate to perform the heat removal function. However, overall reliability is reduced as compared to Condition C and a reduced Completion Time of 72 hours is provided. The 72 hour Completion Time is based. i on the remaining SW System heat removal capability, a ' reasonable time for repairs, and the low probability of an event occurring during the time period requiring the SW System. L1 With two required CSW pumps inoperable, the one ' required inoperable pump must be restored to OPERABLE status within 72 hours and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the OPERABLE NSW pumps are adequate to perform the heat removal function.
, (continued)
U Brunswick Unit 2 B 3.7-13 Revision No.
SW Systen and UHS B 3.7.2 BASES Ed (continued)
. ACTIONS The 72 hour Completion Time is based on the availability of the remaining MSW pumps to support the unit's service water 8
loads. The 72 hour Completion Time is based on the remaining SW System heat removal capability, a reasonable - time for repairs, and the low probability of an event occurring during this time period requiring the SW System. g. The second Completion Time for Required Action E.1 establishes a limit on the maximum time allowed for any k combination of required NSW and CSW pumps to be inoperable during any single contiguous occurrence of failing to meet d the LCO. If Condition E is entered while, for instance, a required NSW pump is inoperable, and that NSW pump is h subsequently returned OPERABLE, the LCO may already have been not met for up to 7 days. This situation could lead to a total of 14 days, since initial failure to meet the LCO, to restore the CSW pump. At this time, a required NSW pump could again become inoperable, the CSW pump restored OPERABLE, and an additional 7 days (for a total of 21 days) g allowed prior to complete restoration of the LCO. The 14 day Completion Time provides a limit on the time allowed O in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which conditions B and E are entered concurrently. The "NG" connector between the 7 day and the 14 day Completion bl Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. The l second Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
d This exception results in establishing the " time zero" at the time LCO 3.7.2 was initially not met, instead of at the time that Condition E was entered. Pursuant to LC0 3.0.6, the RHRSW ACTIONS would not be /A entered even if cooling capability were lost to the RHRSW m heat exchangers, resulting. in one or more inoperable RHRSW subsystems. Therefore, Required Action E.1 is modified by a "/g\ i Note to indicate that when Condition E is entered and cooling capability is unavailable to one or more RHRSW subsystems, ACTIONS for LCO 3.7.1, " Residual Heat Removal Service Wster (RHRSW) System," must be immediately entered. g l (cont;inued) O V I Brunswick Unit 2' B 3.7-14 Revision No. l ___________ _ _ a
SW System and UHS B 3.7.2 BASES ACTIONS Ed (continued) This allows Condition E to provide requirements for one or b more required inoperable CSW pumps without regard to whether a cooling water supply is available to the RHRSW heat exchangers. LCO 3.7.1 provides the appropriate restrictions for one or more inoperable RHRSW subsystems. g F.1 and F.2 b If one required CSW pump and one required NSW pump are concurrently inoperable, one of the inoperable pumps must be b restored to OPERABLE status within 72 hours. With the unit in this condition, the OPERABLE SW pumps are adequate to perform the heat removal function. The 72 hour Completion g Time is based on the remaining SW System heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during this time period requiring the SW System. G.I. G 2.1. and G.2.2 b If two required CSW pumps are inoperable concurrent with one required NSW pump inoperable and both Unit 2 NSW pumps are verified OPERABLE, one of the required CSW pumps must be h restored to OPERABLE status within 72 hours or the required NSW pump must be returned to OPERABLE status within 72 hours. Since loss of the two required CSW pumps and one required NSW pump could result in a loss of cooling capability to the vital and RHRSW headers, immediate verification that two Unit 2 NSW pumps are OPERABLE is
~
required to ensure cooling capability to the vital and RHRSW headers is maintained. This may be performed as an administrative check by examining logs or other information to determine if one or both Unit 2 NSW pumps are out of service for maintenance or other reasons. It does not mean to perform the Surveillance needed to demonstrate the OPERABILITY of the NSW pumps. However, if the OPERABILITY of both Unit 2 NSW pumps cannot be verified, cooling g capability to the ECCS loads cannot be assured. As such, Condition I must be immediately entered. With two required 'h CSW pumps inoperable concurrent with one required NSW pump inoperable and both Unit 2 NSW pumps are OPERABLE, adequate heat removal capability is ensured by the OPERABILITY of the (continued) O Brunswick Unit 2 B 3.7-15 Revision No.
SW Systea and UHS B 3.7.2 ( BASES V ACTIONS G.I. G.2.1. and G.2.2 (continued) h remaining OPERABLE SW pumps. However, the overall SW System reliability is significantly reduced because of the reduction in SW pump redundancy.and operational diversity such that the SW System may not be able to perform its required support function. Therefore, a more restrictive Completion Time of 72 hours is required to restore at least l one required CSW pump or the required NSW pump to OPERABLE ! status. M l With water temperature of the UHS > 89'F and s 92*F, the l design basis assumption associated with initial UHS l temperature are bounded provided the temperature of the UHS averaged over the previous 24 hour period is s 89'F. With the water temperature of the UHS > 89'F, long term cooling capability of the ECCS loads and DGs may be affected. Therefore, to ensure long term cooling capability is provided to the ECCS loads when water temperature of the UHS is > 89'F, Required Action H.1 is provided to more b , O' frequently monitor the water temperature of the UHS and verify the temperature is s 89'F when averaged over the ; previous 24 hour period. The once per hour Completion Time takes into consideration UHS temperature variations and the increased monitoring frequency needed to ensure design basis assumptions are not exceeded in this condition. If the water temperature of the UHS exceeds 89'F when averaged over the previous 24 hour period or the water temperature of the UHS exceeds 92*F, Condition I must be entered immediately. I.1 and I.2 If Required Actions cannot be completed within the associated Completion Time of Condition A, B, D, E, F, G, and H; Required Action C.2 cannot be completed within the g associated Completion Time; two or more required NSW pumps are inoperable; the SW System is inoperable for reasons other than Conditions A, B, C, D, E, F, and G; or the VHS is inoperable for reasons other than Condition H (e.g., low water level); the unit must be placed in a MODE in whid. Le LCO does not apply. To achieve this status, the unit must (continued) O Brunswick Unit 2 B 3.7-16 Revision No.
SW System and UHS B 3.7.2 BASES ACTIONS I.1 and I.2 (continued) be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies the water level in the SW pump suction bay I of the intake structure to be sufficient for the proper operation of the SW pumps (net positive suction head and pump vortexing are considered in determining this limit). This SR may be accomplished by measuring intake canal water level provided the deviation in water level between the intake canal and the pump suction bay due to the differential pressure of the traveling screens is taken into account. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. SR 3.7.2.2 Verification of the UHS temperature ensures that the heat removal capability of the SW System is within the assumptions of the DBA analysis. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. SR 3.7.2.3 Verifying the correct alignment for each manual, power operated, and automatic valve in the SW System flow paths provide assurance that the proper flow paths will exist for SW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be automatically realigned to its accident position within the (continued) j ( v Brunswick Unit 2 B 3.7-17 Revision No. , 1 i i
SW Syst:m and UHS B 3.7.2 BASES SURVEILLANCE SR 3.7.2.3 (continued) REQUIREMENTS required time. This SR does not require testing or valve manipulation; rather, it involves verification that those valves crpable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. 1 This SR is modified by a Note indicating that isolation of the SW System to components or systems may render those components or systems inoperable, but does not affect the OPERABILITY of the SW System. As such, when all SW' pumps, valves, and piping are OPERABLE, but a branch connection off the NSW or CSW header is isolated, the SW System is still OPERABLE. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. SR 3.7.2.4 The dominant contributor to a loss of DG cooling is a failure of the normal and alternate cooling water supply valves to open on demand from their normally closed position. As a result, since only three site NSW pumps are required to be OPERABLE, the capability to automatically transfer the cooling water supply to the DG jacket water coolers from the NSW header of one unit to the NSW header of the opposite unit is necessary to meet single failure criteria. The 92 day Frequency was chosen to provide additional assurance that the capability to provide cooling water to each DG under accident conditions is maintained. The 92 day Frequency is consistent with the Inservice Testing Program Frequency for testing of valves. To minimize testing of the cooling water supply valves to each DG, Note 1 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. Note 2 indicates that isolation of the SW System to a (continued) Brunswick Unit 2 B 3.7-18 Revision No. l
I l SW Systea and UHS l B 3.7.2 i (Gg BASES i SURVEILLANCE SR 3.7.2.4 (continued) REQUIREMENTS DG renders the DG inoperable but does not affect the OPERABILITY of the SW System. As such, if the automatic transfer of the cooling water supply valves associated with a DG fails this Surveillance, the DG should be considered inoperable. However, the SW System is still OPERABLE. g SR 3.7.2.5 This SR verifies that the automatic isolation valves of the SW System will automatically align to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated . initiation signal. This SR also verifies the automatic start capability of the required NSW pumps. Operating experience has demonstrated that these components will usually pass the SR when performed at the 24 month frequency. Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.
'~
A Note indicates that the isolution of the SW System to individual components (e.g., an RBCCW heat exchanger) does not affect the OPERABILITY of the SW System. Isolation of SW System flow to an individual component must be performed such that an active component failure will not result in diverting SW System flow from the safety related components. REFERENCES 1. BNP Calculation PCN G0050A-10, BSEP Unit No. I Service l Water System Hydraulic Analysis, Revision 6, 7/29/93.
- 2. BNP Calculation PCN G0050A-12, BSEP Unit No. 2 Service Water System Hydraulic Analysis, Revision 5, 8/11/92.
1
- 3. UFSAR, Chapter 6.2.
- 4. 10 CFR 50.36(c)(2)(ii).
O Brunswick Unit 2 B 3.7-19 Revision No.
~ .. ., :... . . ... .
r\. p. Qe k % 3.7.L I w () ..; 3M.7PLANTSYSTEMS 3/4MSERVICE WATER 'SYSTDtS' dl1i h j.1 I.N_Il COND FOR ERAT [ d1%4e/Q- G
. Leo 3.78.2 The Service Water System be OPERABLE)$th at: le g,,
In OPERATI CONDITIONS 1, 2, 3: ee OPERABLE site clear servi water , and two OPERAS l conventional servi e water pump capable o/ f nr, j,2.i
. upplying the conventional hpaders.
In OP 10NAL CONDITIONS 4 5: " I Thr OPERABLE site nuc ar service water s. and two LE Un 1 servic wa ar and/or conven onal, powered f separa . emergenc 'ter pumps, nucbuses and capabl of supplying the uclear header. _ APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3.M. a s[ 5 y,7 ACTION: (a.,,, Tn OPF,BAHONAL C0tiDHf0NS 1, 2, eP7i) With one OPERABLE conventional service water pump:
- a. Ensure that.1f only one' Unit I nuclear service water pump /d.L
,[ C ' is OPERABLE. the OPERABLE conventional service water bump is , /d red from a separate emergency bus than the OPERAB nit,1 nuclear _ service water pump. and ,
_. g} , Restore at least one additional conventional service water C"7
# '3 @) to OPERABLE status within 7 days n bw
'Lg*~C j M MD l."AT '
,j rp g% ** ,1 p.g Ac.ma lC f g ,,E.1fQPM)
(,. Othe SHilTDOWN within W.I se, be in at least HOT SHlffDOWN withi ITN5urs ano m the following 24 hours' Q9 - 8 With no conventional service water pumps OPERABLE: 1, i (. r nit 1 aac_ Tear terWee wady arf' OPERABLE) ! Q$ t% .3 Restore at least one conventional service water pump to OPERABLE status within 72 hours. , Otherwise, be in at least HOT SHlHDOWN within 12 hours and COLD Acrlao [ (k ," SHLRDOWN within the following 24 hours. '
'3
@* 8 .@ (With two OPERABLE site nuclear service water pumps,dilDHC:EllD, p site nuclear service water pump withi 7 days or be in at least gg
( HOT SHilTDOWW within 12 hours and COLD within the MI[ L following 24 hours. O k".M P*~ B \n b i
".ww rg Ak%.2."*Co 4 e d pg%e.3 Y7 L)
BRUNSWICK - UNIT 1 3/4 7 2 Amendment No. 164 l
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*. 6 *: W *-; x*y,). 7;2'-
hPLAlff SYSTEMS CLI3pmCONotuarm OJP RAffGF(Con,t,,imadp - KI1Ql: (Continued)
,@- With two OPERABLE site nuclear service water pumps and one OPERABLE conventional service water pump: LA f sure at lea OPERABLE.
w Unit I nuc ' r service er pump isT pM F f Ensur that. if oni unit I nucie service wate is RABLE the LE conventi service wa pump'is red fron'a se rate emergen s than the LE j (' nit I nuclear rvicewater=yc and A ',,h g -Restore two co'nventiodi service w6ter pumps or three site
- m. . s.
nuclear / service water pumps to OPERABLE status within 72 hours. , _ b [ g[L Otherwise, be in at least HOT SHUT 110WN within 12 hours and COLD SHUTDOWN within the following 24 hours.
/k N I @ With less than two OPERABLE site nuclear service water in at least HOT SHllTDOWN within 12 hours and COLD
- s. be within
= the following 24 hours.
- b. I ERATIONAU ITIONS 4 or 5: ~
- 1. With OPERABLE Unit 1 ser ce water pump, restore eastw t ]o)
Uni service water pump o OPERABLE status withi days. rwise, suspend all rations that have a pot ial for raining the reactor essel. 1 b . With no OPERAB it I service water pump . suspend all operations t have a potential for dr ing the reactor vessel.- l-* I 3. With ERABE site nuclear se water pumps, unless the l provi of ACTION b.4 apply, tore at least one additi i
@aO nuc ar service water rwise, take the AC I to status within 7 ired by Specification ..2 l
g f*s bM @ of ith t rvice wa 1ts may nue tem 'r header i th:t able, appetion i 2 nucimr ' - M.2. A water s are th its' nuc r er helde valves ar aminis atively rolled s red to awe ens re coo 11 water to the die nerat s at le t two it 1 ' d *O,*^ c ntional s evice wat pumps OPERAB on the i 1 2 7-
~ yA.I heade , and vit 1 ECCS 1 is arm a swd to ! onal 1 water tem headetJRes " the serv',ge' water system 'L !
. Acyjog A ' nuclepheader andpleast tt e nuclear servica dar=gs toJIPERABI status withiu :Mtys /ptnerw1 . take the F TI required >y Iricat1on U.8X.2.
a !.
- 5. th less than OPERABLE si lear servi water ptmps, take t ACTION requi by Specifica 3.8.1.2.
BRUNSWICK UNIT 1 3/4 7 2a Amendment No.164 l mm
7
. ,, j ..,/,
s. sc . _r. - od 7, 3M.7PLANTSYSTEMS
/4.7.1 SERM CE WATER SY I_ CONDITI OPERATION MbIld 3.7.1.2 The Service Water System 11-beOPERABL[Eth at 1 ast:
O* n' OPERATIONAL CO IT50NS1,2,and[ Thr LE site nucl service water . and two OPERABLE entional service wpt'er pumps capable o supplying the nucl and nventional headers / ! In OPEPATI CONDITIONS 4 AND 5: i Three OP LE site nuclear serv e water s. and two OP LE Unit 2 service wa er pumps, nuclear and/o conventi al. powered froe separate emergency ,es andlacable of supp ng the clear header. g APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 4. an 5 ACTION: [ Irr0PERATI0BAMDNDITIOM2.,pr@ g With one OPERABLE conventional service water pump:
- a. Ensure that, if only one Unit 2 nuclear service water pump fA .7-M*d C g.'3 is OPERABLE the OPERABLE conventional service water ump is g ered from a separate emergency bus than the OPERAB nit 2 nuclear service water pump, and Restore at least one additional conventional service water -
/ M' 2*
.1&a@ j ump to OPERABLE status s N , .. swithin
.,t re A 7 *- day Q4 .Ag g s, '
Acred $ Othe se, be in at least HOT SHlHDOWN within u nours and in COLD) I SHLITDOWN within the following 24 hours. g4 fg i With no r_ conventional service water pumps OPERABLE: e both UnitJM6 clear ser)v ce'Trater pumpsALEp 6 Restore at least one conventional service water pump to y' ( k[
~
OPERABLE status within 72 hours,. Otherwise, be in at least HOT SHlRDOWN within 12 hours and COLD gmo f{( , SHUTDOWN within the following 24 hours. pa(L h Wjth two OPERABLE site nuclear service water pumps,dialesttElb rovjetons;#iu.iin.* angrv for un+t u restore one additTonal gl.3 site nuclear service water pump with 7 days or be in at least A420 HOT SHUTDOWN within 12 hours and C0 within the following 24 hours. - k J134-y b'g rCo-yW + y ed t%A flnle WO Mm & BRUNSWICK - UNIT 2 3/4 7-2 (b b Amendment No. 195 l C 40%
- , .< + w . : . ,.e. ., ,, . . .
h(lANT SYSTEMSIMITJNrrCONDITp 0PERATIMn eGIl0N: (Continued) With two OPERABLE site nuclear service water pumps and one t, I
@ OPERABLE conventional service water pump:
Ens at least one t 2 nuclear se ce water pump i LE, and lnnou F Ensure that f only one Unit nuclear service er pump ater pump is entional servic j is OPERAB , the OPERABLE (( powere Uni rom a separate nuclear service ter pump, and rgency bus than Restore two conventional service water pumps or three site OPERABLE ] - g p nuclear service water pumps to OPERABLE status within
. -y, [ ;.,,
G2 hours.
)
Otherwise, be in at least HOT SHUlDOWN within 12 hours and COLD JC71od f SHlTTDOWN within the following 24 hours. With less than two OPERABLE site nuclear service water pumps, be SC N I @. in at least HOT SHlflDOWN within 12 hours and COLD SHUTDOWN within the following 24 hours. g,
- b. In ' RATIONAL CONDITI 4 or 5:
Unit 2 service w er pump, restore at le two
. With one OP Unit 2 sery water pumps to OP LE status within 7 da .
4 Otherwise suspend all operati s that have a potential or j
/ ,
draini the reactor vessel. no OPERABLE Unit 2 s vice water pumps, suspe all b ' f G 2. WI tential for draining th reactor vessel. I rations that have a
- 3. With two OPERABLE si nuclear service water s unless the i
provisions of ACTI b.4 apply, restore at ast one additional )
. to OPERABLE st us within 7 days.
g jt* nuclear service ter otherwise, take/the AC required by ification 3.8.1.2. l b { ith the se 4ctiwater systeg,nucrear header i able, ope >r tion
. gb j
h of bot s may contingr5rovided that t nit I nuclear i water m=nt wate header valve e administr ively controT ed as requi
~are'DPERABLEAmth to.
units' ' nuclear
/lhfe.,4 nerators, as east two 2 L/),2-ensure ooling water the diesel L,
' '7"
% convent nal service w r pumps are ERABLE on t conventio "g header, a vital ECCS s are alio to the ennvantinnal uervice wat system head store ice water s Aajo.s A ' nuclear headef and at 1 n 14 days. hree si lear servic ater pumps to LE status e, take the ION requTrea by speci cation 3.8.1.2.
ce water pumps, ke
- 5. ith less than two LE site nuclear se ACTION required by cification 3.8.1.2.
'f m 3/4 7 2a Amendment No. 195 l BRUNSWICK - UNIT 2 ye SofG
L DISCUSSION OF CHANGES ITS:-3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINd (VHS) ADMINISTRATIVE A.) In the conversion of the Brunswick Nuclear Plant (BNP) current l Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). ' Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor Standard
- Technical Specifications, NUREG-1433, Rev.1.
I A.2 A Note is added to CTS 4.7.1.2.a (ITS SR 3.7.2.3), CTS 4.7.1.2.b l (ITS SR 3.7.2.5), and CTS 4.7.1.2.c (ITS SR 3.7.2.4) which ! clarifies that the isolation of individual components which are supported by the Service Water (SW) System does not make the support system (SW System) inoperable. The Note is added to provide clarity consistent with current interpretation. This change is only an enhanced presentation of existing interpretation of the requirement and does not alter the intent of the requirement. As such, the change is considered administrative. A.3 A Note is added to CTS 4.7.1.2.c (ITS SR 3.7.2.4) that allows one test performance to satisfy the requirements for both units to minimize testing of the cooling water supply valves to each OG. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. Adding this hq information does not alter the testing requirements (actual or interpretational) for the DG cooling water supply valves and is consistent with current plant practice. Therefore, this change is considered administrative. TECHNICAL CHANGES - MORE RESTRICTIVE M.1 LC0 requirements and Required Actions associated with the Ultimate Heat Sink (UHS) are added to CTS 3.7.1.2 and additional Surveillance Requirements are added to CTS 4.7.1.2 (ITS SRs 3.7.2.1 and 3.7.2.2) to periodically verify that the UHS is OPERABLE. The minimum UHS level requirement is assumed in the BNP safety analysis to ensure proper net positive suction head to the SW pumps and maximum UHS temperature is assumed in the BNP long term cooling analysis and containment cooling analysis. This change represents an additional restriction on plant operation necessary to help ensure the OPERABILITY of the UHS. M.2 The Completion Times of ITS 3.7.2 Required Actions B.1, C.2, and E.1 include a limitation in addition to the 7 day limit in CTS 3.7.1.2 ACTION a.l.b and a.3 and the allowable outage time h
-limit in CTS 3.7.1.2 ACTION a.2.b. This. additional limit establishes a maximum time allowed for any combination of required NSW and CSW pumps to be inoperable during any single contiguous occurrence of failing to meet the LCO. If a required NSW pump is /]
V inoperable while, for instance, a required CSW pump is inoperable and subsequently returned to OPERABLE status, the LCO may already BNP UNITS l & 2 1 Revision 0 a
DISCUSSION OF CHANGES ITS: 3.7.2 - SERVI;c WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS) l TECHNICAL CHANGES - MORE RESTRICTIVE M.2 have been not met for up to 7 days. This situation could lead to (cont'd) a total duration of 14 days since initial failure to meet the LCO to restore the SW System to OPERABLE status- Then, a CSW pump could again become inoperable, and the NSW pump restored to OPERABLE status. As a result, failure to meet the LCO could continue indefinitely. Therefore, to preclude this situation and place an appropriate restriction on any such unusual situation, the additional Completion Time of "14 days from discovery of failure to meet LC0" is added. D.s addition of this " maximum" Completion Time represents an additional restriction on plant operation. M.3 Pursuant to ITS 3.0.6, the Technical Specification ACTIONS for AC Sources-Operating (ITS 3.8.1) or Residual Heat Removed Service Water (RHRSW) System (ITS 3.7.1), as applicable, would not be-entered even if cooling capability were lost to the DGs or the RHRSW System. Therefore, ITS 3.7.2 Required Action B.1
- l. (CTS 3.7.1.2 ACTION a.3) is modified by a Note to indicate that l when ITS 3.7.2 Condition B is entered and NSW cooling capability is unavailable to one .or more DGs, the applicable ACTIONS for ITS 3.8.1 must be immediately entered. Also, ITS 3.7.2 Required Action E.1 (CTS 3.7.1.2 ACTION a.2.b) is modified by a Note to indicate that when ITS 3.7.2 Condition E is entered and CSW g
cooling capability is unavailable to one or more RHRSW subsystems, the applicable ACTIONS for ITS 3.7.1 must be immediately entered. This allows ITS 3.7.2 Conditions B and E to provide requirements for an inoperable NSW pump or CSW pumps without regard to whether h cooling water is available t, the DGs or the RHRSW System. ITS 3.8.1 and 3.7.1 provide the appropriate restrictions for one or more inoperable DGs or RHRSW subsystems, respectively. The addition of these Notes represent an additional restriction on plant operation. M.4 A requirement to verify the automatic starting of each NSW pump on an actual or simulated initiation signal is added to CTS 4.7.1.2.b (ITS SR 3.7.2.5) by specifying that each required automatic
" component" actuates on at actual or simulated initiation signal.
This requirement is added to periodically verify that the NSW pumps are capable of automatically starting on a loss of coolant accident or a loss of offsite power signal to ensure cooling water is provided to the DGs. The addition of the requirement to verify the automatic starting of each NSW pump represents an additional restriction on plant operation necessary to help ensure the OPERABILITY of the NSW pumps. D U , l l BNP UNITS 1 & 2 2 Revision 0 '
- - _ _ - _ _ _ _ _ . _ - _ A
DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS) O V TECHNICAL CHANGES LESS RESTRICTIVE
" Generic" LA.1 The details relating to system OPERABILITY (i.e, at least three OPERABLE site NSW pumps and two OPERABLE CSW pumps) in CTS 3.7.1.2 are to be relocated to the Bases. These details are not necessary to ensure the SW System is OPERABLE. The requirements of ITS 3.7.2 and the definition of OPERABILITY are adequate for ensuring the SW System is OPERABLE. These details are not necessary to ensure the SW System can perform its required support function. Therefore, 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. ,
LA.2 The requirements for OPERABILITY of the Service Water System in ! non-operating MODES (i.e., MODES 4 and 5) in CTS 3.7.1.2 are to be ' relocated to the Bases for the supported systems and the Technical Requirements Manual. Since this system is a suppert system for other required equipment with their own Specifications, the definition of OPERABILITY in ITS 1.1 will provide sufficient assurance the system can perform its required support function. As such, these details are not required to be in Technical n Specifications to provide adequate protection of the public health i) and safety. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the Technical Specifications. Changes to the Technical Requirements Manual will be controlled by the provisions of 10 CFR 50.59. 8 LD.1 CTS 4.7.1.2.b requires that a functional test be performed on the Service Water System every 18 months. In ITS SR 3.7.2.5, the ! Frequency for the Service Water System functional test is i specified as once per 24 months. The surveillance test interval of this SR is oeing increased from once every 18 months to once i every 24 months for a maximum interval of 30 months including the ; 25% grace period. This SR ensures that the Service Water System is capable of automatic initiation. The surveillance test , verifies the OPERABILITY of the Service Water System actuation l circuitry. The Service Water System circuitry is designed to meet the requirements of IEEE 279 which ensures that no single circuit fault can prevent the safety system actuation. Furthermore, the service water pump and valves which are required to function are tested on a more frequent basis. This more frequent testing, although it does not test the actual initiation signal, verifies the OPERABILITY of the majority of the Service Water System circuitry. Furthermore, as stated in the NRC Safety Evaluation Report (dated August 2, 1993) related to extension of the Peach Bottom Atomic Power Station, Unit Numbers 2 and 3, surveillance
~'N intervals from 18 to 24 months:
(D BNP UNITS 1 & 2 3 Revision 0
1 DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS) TECHNICAL CHANGES - LESS RESTRICTIVE LD.1 " Industry reliability studies for boiling water reactors (cont'd) (BWRs), prepared by the BWR Owners Group (NEDC-30936P) t,how 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. i Since the probability of a relay or contact failure is small relative to the probability of mechanical component failure, increasing the logic system functional test interval represents no significant change in the overall safety system unavailability." Based on the above discussion, the impact, if any, of this change 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. " Specific" l L.1 The SW System is designed to provide cooling water for the removal of heat from equipment, such as the diesel generators (DGs), I residual heat removal (RHR) pump seal coolers, room cooling units ! for Emergency Core Cooling System (ECCS) equipment, and residual heat removal service water (RHRSW) heat exchangers, required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient. The SW System also provides cooling to unit components, as required, during normal operation. For each unit, the SW System consists of two 8000 gpm site nuclear b service water (NSW) pumps (the opposite unit also includes two 8000 gpm NSW pumps which can provide cooling water to the DGs), . three 8000 gpm unit conventional service water (CSW) pumps, a suction source, valves, piping, associated instrumentation, and two independent headers; the NSW header and the CSW header. The NSW header normally supplies cooling water to the Reactor Building , Closed Cooling Water (RBCCW) System and the CSW header normally supplies cooling water to the Turbine Building Closed Cooling Water (TBCCW) System. The NSW pumps are capable of supplying only the NSW header. However, each CSW pump can be manually aligned to the CSW header or the NSW header which provides additional operating flexibility. Each NSW pump is powered from a separate emergency bus. Two of the three CSW pumps associated with each unit are powered from two emergency buses powering NSW pumps associated with that unit. The remaining CSW pump is powered from an emergency bus associated with the opposite unit. Due to this BNP UNITS 1 & 2 4 Revision 0 4
f DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS) ( TECHNICAL CHANGES - LESS RESTRICTIVE L.1 configuration, a single failure of an emergency bus may result in I (cont'd) the loss of one NSW pump and one CSW pump on the same unit ud the loss of a CSW pump on the opposite unit. Upon receipt of a loss of offsite power (LOOP) signal, the inlet valves to the RBCCW heat exchangers associated with both units automatically close when power is available to isolate nonessential loads; the NSW pumps associated with both units automatically start immediately after power is restored; and cooling water is supplied to the DGs and the ECCS loads for each unit. Upon receipt of a unit loss of coolant accident (LOCA) signal (with or without a LOOP), the redundant inlet valves to the RBCCW heat exchangers associated with the affected unit automatically close wnen power is available to isolate nonessential loads; the NSW pumps, associated with the unit receiving the LOCA signal, automatically start 5 seconds after power is restored (if the pumps are not already running); and cooling water is supplied to the DGs and the associated unit ECCS loads. Upon receipt of a LOCA or LOOP signal, the CSW pumps are assumed to trip and flow to the TBCCW heat exchangers stops. Operator action is not assumed to occur during the first 10 minutes after initiation of the event. After 10 minutes, operators are assumed to isolate flow to the TBCCW heat exchangers and align the CSW pumps, as necessary, to the required SW header and provide cooling to the ECCS and RHRSW loads or DGs. 4 One pump (unit NSW or CSW pump) is capable of providing the required cooling capacity to support the vital header, which b supplies cooling water to the RHR pump seal coolers and ECCS room coolers; and the RHRSW header, which provides a ,uction source to the RHRSW pumps. In addition, one NSW pump is capable of providing the required cooling capacity to support all four DGs and the subject unit vital header loads. Cooling water is pumped from the intake canal by the SW pumps to the vital and RHRSW headers through either the CSW or NSW headers. After removing heat from the components, the water is discharged to the circulating water discharge tunnel. The vital and RHRSW headers can be aligned, using remotely operated valves, in configurations where cooling water is supplied by the NSW header alone, the CSW header alone, or a combination of the NSW and CSW headers such that each header serves only one safety related division. The four DGs are the only SW System loads common to both units. The normal cooling water supply for two of the four DGs is provided by the Unit 1 NSW header and the normal cooling water I supply for the remaining two DGs is provided by the Unit 2 NSW header. If a low SW supply pressure is sensed at a DG after the D3 starts, an automatic transfer is initiated which causes the alternate cooling water supply valve for the affected DG(s) to BNP UNITS 1 & 2 S Revision 0
DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS)
,- m i
v) TECHNICAL CHANGES - LESS RESTRICTIVE L.1 open and the normal cooling water supply valve to close thereby (cont'd) providing a cooling water flow path from the opposite unit's NSW header to the affected DG(s). A LOCA or LOOP signal generates DG start signals for the four DGs and automatically opens the service water supply valves to the associated DG jacket water coolers. The valves controlling flow from the vital header to the individual components served by the vital header are air-operated, ' and these valves are assume to fail open due to loss of unqualified service air compressors following a LOOP or a LOCA. . The two motor operated header isolation valves for each unit i individually supplying service water from the nuclear header to i the vital header and RHRSW header, are powered from a single i emergency bus, and this bus is separate from the emergency bus sup;'ving power to the header isolation valves on the conventional he&. Portions of the SW System which are not safety related are (. poble of being isolated from the safety related portions by redundant, electrically independent, motor operated valves. In the event of a DBA, the NSW header and associated components are adequate to provide the minimum heat removal capability assumed in the safety analysis for the systems to which it supplies cooling water. However, the CSW header and associated g components are required to ensure maximum reliability in the event (nj of a single failure. To ensure this requirement is met, the appropriate equipment to supply the unit NSW and CSW headers must be OPERABLE. In addition, at least three site NSW pumps are required to ensure adequate NSW pump redundancy is available to ensure cooling to the DGs in the event of an active single failure. CTS 3.7.1.2 and ITS LC0 3.7.2 requires the SW System to be OPERABLE. The SW System is considered OPERABLE when it has two OPERABLE CSW pumps, three site NSW pumps (any combination of Unit 1 and Unit 2 NSW pumps), and an OPERABLE flow path capable of taking suction from the intake structure and transferring the water to the ECCS equipment and the DGs. In addition, for a site NSW pump to be considered OPERABLE, it must be capable of supplying its associated unit NSW header. For a CSW pump to be considered OPERABLE, it must be capable of supplying the CSW header and the NSW header. The following changes apply, in MODES 1, 2 and 3, to CTS 3.7.1.2 ACTIONS:
- a. In the event one required CSW pump is inoperable and the subject unit NSW pump is not powered from a separate emergency bus from the OPERABLE CSW pump, ITS 3.7.2 Required Action D.1 allows continued operation for 72 hours.
/G CTS 3.7.1.2 ACTION a.1 requires a plant shutdown in the same V condition. BNP UNITS 1 & 2 6 Revision 0
DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS)
\
(O TECHNICAL CHANGES - LESS RESTRICTIVE L.1 b. The requirement to verify that the subject unit NSW pumps (cont'd) are OPERABLE when the required CSW pumps are inoperable is deleted. Therefore, ITS 3.7.2 Required Action E.1 allows continued operation for 72 hours in the event the required CSW pumps are inoperable and one of the two subject unit NSW pumps are inoperable. CTS 3.7.1.2 ACTION a.2 requires a plant shutdown in the same condition.
- c. The requirements to verify at least one subject unit NSW pump is OPERABLE and verify that the one OPERABLE CSW pump and one OPERABLE subject unit NSW pump are powered from separate emergency buses when one required NSW pump and one required CSW pump are inoperable are deleted. Therefore, ITS 3.7.2 Required Actions F.1 and F.2 allow continued {
operation for 72 hours in the event one required NSW pump i and one required CSW pump are inoperable concurrently, the two remeining OPERABLE NSW pumps are opposite unit NSW pumps, and the one OPERABLE CSW pump and one OPERABLE subject unit NSW pump are not powered from separate emergency buses. CTS 3.7.1.2 ACTION a.4 requires a plant shutdown in the same condition. g
- d. ITS 3.7.2 Required Actions G.1, G.2.1, and G.2.2 are added a to allow continued operation for 72 hours in the event one l required NSW pump and two required CSW pumps are inoperable
!") provided two subject unit NSW pumps are OPERABLE. Since CTS 3.7.1.2 does not address this condition, entry into CTS 3.0.3 is required implying that the plant is outside i design basis. The SW System hydraulic analyses summarized in CP&L calculations PCN G0050A-10, "BSEP Unit No. 1 Service Water System Hydraulic Analysis," Revision 6, 7/29/93; and PCN G0050A-12, "BSEP Unit No. 2 Service Water System Hydraulic Analysis," Revision 5, l 8/11/92, show that adequate cooling water is provided to the ECCS loads and two of the four DGs by one NSW pump for each unit during a design basis event. These analyses are based on BSEP computer models of the SW System using the KYPIPE hydraulic and document the calculated performance of the SW System under pump configurations permitted for continuous operation by the CTS 3.7.1.2 and ITS LCO 3.7.2 which were determined to be limiting. Additional analysis using this computer model were also performed and confirmed that one NSW pump is capable of providing the required cooling capacity to suppcrt all four DGs and the subject unit vital header loads (including accounting for leakage across the isolation valves between the nuclear header and conventional header piping when one of the two headers is depressurized). As a result, on a per unit basis, only one site
,, NSW pump is necessary to provide cooling to all four DGs and one unit specific SW pump (CSW or NSW pump) is necessary to provide (U)' cooling to the unit ECCS loads and RHRSW loads. The combinations BNP UNITS 1 & 2 7 Revision 0
DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS) TECHNICAL CHANGES - LESS RESTRICTIVE L.1 of inoperable SW pumps in the ITS 3.7.2 ACTIONS are based on the (cont'd) above referenced analyses which have been previously evaluated by the NRC for the issuance of Technical Specification Amendments 164 (Unit 1) and 195 (Unit 2). For all the above described changes, 1 the overall SW System redundancy is reduced. However, CP&L l calculations PCN G0050A-10 and PCN G0050A-12 and the referenced analysis for one NSW pump show the capacity and capability of the remaining SW pumps are such that adequate SW cooling is provided to all four DGs, the ECCS loads, and the RHRSW loads.
]
- a. For the change associated with the condition of one required CSW pump inoperable and the subject unit NSW pump not powered from a separate emergency bus, the OPERABLE SW pumps )
are adequate to perform the heat removal function. However, I overall reliability is reduced since a single failure of an l emergency bus may result in the loss of cooling capability to required components. The 72 hour Completion Time is based on the remaining SW System heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during the time period requiring the SW System.
- b. For the change associated with the deletion of the p, requirement to verify that the subject unit NSW pumps are b Q OPERABLE when the required CSW pumps are inoperable, the remaining OPERABLE NSW pumps are adequate to perform the heat removal function since, in this condition, three NSW pumps would be OPERABLE with at least one NSW pump l associated with the subject unit (due to the requirements of the LCO and the SW design). However, overall reliability is reduced since a single failure may result in the loss of cooling capability to required components. The 72 hour l Completion Time is based on the remaining SW System heat l removal capability, a reasonable time for repairs, and the low probability of an event occurring during the time period requiring the SW System.
- c. For the change associated with the deletion of the ,
requirements to verify at least one subject unit NSW pump is ) OPERABLE and verify that the one OPERABLE CSW pump and one l OPERABLE subject unit NSW pump are powered from separate emergency buses when one required NSW pump and one required CSW pump are inoperable, the remaining OPERABLE SW pumps are adequate to perform the heat removal function (even if one OPERABLE CSW pump and one OPERABLE subjact unit NSW pump are powered from the same emergency bus or the two remaining OPERABLE NSW pumps are opposite unit pumps). However, overall reliability is reduced since a single failure of an emergency bus may result in the loss of cooling capability O V to required components. The 72 hour Completion Time is based on the remaining SW System heat removal capability, a reasonable time for repairs, and the low probability of an BNP UNITS 1 & 2 8 Revision 0
)
DISCUSSION OF CHANGES' ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (UHS) TECHNICAL CHANGES - LESS RESTRICTIVE L.1 event occurring during the time period requiring the SW (cont'd) System.
- d. For the change associated with allowing continued operation for 72 hours in the event one required NSW pump and two required CSW pumps are inoperable provided two subject unit NSW pumps are OPERABLE, the remaining OPERABLE SW pumps are adequate to perform the heat removal function. However,-
overall reliability is reduced since a single failure will result.in the loss of cooling capability to required components. The 72. hour Completion Time is based on-the remaining SW System heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during the time period requiring the SW System. In each of the above conditions the remaining OPERABLE pumps in the SW System are capable of providing adequate cooling to the DGs, the ECCS and RHRSW loads. However, overall SW System reliability is reduced because a worst case single active component failure will result in the SW System not being able to perform its intended safety function. The 72 hour allowed outage L time is derived from a reliability study (Memorandum from R. L. Baer (NRC) to V. Stello, Jr. (NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1,1975) that evaluated the 8 O' impact on the ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability.of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times. Based on this reliability study, allowed outage times.of 72 hours were assigned to :onditions where the capability in the remaining OPERABLE components of a system was sufficient to mitigate accidents and transients as assumed in the safety analyses if no single failure was assumed (i.e., the OPERABLE components provided 100% capability). The proposed allowed outage times associated with ITS 3.7.2 Required Actions D.1, E.1, F.1, F.2, G.2.1, and G.2.2 and the capability of the SW System to perform its intended safety function, in the associated conditions, are consistent with Technical Specification allowed outage tin,es and capabilities of other safety related systems with similar levels of degradation. Furthermore, since adequate SW cooling is available to the ECCS and RHRSW loads and the DGs for all of the above described conditions, this change also provides the benefit of avoiding the transient risk associated with an unnecessary plant shutdown. ; Therefore, the proposed changes to the SW System allowed outage l times are acceptable. l L.2- . The phrase " actual or," in reference to the actuation test signal i
<[] in CTS 4.7.1.2.b,'is added to ITS SR 3.7.2.5 which verifies that ,
V - .the SW System automatic components' actuate on an initiation' : signal. This allows satisfactory automatic SW System actuations ! BNP. UNITS 1 & 2. 9~ Revision 0
DISCUSSION OF CHANGES ITS: 3.7.2 - SERVICE WATER (SW) SYSTEM AND ULTIMATE HEAT SINK (VHS) TECHNICAL CHANGES - LESS RESTRICTIVE L.2 for other than Surveillance purposes to be.used to fulfill the (cont'd) Surveillance Requirement. OPERABILITY is adequately demonstrated in either case since the SW System components cannot discriminate between " actual" or " test" signals. L.3 The requirement that the testing of CTS 4.7.1.2.b (ITS SR 3.7.2.5) be performed "during shutdown" is to be removed from the Technical Specifications in accordance with the guidance of Generic Letter 91-04. This requirement is a prerequisite for performance of a Surveillance and is not necessary for ensuring the requirements of ITS SR 3.7.2.5 (CTS 4.7.1.2.b) are satisfied. ITS SR 3.7.2.5 might be able to be performed while operating without jeopardizing safe plant operations. The control of plant g conditions appropriate to perform the test is an issue for procedures and scheduling and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, allowing this control is consistent with the vast majority of other Technical Specification Surveillance that do not dictate plant conditions for the Surveillance. RELOCATED SPECIFICATIONS None I O BNP UNITS 1 & 2 10 ' Revision 0
Cf5/ibc5
' Insert 3.7.2-1 (continued) (det/ dh C. One required C.1 Verify the one Immediately conventional-service OPERA 8LE CSW pump and water (CSW) pump ' one OPERABLE Unit inoperable. NSW pump are powered from separate 4.16 kV emergency buses.
8!E I.ll L C.2 Restore required CSW 7_ days g g/ _ pump to OPERABLE status. AND g A.2-14 days from discovery of failure to meet LCO D. Required Action C.1 D.) Restore required CSW 72 hours 7,g,.3 and at-ociated pump to OPERABLE Completion Time not status. g Ogg/ u, s.2 Met-L.s (continued) 10 _--._ _ _ _ m.__ _ _
i C.T5[00c.5 6 i r Insert 3.7.2-1 (continued) , 1 E. Two required CSW pumps inoperable. E.1 -------NOTE------ b i Enter applicable Conditions and Required Actions of W Z' LC0 3.7.1, " Residual l paga2/ Heat Removal Service Water (RHRSW) AS,M'3/ g'i System," for RHRSW subsystems made inoperable by CSW. Restore one required CSW pump to OPERABLE 72 hours g status. AND 14 days from discovery of failure to meet LCO l b-F. One required NSW pump inoperable. F.1 Restore required NSW pump to OPERABLE 72 hours h status. AND ! l 98 One required CSW pump inoperable. F.2 Restore required CSW 72 hours pump to OPERABLE status. (continued) O am-__mmm__ . . _ _ _ _ - - _ _ _ . _ _ . _ _
I cas/mes Insert 3.7.2-1 (continued) 1 O G. One required NSW pump G.1 ~Verifi by Immediately inoperable. administrative means i that two Unit NSW b A_NQ pumps are OPE B EQgJ 2*^'Y) Two required CSW pumps AND inoperable. G.2.1 Restore required NSW 72 hours g pump to OPERABLE f
/l status.
i 98 G.2.2 Restore one required CSW pump to OPERABLE 72 hours h status. H. Water temperature of the UHS is > 89'F and H.1 Verify water temperature of the Once per hour h I i s 02*F. UHS is s 89'F l averaged over O /Al previous 24 hour period. (continued) i h-_e---.._-- . _ _ _ _ _ _ _ - _ _ _ .____m _ m -
[
- se.
TYa e ves eaum e-p
&T%d cad.:r
; oJ,t c . @SW) System and (UHSF
=
j .3aQ 3.7.2 k $n d"*S' ACTIONS- (continued) l CONDITION REQUIRED ACTION COMPLETION TIME Required Action and associated Completion g,1) 8e in MODE 3. 12 hours ] 1 I l TimeofConditiong (p
],7.1% * *
- l Ab[ (] ):
N tems; b
@ @ble
'nopera reasons other than .
F ,c ,b, E, f
~
g,
. b
/M.)@) y '
(UNSpinoperablefor s. reasons other than l A J Condition T. o rs - O SURVEILtJUICE REQUIREMENTS SURVEILLANCE FREQUENCY h 3.7 . Verify t ater level of each 24 hou cooli ower basin is 2 [
~
-- m w _:
/Al h 3.7.2.h V fythewaterlevel(in SW pump 24 hours T'
of the intake structure is y 2"'@*(mean sea levely.gg.; - Ml 2 water temperature of 24 hours yh 3.7.g. Verify the aunStiss . g . x
. e (continued) j J
17./0 '7:"
- 3.7-5 u*r 1. 00/07/;:-
A V
. ~ . , -
R l JUSTIFICATION FOR DEVIATION FROM NUREG-1433, REVISION 1 I l SECTION 3.7 - PLANT SYSTEMS 1 lO
- 1. The Completion Time associated with NUREG-1433 Specification 3.7.1 Required Action A.1 is changed from 30 days to 14 days. The 30 day l Completion Time to restore onc inoperable RHRSW pump to OPERABLE status in NUREG-1433 Specification 3.7.1 is based on cross tie capabili+.y of the RHRSW subsystems. The BNP RHRSW System design does not include a ,
cross tie line between the two RHRSW subsystems downstream of the RHRSW ( pumps. Therefore, a risk based analysis was performed to determine an l ! appropriate allowable out of service time for one inoperable RHRSW pump. ! Based on the results this study, it has been concluded that 14 days is l an acceptable allowable out of service time for one inoperable RHRSW j pump. Also, NUREG-1433 Specification 3.7.1 Condition B is not included in the BNP ITS consistent with the current BNP licensing basis. In addition, a Note is added to BNP ITS 3.7.1 Required Action A.1 and Note 2 is added to BNP ITS 3.7.1 Required Action B.1, which state that l LC0 3.0.4 is not applicable consistent with current BNP licensing basis. The following requirements are renumbered or revised, where applicable, to reflect these changes.
- 2. The proper LC0 number is referenced.
- 3. The change to NUREG-1433 Specification 3.7.1 Required Action C.1 Completion Time (BNP ITS 3.7.1 Required Action 8.1) is made to be l I
consistent with the ITS Writer's Guide.
- 4. The brackets in NUREG-1433 Section 3.7 are removed and the proper plant (o) x specific information/value is provided in BNP ITS Section 3.7.
- 5. NUREG-1433 Specification 3.7.2 LC0 states that two plant service water subsystems shall be OPERABLE. BNP ITS 3.7.2 does not specify subsystems, rather, BNP ITS 3.7.2 LC0 requires the Service Water System to be OPERABLE. This change is made consistent with BNP plant design since BNP's Service Water System is not divided into subsystems.
References to subsystem in BNP ITS SR 3.7.2.3 and SR 3.7.2.5 are revised to reference system consistent with the BNP plant design. Additionally, NUREG-1433 SR 3.7.2.6 (BNP ITS SR 3.7.2.5) is modified to specify functional testing of the required Service Water System automatic components instead of verifying automatic initiation of a subsystem consistent with the current BNP licensing basis.
- 6. NUREG-1433 Specification 3.7.2 Conditions A, B, C, and D are not I included in BNP ITS 3.7.2. BNP ITS 3.7.2 Crnditions A, B, C, D, E, F, l and C are added consistent with BNP current licensing basis as modified "
per Discussion of Change L.1 for ITS 3.7.2. An additional condition I which results in a loss of the required support function is also added I to NUREG-1433 Specification 3.7.2 Condition E (BNP ITS 3.7.2 Condition I) which requires a plant shutdown if two or more required nuclear service water pumps are inoperable. This change is also b l l consistent with BNP current licensing basis. The following requirements are renumbered or revised, where applicable, to reflect these changes. p i ( BNP UNITS 1 & 2 1 Revision 0 i
JUSTIFICATION FOR DEVIATION FROM NUREG-1433, REVISION 1
-SECTION 3.7 - PLANT SYSTEMS I
D 7. Condition H is added to NUREG-1433 Specification 3.7.2 (BNP ITS 3.7.2), consistent with plant specific analyses, to allow water temperature of - b the ultimate heat sink (UHS) to exceed 89'F provided UHS temperature does not exceed a peak temperature of 92*F and UHS temperature averaged over a 24 hour period is maintained s 89'F. With water temperature of the UHS > 89'F and 5 92*F, the BNP design basis assumption associated with initial UHS temperature is bounded provided the temperature of the UHS averaged over the previous 24 hour period is s 89'F. With the water temperature of the UHS > 89'F, long term cooling capability of the ECCS loads and DGs may, be affected. . Therefore, to ensure long term cooling capability is provided to the ECCS loads when water temperature of the UHS is > 89'F, BNP ITS 3.7.2 Required Action H.1 is provided to more frequently monitor the water temperature of the UHS and verify the h temperature is s 89'F when averaged over the previous 24 hour period.
- 8. This bracketed requirement in NUREG-1433 Section 3.7 and associated information or information that references the bracketed information is deleted because the requirements are not applicable to BNP. The following requirements are renumbered or revised, where applicable, to reflect this deletion.
- 9. BNP ITS SR 3.7.2.4 is added to require verification that the automatic transfer of each DG cooling water supply is functional every 92 days.
This test is added consistent with BNP current licensing basis as required by BNP Technical Specification Amendments 164 (Unit 1) and 195 (Unit 2).
- 10. NUREG-1433 Specification 3.7.3 is not included in the BNP ITS since BNP does not have a separate system for DG cooling. DG cooling is provided by the Service Water System and BNP ITS 3.7.2 contains the requirements for the Service Water System. The following requirements are renumbered to reflect this change.
- 11. Not used.
b O BNP UNITS 1 & 2 2 Revision 0
O RHR$W System 8 3.7.1 SASES (continued) APPLICABLE The RHRSW System removes heat from the suppression pool to SAFETY ANALYSES limit the suppression pool temperature and primary containment pressure following a LOCA. This ensures that the primary containment can perform its function of limiting - the release of radioactive materials to the environment following a LOCA. .The ability of the RHR$W System to
, support long tem cooli of D s. reactor or primary M inment 1 snact
^ ers Itj#15]T (& hee Q 2 ana yns explicit y
, assume that the RHRSW System will provide adequate cooling support to the equipment required for safe shutdown. These analyses include the evaluation of the long tem primary containment response after a design basis LOCA.
The safety analyses for long tem cooling were performed for various combinations of RHR System failures. The worst case A si le failure that would affect the perfomance of the - System is any a ure that would disable one subsystem of the IHtSW Sys+=. Owsn I5,r:1. add (Ref. iscussed in the % S 1/h for these analyses, manual ' W alt <atton of the OPERA 8LE subsystem and the associated Itit System is assumed to occur 110}eminute a 084. The RHR$W flow assumed in the analyses is r i h 4 amaLgt3 two pumpsioperating in one loop. In this -.ppe I 2 case, tte maximum suppression chamt!Pr water temperature and iA pressure are ORKJh*F and #36A9Fyng, respectively, well gl4,0 l/_rh below the des'Fgn taiperature of 'F and imum allowable pressu see.f f(62 psig - --
/
pg,j y 4 The intSW System sf es Criterion 3 o PoM@' Ctrocel., LC0 <& wo IHtSW subsystems are required to be OPERA 8LE to provide A the required redundancy to ensure that the system functions to remove post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power. An RHRSW subsystem is considered OPERA 8LE when: I
- a. Two pumps are OPERABLE; and (continued)
OWR /A * 8 3.7-2 Rev-4, ^'/07/ W 4 0 . l
Insert B 3.7.2-6 o ed V - The normal cooling water supply for two DGs and the alternate cooling water
-supply for two DGs are provided by the opposite unit NSW pumps via the-associated NSW header. Therefore, this Required Action provides a,14 day period to_ perform maintenance on the opposite unit NSW header and associated NSW pumps. This is acceptable because performing maintenance on the- opposite unit NSW header and NSW pumps will increase the reliability of the DGs cooling water supply. However, if this condition results in two required site NSW pumps being incapable of providing cooling water to the DGs, Condition I is entered.
The 14 day Completion Time takes-into account the capacity and capability of the remaining NSW pumps to supply cooling to all four DGs and a reasonable time for performance of maintenance. t(Z) l The Note to Condition A only allows the 14 day Completion Time to apply when the opposite unit is in MODE 4 or 5. When a required NSW pump becomes inoperable or incapable of providing cooling water to the DGs while Unit is in N0DE 1, 2, or 3, Condition B or I of Uni entered, as applicable, and the associated specification 3.7.2 must be ired Action (s) performed. g-tw z-Q Pursuant to LCO 3.0.6, the AC Sources-Operating ACTIONS would not be entered even if cooling capability were lost to the DGs, resulting in one or more inoperable DGs. Therefore, Required Action A.1 is modified by a Note to indicate that when Condition A is entered and NSW cooling capability is O unavailable to one or more DGs, ACTIONS for LCO 3.8.1, "AC Sources-Operating," must be immediately entered. This allows Condition A to provide requirements for an inoperable NSW pump without regard to whether a cooling water supply is available to the DGs. LCO 3.8.1 provides the appropriate restrictions for one or more inoperable DGs. l I l l l O
)
i Insert B 3.7.2-7 (continued)
) The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required NSW and CSW pumps to be inoperable during any single contiguous occurrence of failing to meet the LCO.
If Condition C is entered while, for instance, a required NSW pump is inoperable, and that NSW pump is subsequently returned OPERABLE, the LC0 may already have been not met for up to 7 days. This situation could lead to a total of 14 days, since initial failure to meet the LCO, to restore the CSW pump. At this time, a required NSW pump could again become inoperable, the CSW pucp restored OPERABLE, and an additional 7 days (for a total of 21 days) allowed prior to complete restoration of the LCO. The 14 day Completion Tiine provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions B and C are entered concurrently. The "AND" connector between the 7 day and the 14 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. The second Completion Time allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." This exception results in establishing the " time zero" at the 4 ime LCO 3.7.2 was initially not met, instead of at the time that Condition C was entered. g pi " If Required Action C.1 cannot be completed within the associated Completion i Time or if the status of the Unit SW pumps changes after Required Action C.1 bQ is initially met, one required CSW pump must be restored to OPERABLE status within 72 hours. With the unit in this condition, the OPERABLE SW pumps are , adequate to perform the heat removal function. However, overall reliability is reduced as compared to Condition C and a reduced Completion Time of 72 hours is provided. The 72 hour Completion Time is based on the remaining SW System heat removal capability, a reasonable time for repairs, and the low b probability of an event occurring during the time period requiring the SW System. Ll With two required CSW pumps inoperable, the one required inoperable pump must be restored to OPERABLE status within 72 hours and 14 days from discovery of failure to meet the LCO. With the unit in this condition, the OPERABLE NSW pumps are adequate to perform the heat removal function. The 72 hour Completion Time is based on the availability of the remaining NSW pumps to n support the unit's service water loads. The 72 hour Completion Time is based D on the remaining SW System heat removal capability, a reasonable time for repairs, and the low probability of an event occurring during this time period g requiring the SW System. The second Completion Time for Required Action E.1 establishes a limit on the l maximum time allowed for any combination of required NSW and CSW pumps to be . l inoperable during any single contiguous occurrence of failing to meet the LCO. g If Condition E is entered while, for instance, a required NSW pump is 3 inoperable, and that NSW pump is subsequently returned OPERABLE, the LC0 may h l l
E 1 l l Insert 8 3.7.2-7 (continued)
@ 4 already have been not met for up to 7 days. This situation could lead to a total of 14 days, since initial failure to meet the LCO, to restore the CSW pump. At this time, a required NSW pump could again become inoperable, the CSW pump restored OPERABLE, and an additional 7 days (for a total of 21 days) g )
j allowed prior to complete restoration of the LCO. The 14 day Completion Time i provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for i situations in which Conditions B and E are entered concurrently. The "AND" connector between the 7 day and the 14 day Completion Times means that both h Completion Times apply simultaneously, and the more restrictive Completion Time must be met. The second Completion Time allows for an exception to the . normal " time zero" for beginning the allowed outage time " clock." 1 This exception results in establishing the " time zero" at the time LC0 3.7.2 l was initially not met, instead of at the time that Condition E was entered. h Pursuant to LCO 3.0.6, the RHRSW ACTIONS would not be entered even if cooling A-capability were lost to the RHRSW heat exchangers, resulting in one or more E inoperable RHRSW subsystems. Therefore, Required Action E.1 is modified by a g~ Note to indicate that when Condition E is entered and cooling capability is unavailable to one or more RHRSW subsystems, ACTIONS for LC0 3.7.1, " Residual Heat Removal Service Water (RHRSW) System," must be immediately entered. This g allows Condition E to provide requirements for one or more required inoperable CSW pumps without regard to whether a cooling water supply is available to the h RHRSW heat exchangers. LC0 3.7.1 provides the appropriate restrictions for one or more inoperable RHRSW subsystems. b F.1 and F.2 h If one required CSW pump and one required NSW pump are concurrently ino)erable, one of the inoperable pumps must be restored to OPERABLE status wit 11n 72 hours. With the unit in this condition, the OPERABLE SW pumps are adequate to perform the heat removal function. The 72 hour Completion Time is g based on the remaining SW System heat removal capability, a reasonable time d for repairs, and the low probability of an event occurring during this time i period requiring the SW System. I G.I. G.2.1 and G.2.2 h l If two required CSW pumps are inoperable concurrent with one required NSW pump andbothUnit(1]NSWpumpsareverifiedOPERABLE,oneoftherequiredCSWpumps Faust be restored to OPERABLE status within 72 hours or the required NSW pump must be returned to OPERABLE status within 72 hours. Since loss of the two required CSW pumps and one required NSW pump could result in a loss of cooling capa ity to the vital and RHRSW headers, immediate verification that two g SW pumps are OPERABLE is required to ensure cooling capability to the ital and RHRSW headers is maintained. This may be performed as an administrative check by examining logs or other information to determine if q one or both Uni t do es
$ SW pumpstoare out ofthe service for maintenance needed to or other Q reasons. not mean perform Surveillance demonstrate 7 p 2.h
.d'
Insert'B 3.7.2-7 (continued) /h the OPERABILITY of the NSW pumps. However, if the OPERABILITY of both Unit I l' NSW pumps cannot be verified, cooling capability to the ECCS loads cannot be /A assured. As such, Condition I must be immediately entered. With two re ire E CSW pumps inoperable concurrent with one required NSW pump and both Unit 1 SW pumps are OPERABLE, adequate heat removal capability is ensured by the OPERABILITY of the NSW subsystem and remaining OPERABLE NSW pumps. However, the overall. SW System reliability is significantly reduced because of the.. reduction in SW pump. redundancy and operational diversity such that the SW System may not be able to perform its required support function. Therefore, a more restrictive Completion Time of 72 hours is required to restore at least one required CSW pump or the required NSW pump to OPERABLE status. L1 $ l With water temperature of the UHS > 89'F and s 92*F, the design basis
. assumption associated with initial UHS temperature are bounded provided the temperature of the UHS averaged over the previous 24 hour period is s 89'F.
With the water temperature of the UHS > 89'F, long term cooling capability of the ECCS loads and DGs may be affected. Therefore, to ensure long term cooling capability is provided to the ECCS loads when water temperature of the UHS is > 89'F, Required Action H.1 is provided to more frequently monitor the
. water. temperature of the UHS and verify the temperature is s 89'F when averaged over the previous 24 hour period. The once per hour Completion Time takes into consideration UHS temperature variations and the increased O monitoring frequency needed to ensure design basis assumptions are not exceeded in this condition. .If the water temperature of the UHS exceeds 89'F when averaged over the previous 24 hour period or the water temperature of the UHS exceeds 92*F, Condition I must be entered immediately.
i O i
A Q ,
$WFSystemandfUHSk B 3.7.2 BASES ACTIONS [J t tinued)
,the time require o reasonably comply the Required '
,4 Action. ,/ -
Y .__ With one [PSW) uhsystem inoperable fo reasons other than Condition A and [Copdition C) (e.g., in rable flow pathor
, the [P both pumps inoperabit instatus be restored to OPERAB a loop)ithin w 72 ho[b s. subsystem With the must s
N nit in this condition he remaining OPERAB SW)
. subsystem is adequate to rform the heat remo function.
e overall rell liity is reduced bec HoweverM'the failure in OPERABLE [PSW} subsystem could u t in loss res(e a single of [PSW) functi n. he 72 hour Complet on Time is ba d on the reduhdant SW) Sy em capabilities forded by th x0PERABLE subsystem, e 1 robability of an ccident occurk ng during this time pari and is consiste with the al' Completion Time for res e g an inopera e DG. Required Ac on D.1 is modi ted by two Not indicating that he applicabi Conditions of C0 3.8.1, "AC urces-rating,' LC .4.8, "Resid 1 Heat Removal R) Shutdown Coo ng System- t Shutdown," e entered and R u' red l Actio taken if e inoperable PSW1 subsystem r uits in an inop rable DG or shutdown oo' ing subsystem, respecti tly. This in accorda e with LCO 3.0.6 d sures thKproper ac ons are take for these compone ts. b nnd 2 Q4 Mw) g & &
?N If @QEarr subsyste4 cannot e6estocan toJERA8LE status) p4vh er r^84 IS within th clated Completion Ti * '
W SWF ' 4 j(anaystemeEnen noper b1 or reason other thahCondit'o , yW IJ 50 Anna 1t4ea c]) 4 r e (UHS) i N4_i operab e Tor reasons oTner than Conditio he unit must . placed
~
p g o,c i n a MODE in which the LEO does no
~
pply. To achieve tnts i^ f*8M8$ b status, the unit must be placed in a east MODE 3 within
, 12 hours and in M00E 4 within 36 hours. The allowed Completion Times are reasonable, based on operating e
[e_.$.# L- , experience, to reach the required unit conditions from full h f (continued) M/4 5i5 ^ B 3.7-10 of G4; L. :, c'/07/95
- 1. D '\ tl l A,8, b, E,f G A,6, c, ()'f, f*,*artl 9 '.. *
- Q4AM,a4N re%) J,% +4e-
.kW
.J b
yassuk sp+e6 Co~f l eb M ! t
QSWySystemandfUHS5 8 3.7.2 h - i BASES l ACTIONS .2 (continued) - power conditions in an orderly manner and without ' challenging unit systems.
~
SURVEILLANCE REQUIREMENTS SR 3. s SR ensures adequate ng ters (30 days) cool can be h maintained. With th ] water source below a minimum
/ level, the affect 'PSW) subsystem must be clared
{ inoperable. T 4 hour Frequency is bas on operating - experience ated to trending of the par ter variations / during the pplicable MODES.
/ ~
/_ )
3 SR 3.7.2 4 ppp.g This SR verifies the water level. fin M oumMf the f intake structuret to be sufficient for the proper operation yq of the QSW) vortexing arepumps (net positive considered suctionthis in detemining head and The limit). pumOp, O 24hourFrequencyisbasedonoperatingexperiencerelated)! to trending of th's parameter variations during the applicable MODES. y
~
SR 3.7.2. ..
- 4. m Verification of the(UNS), temperature ensures that the heat g removalcapabilityofthe$SWFSystemiswithinthe assumptions of the 08A ana.ysis. The 24 hour Frequency is 24 based on operating experience related to trending of the
_ parameter variations during the applicable MODES.
)
N SSR mAy b / aco plish) h f_1 3724
]
[ Af*5"D I^ erating each ling tower fan f 2 15 minutes ens s h l m kr/cel .
/ at all fa are OPERABLE and t t all associated trols are funct ing properly. It so ensures that f or motorf ure, or excessive ration, can be de ted for
. .-W P,,gge) m4er lesej 4e b de,;.h co ive action. The day Frequency is b on gI^M g g .o ating experience, a known reliability the fan y nits, the redundan available, and the probability of k
l. dwe.fdFP 4M dbW gaek bas 7 (continued) ps.it. d aa. + a;g)
$cee.en$ 8 3.7-11 - Pr I, e'/07/Or
% q/0 :T F j l
4 3-
AC S:urces-Operating 3.8.1 3.8. ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:
- a. Two Unit 1 qualified circuits between the offsite transmission network and the onsite Class IE AC Electrical Power Distribution System;
- b. Four diesel generators (DGs); and
- c. Two Unit 2 qualified circuits between the offsite transmission network and the onsite Class IE AC Electrical Power Distribution System.
APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME O A. ---------NOTE--------- A.1 Restore Unit 2 45 days Only applicable when offsite circuit to Unit 2 is in MODE 4 OPERABLE status, or 5. One Unit 2 offsite circuit inoperable. l B. One offsite circuit B.1 Perform SR 3.8.1.1 2 hours i b inoperable for reasons for OPERABLE offsite other than circuit (s). AND Condition A. g 12 hours thereafter 9.Q (continued) vO.. ,
- Brunswick Unit 1 3.8-1 Amendment No.
I s !
1 AC Scurces-0perating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Declare required 24 hours from discovery of no b feature (s) with no offsite power offsite power to available inoperable one 4.16 kV when the redundant emergency bus required feature (s) concurrent with are inoperable. inoperability of redundant required feature (s)
.AM B.3 Restore offsite circuit to OPERABLE 72 hours b status. AND 10 days from discovery of failure to meet LC0 3.8.1.a or b C. One DG inoperable. C.1 Perform SR 3.8.1.1 for OPERABLE offsite 2 hours 6 circuit (s). AND Once per 12 hours thereafter AND C.2 Declare required 4 hours from 'b ;
feature (s), supported discovery of i by the inoperable DG, Condition C b, inoperable when the concurrent with redundant required inoperability of feature (s) are redundant inoperable. required feature (s) AND (continued) Brunswick Unit 1 3.8-2 Amendment No.
AC Sources-Operating 3.8.1 l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l C. (continued) C.3.1 Determine OPERABLE 24 hours b DG(s) are not inoperable due to common cause failure. l 93 C.3.2 Perform SR 3.8.1.2 24 hours b for OPERABLE DG(s). 6NQ C.4 Restore DG to 7 days OPERABLE status. AND 10 days from discovery of failure to meet LC0 3.8.1.a or b
- N
')
D. Two or more offsite circuits inoperable, D.1 Declare required feature (s) inoperable 12 hours from discovery of h when the redundant required feature (s) Condition D concurrent with k are inoperable. inoperability of redundant required feature (s) AND D.2 Restore all but one offsite circuit to 24 hours g OPERABLE status. I (continued) ll \ v Brunswick Unit 1 3.8-3 Amendment No. I
AC Scurces-Operating 3.8.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME E. One offsite circuit ------------NOTE------------- A inoperable. Enter applicable Conditions OE and Required Actions of. MQ LCO 3.8.7, " Distribution Systems-Operating," when One DG inoperable. Condition E is entered with no AC power source to any g 4.16 kV emergency bus. E.1 Restore offsite circuit to OPERABLE 12 hours b status. 9.8 E.2 Restore DG to OPERABLE status. 12 hours b F. Two or more DGs F.1 Restore all but one 2 hours b inoperable. DG to OPERABLE status. G. Required Action and G.1 Be in MODE 3. 12 hours associated Completion . Time of Condition A, AND B, C, D, E, or F not met. G.2 Be in MODE 4. 36 hours (continued) I f\ ,
.h l Brunswick Unit 1 3.8 Amendment No.
i AC Sources-Operating 3.8.1 ACTIONS -(continued) CONDITION REQUIRED ACTION COMPLETION TIME I H. 'One or more offsite circuits and two or H.1 Enter LCO 3~0.3.
. Immediately b more DGs inoperable.
9.8
.Two or more offsite circuits and one DG inoperable. g SURVEILLANCE REQUIREMENTS g SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each offsite circuit.
(continued) O ; Brunswick Unit 1 3.8-5 Amendment No.
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.2 -------------------NOTES-------------------
- 1. All DG starts may be preceded by an engine prelube period. g
- 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.
- 3. A single test at the specified I Frequency will satisfy this ,
. . . . . . I. !$ ".$..$..$..$."..'*..........
l l Verify each DG starts from standby 31 days conditions and achieves steady state ) voltage 2 3750 V and s 4300 V and frequency i a 58.8 Hz and s 61.2 Hz. (continued) l 1 i l l O Brunswick Unit 1 3.8-6 Amendment No. l~ L l
l AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------NOTES-------------------
- 1. DG loadings may include gradual loading.
- 2. Momentary transients outside the load range do not invalidate this test.
- 3. This Surveillance shall be conducted on only one DG at a time.
- 4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
- 5. A single test at the specified Frequency will satisfy this Surveillance for both units. l Verify each DG is synchronized and loaded 31 days I and operates for a 60 minutes at a load 2 2800 kW and :s; 3500 kW.
i SR 3.8.1.4 Verify each engine mounted tank contains 31 days a 150 gal of fuel oil. SR 3.8.1.5 Check for and remove accumulated water from 31 days , each engine mounted tank. I SR 3.8.1.6 Verify the fuel oil transfer system operates to transfer fuel oil from the day 31 days 8 i fuel oil storage tank to the engine mounted tank. (continued) O . Brunswick Unit 1 3.8-7 Amendment No.
l AC Sources-Operating j 3.8.1 i l l SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.7 -------------------NOTES-------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG starts from standby 184 days condition and achieves, in s 10 seconds, voltage a 3750 V and frequency a 58.8 Hz, and after steady state conditions are reached, maintains voltage 2 3750 V and s 4300 V and frequency a 58.8 Hz and s 61.2 Hz. i l 1 (continued) O l l l l l O Brunswick Unit 1 3.8-8 Amendment No.
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.8 -------------------NOTES-------------------
- 1. SR 3.8.1.8.a shall not be performed in MODE 1 or 2 for the Unit 1 offsite b
circuits. However, credit may be taken for unplanned events that d satisfy this SR.
- 2. SR 3.8.1.8.a is not required to be met if the unit power supply is from the preferred offsite circuit.
l
- 3. A single test at the specified Frequency will satisfy this Surveillance for both units.
d> ! I Verify: 24 months
- a. Automatic transfer capability of the unit power supply from the normal circuit to the preferred offsite circuit; and ;
- b. Manual transfer of the unit power ;
supply from the preferred offsite 4 circuit to the alternate offsite circuit. (continued) l 4 Brunswick Unit 1 3.8-9 Amendment No.
I i 1 AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.9 -------------------NOTES-------------------
- 1. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 1 and DG 2. However, credit may be iA taken for unplanned events that 15 satisfy this SR.
- 2. If performed with the DG synchronized with offsite power, it shall be performed at a power factor s 0.9.
- 3. A single test at the specified frequency will satisfy this Surveillance fo'r both units.
Verify each DG rejects a load greater than 24 months or equal to its associated core spray pump without tripping. (continued) l l l l~ LO Brunswick Unit 1 3.8-10 Amendment No. 1
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.10 -----------
-------NOTE--------------------
A single test at the specified Frequency g will satisfy this Surveillance for both units. 1 ........................................... Verify each DG's automatic trips are 24 months bypassed on an actual or simulated ECCS initiation signal except: i
- a. Engine overspeed;
- b. Generator differential overcurrent;
- c. Low lube oil pressure;
- d. Reverse power;
- e. Loss of field; and g f. Phase overcurrent (voltage restrained),
i (continued) 1 1 l l l l l O U Brunswick Unit 1 3.8-11 Amendment No.
i AC Scurces-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.11 -------------------NOTES-------------------
- 1. Momentary transients outside the load and power factor ranges do not invalidate this test.
- 2. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG operating at a power factor 24 months s 0.9 operates for a 60 minutes loaded to a 3500 kW and s 3850 kW. SR 3.8.1.12 -------------------NOTE-------------------- A single test at the specified Frequency will satisfy this Surveillance for both units. Verify an actual or simulated ECCS 24 months initiation signal is capable of overriding the test mode feature to return each DG to ready-to-load operation. (continued) I '. Brunswick Unit l' 3.8-12 Amendment No. l
)
AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.13 -------------------NOTE-------------------- This Surveillance shall not be performed in MODE 1, 2, or 3 for the load sequence r relays associated with DG 1 and DG 2. 4 However, credit may be taken for unplanned events that satisfy this SR. Verify interval between each sequenced load 24 months block is within i 10% of design interval , for each load sequence relay. (continueo) 1 l l I O Brunswick Unit 1 3.8-13 Amendment No. l
)
AC Sources-0perating 3.8.1 l l SURVEILLANCE REQUIREMENTS (continued) ['^') SURVEILLANCE FREQUENCY SR 3.8.1.14 -------------------NOTES-------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 1 h, '
and DG 2. However, credit may be gi taken for unplanned events that satisfy this SR. l
...................__.___________ ...... .. l Verify, on actual or simulated loss of 24 months offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
,- c. DG auto-starts from standby condition
( and: s
- 1. energizes permanently connected loads in s 10.5 seconds,
- 2. energizes auto-connected emergency loads through load sequence relays,
- 3. maintains steady state voltage 2 3750 V and s 4300 V,
- 4. maintains steady state frequency a 58.8 Hz and s 61.2 Hz, and
- 5. supplies permanently connected and auto-connected emergency loads for 2 5 minutes.
b
~
l l l
,a 4
[ Brunswick Unit 1 3.8-14 Amendment No.
AC Sources-Shutdown 3.8.2
~
3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown I LC0 3.8.2 The following AC electrical power sources shall be OPERABLE:
- a. One Unit 1 qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem (s) required by LCO 3.8.8, " Distribution Systems-Shutdown";
- b. Two diesel generato*s (DGs) capable of supplying onsite Class 1E AC electrical power distribution subsystem (s) b required by LC0 3.8.8; and
- c. One Unit 2 qualified circuit between the offsite transmission network and the onsite Class IE AC .
electrical power distribution subsystem (s) needed to I support the Unit 2 equipment required to be OPERABLE by . LC0 3.7.3, " Control Room Emergency Ventilation (CREV) System," LCO 3.7.4, " Control Room Air Conditioning (AC) System," and LC0 3.8.5, "DC Sources-Shutdown." O APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment. 1 Brunswick Unit 1 3.8-15 Amendment No. l
AC Scurces-Shutdown 3.8.2 ACTIONS
- - ~------------------------------------NOTE-------------------------------------
LCO -3.0.3 is not applicable. CONDITION REQUIRED ACTION -COMPLETION TIME A. One or more required ------------NOTE------------- Enter applicable Condition
-offsite circuits
. inoperable, and Required Actions of LCO 3.8.8, with one or more required 4.16 kV emergency buses de-energized as a result of Condition A.
1 ............................. A.1 Declare affected Immediately l required feature (s), with no offsite power available, inoperable. 98 A.2.1 Suspend CORE Immediately ALTERATIONS. 1 S i i A.2.2 Suspend movement of Immediately ) irradiated fuel assemblies in the secondary I containment. AND A.2.3 Initiate action to Immediately suspend operations with a potential for i draining the reactor i vessel (0PDRVs). M
.(continued) ,
O ! Brunswick Unit'l- 3.8-16 Amendment No.. l
AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION CONPLETION TINE A. (continued) A.2.4- Initiate action to Immediately restore required offsite power circuit
.to OPERABLE status.
B. One required DG B.1 Declare affected Immediately inoperable. required feature (s) with no DG available inoperable. DE I B.2.1 Suspend CORE Immediately I ALTERATIONS. 8HE B.2.2- Suspend movement of Immediately irradiated fuel O assemblies in secondary containment. 83Q B.2.3 Initiate action to Immediately suspend OPDRVs. ; i 6ND B.2.4 Initiate action to Immediately restore required DG to OPERABLE status. (continued) ! l O Brunswick Unit 1 3.8-17 Amendment No.
AC Sources-Shutdown 3.8.2 fTIONS.(continued) CONDITION REQUIRED ACTION COMPLETION TIME-C. Two required DGs C.I. Suspend CORE Immediately-inoperable. ALTERATIONS. M C.2 Suspend movement of- Immediately irradiated fuel assemblies in secondary containment. M C.3 Initiate action to Immediately suspend OPDRVs. M C.4 Initiate action to Immediately restore required DGs , to OPERABLE status.
' SURVEILLANCE REQUIREMENTS l
SURVEILLANCE FREQUENCY SR 3.8.2.I' -------------------NOTE-------------------- Unless required to be performed by Unit 2 Specification 3.8.1, the following SRs are b not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.I'.11, SR 3.8.1.13, and SR 3.8.1.14. d For AC sources required to be OPERABLE the In accordance lk ' SRs of Specification 3.8.1, except with applicable SR 3.0.1.8 and SR 3.8.1.12, are applicable. SRs jfy M; Brunswick Unit l= 3.8-18 Amendment No.
1 1 Diesel Fuel Oil 3.8.3 D 3.8 ELECTRICAL POWER SYSTEMS
. \)' 3.8.3 Diesel Fuel Oil LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG).
APPLICABILITY: When associated DG is required to be OPERABLE. ACTIONS
-------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each DG. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required day 48 hours DGs with fuel oil fuel oil storage tank level in the level to within associated day fuel limit. k oil storage tank (s)
< 22,650 gal per
! required DG and 2 17,000 gal per required DG. AND Fuel oil level in the : main fuel oil storage ! tank 2 20,850 gal per required DG. (continued) i Brunswick Unit-1 3.8-19 Amendment No.
Diesel Fuel Oil 3.8.3 4 ()/ ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Restore main fuel oil 48 hours DGs with fuel oil storage tank level to level in the main fuel within limit. oil storage tank
< 20,850 gal per required DG and a 13,900 gal per required DG.
8N_Q Fuel oil level in the required day fuel oil storage tank (s) 2 22,650 gal per required DG. C. One or more DGs with C.1 Restore stored fuel 7 days iO, stored fuel oil total particulate not oil total particulate to within limit, within limit. D. Required Action and D.1 Declare associated DG Immediately ; associated Completion inoperable. l Time Condition A, B, or C not met. 0_8 One or more DGs with diesel fuel oil not within limits for l reasons other than Condition A, B, or C.
' Brunswick Unit 1 3.8-20 Amendment No.
Diesel Fuel Oil 3.8.3 f$g SURVEILLANCE REQUIREMENTS V SURVEILLANCE FREQUENCY SR 3.8.3.1 For each required DG, verify: 31 days I
- a. The associated day fuel oil storage tank contains at 22,650 gal; and
- b. The main fuel oil storage tank ,
contains 2: 20,850 gal per required DG. SR 3.8.3.2 Verify fuel oil properties of stored fuel In accordance oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Oil Fuel Oil Testing Program. Testing Program l 6 3.8.3.3 Check for and remove accumulated water from 31 days each day fuel oil tank and the main fuel oil storage tank. O l l I Brunswick Unit 1 3.8-21 Amendment No. 1
DC Scurces--Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 .DC Sources-Operating LCO 3.8.4 The following DC electrical power subsystems shall be OPERA 8LE:
- a. Unit 1 Division I-and Division-II DC electrical power )
subsystems; and
- b. Unit 2 Division I and Division II DC electrical power i subsystems.
APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l A. One DC electrical A.1 --------NOTE--------- power subsystem Enter applicable , inoperable. Conditions and Required Actions of LCO 3.8.7,
" Distribution Systems--Operating,"
when Condition A results in de- l energization of an i AC electrical power ! distribution ! subsystem or a DC electrical power distribution subsystem. Restore DC electrical 7 days power subsystem to
- OPERABLE status.
(continued) l i
' Brunswick Unit 1: 3.8-22 Amendment No. <
l
DC S:urces-Opsrating 3.8.4 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time of Condition A A_!g! not met. B.2 Be in MODE 4. 36 hours M Two or more DC electrical power subsystems inoperable. SURVEILLANCE REQUIREMENTS gl SURVEILLANCE FREQUENCY O SR 3.8.4.1 Verify battery terminal voltage is a 130 V on float charge. 7 days SR 3.8.4.2 Verify ne visible corrosion at battery 92 days terminals and connectors. M Verify battery connection resistance is s 23.0 pohms for inter-cell connections and a s 82.8 ohms for inter-rack connections. 22 SR 3.8.4.3 Verify battery cells, cell plates, and 18 months l racks show no visual indication of physical damage or abnormal deterioration that degrades performance. (continued) O ! b-Brunswick Unit 1 3.8-23 Amendment No.
DC Sources-0perating 3.8.4 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery 18 months cell to cell and terminal connections are coated with anti-corrosion material. SR 3.8.4.5 Verify each required battery charger 24 months supplies a 250 amps at a 135 V for ! a 4 hours. SR 3.8.4.6 -------------------NOTES-------------------
- 1. The modified performance discharge test in SR 3.8.4.7 may be performed in lieu of the service test in SR 3.8.4.6 once per 60 months.
- 2. This Surveillance shall not be performed in MODE 1 or 2 for the Unit 1 DC electrical power subsystems.
g O However, credit may be taken for unplanned events that satisfy this SR.
- 3. A single test at the specified frequency will satisfy this Surveillance for both units.
g Verify battery capacity is adequate to 24 months supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test. (continued) O Brunswick Unit 1 3.8-24 Amendment No.
DC Scurces-0perating 3.8.4 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY l' SR 3.8.4.7 -------------------NOTES-------------------
- 1. This Surveillance shall not be m
A performed in M00E.1 or 2 for the ' Unit 1 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR. I
- 2. A single test at the specified Frequency will satisfy this Surveillance for both units.
&i Verify battery capacity is a 80% of the 60 months manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.
12 months when battery shows degradation or has reached 85% , of the expected i e life with l capacity l
< 100% of l manufacturer's l rating AND 24 months when l battery has reached 85% of the expected life with capacity 2 100% of manufacturer's rating f
b O Brunswick Unit 1 3.8-25 Amendment No.
I I DC Ssurces-Shutd:wn } 3.8.5 l l O V 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LCO 3.8.5 The following DC electrical power subsystems shall be OPERABLE: L a. The Unit 1 DC electrical power subsystems needed to I support the DC electrical power distribution j subsystem (s) required by LCO 3.8.8, " Distribution Systems-Shutdown;" and
- b. The Unit 2 DC electrical power subsystem needed to l support the DC electrical power distribution subsystem (s) required by LC0 3.8.8, " Distribution Systems-Shutdown. "
APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment. ACTIONS b V -------------------------------------NOTE------------------------------------- LCO 3.0.3 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately l DC electrical power required feature (s) i subsystems inoperable. inoperable. 98 A.2.1 Suspend CORE Immediately ALTERATIONS. AND (continued) e (m) v Brunswick Unit-1 3.8-26 Amendment No.
I, DC Sources-Shutd:wn 3.8.5 ACTIONS CONDITION _ REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment. MQ A.2.3 Initiate action to Immediately l suspend operations with a potential for draining the reactor vessel. MQ A.2.4 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status, i l l I l O ! Brunswick Unit 1 3.8-27 Amendment No. 1
DC Sources-Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 -------------------NOTE-------------------- Unless required to be serformed by Unit 2 Specification 3.8.4, t1e following SRs are d not required to be performed: SR 3.8.4.6 and SR 3.8.4.7. For DC electrical power subsystems required In accordance with applicable b to be OPERABLE the following SRs are applicable: SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, SR 3.8.4.4, SR 3.8.4.5, SR 3.8.4.6, and SR 3.8.4.7. b n V i l 1 l l l l I l Brunswick Unit 1 3.8-28 Amendment No.
L 1 Battery Cell. Parameters l' 3.8.6 l
- l. 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Cell Parameters i
- LCO 3.8.6 Battery cell parameters for the' Unit 1 Division I and II !
batteries and the Unit 2 Division I and II batteries shall be within' the limits of Table 3.8.6-1. ) 8tEl Battery cell average electrolyte temperature for the Unit 1 i Division I and II batteries and the Unit 2 Division I and II batteries shall be within required limits. APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE. ACTIONS
..................................... NOTE-------------------------------------
Separate Condition entry is allowed for each battery. O CONDITION REQUIRED ACTION COMPLETION TIME l A. One or more batteries A.1 Verify pilot cells I hour with one or more electrolyte level and battery cell float voltage meet parameters'not'within Table 3.8.6-1 Category A or B Category C limits. limits. AND l A.2 Verify battery cell 24 hours parameters meet Table 3.8.6-1 AND Category C limits. Once per 7 days thereafter 8!N1 (continued) l 1 Brunswick Unit 1 3.8-29 Amendment No. l
l Battery Cell Parameters 3.8.6 l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B limits of Table 3.8.6-1. B. Required Action and B.1 Declare associated Immediately associated Completion battery inoperable. l Time of Condition A not met. E l One or more batteries with average electrolyte temperature of the ; representative cells not within limits. O , One or more batteriek with one or more battery cell , parameters not within ' Category C limits. ' l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet 7 days Table 3.8.6-1 Category A limits. (continued)
- %0)
Brunswick Unit 1- 3.8-30 Amendment No.
Battery Cell Parameters 3.8.6 ( SURVEILLANCE REQUIREMENTS { continued) SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet 92 days Table 3.8.6-1 Category B limits. SR 3.8.6.3 Verify average electrolyte temperature of 92 days representative cells is a: 60*F. , l 1 O i
-L/
Brunswick Unit 1 3.8-31 Amendment No.
Battery Cell Parameters 3.8.6 Table 3.8.6-1 (page 1 of 1) O Battery Cell Parameter Requirements CATEGORY A: CATEGORY B: CATEGORY C: LIMITS FOR EACH LIMITS FOR EACH LIMITS FOR DESIGNATED PILOT CONNECTED CELL EACH CONNECTED
-PARAMETER CELL CELL Electrolyte > Minimum level > Minimum level Above top of Level indication mark, and indication mark, plates, and not s i inch above and s i inch above overflowing maximum level maximum level indication mark (a) indication mark (a)
Float Voltage a: 2.13 V at 2.13 V 2: 2.07 V Specifig a: 1.200 at1.195 Not more than Gravity (b )(c) 0.020 below ANQ average of all connected cells O Average of all connected cells AND-a 1.205 Average of all connected cells a: 1.195 (a) It is acceptable for the electrolyte level to temporarily increase above ,
- the specified maximum level during and following equalizing charges j provided it is not overflowing.
(b) Corrected for electrolyte temperature and level. However, level correction is not required when on float charge and battery charging current is < 2 amps. (c) A battery charging current of < 2 amps when on float charge is i acceptable for meeting specific gravity limits following a battery l recharge,.for a maximum of 7 days. When charging current is used to satisfy specific gravity requirements, specific gravity of each connected cell shall be measured prior to expiratlon of the 7 day allowance. ' O Brunswick Unit 1 3.8-32 Amendment No.
Distribution Systems-Operating
-3.8.7 .( 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems-Operating f i
l LCO 3.8.7' Division I and Division II AC and DC electrical power distribution subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.1 Restore AC electrical 8 hours electrical power power distribution i distribution subsystems to AND I subsystems inoperable. OPERABLE status. 176 hours from A 3 discovery of D failure to meet LC0 j (continued) l l l O 3.8-33 Brunswick Unit 1 Amendment No. l
Distribution Systers-Operating 3.8.7 ACTIONS (continued) f] CONDITION REQUIRED ACTION COMPLETION TIME B. One or more DC electrical power B.1 Declare required feature (s), supported Immediately d distribution by the inoperable DC subsystems inoperable electrical power due to loss of normal distribution DC source. subsystem, inoperable. AND d B.2 Initiate action to transfer DC Immediately 8 electrical power distribution subsystem to its alternate DC source. AND h B.3 Declare required Upon completion feature (s) supported of transfer of O by the inoperable DC electrical power distribution the required feature's DC electrical power l subsystem OPERABLE. distribution subsystem to its dl l OPERABLE l alternate DC : source AND B.4 Restore DC electrical power distribution 7 days bi subsystem to OPERABLE AND status. 176 hours from discovery of l failure to meet the LC0 l l (continued) O Brunswick Unit 1 3.8-34 Amendment No.
i Distribution Systems-Operating 3.8.7 C A_CTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC C.1 Restore DC electrical 7 days b electrical power power distribution distribution subsystems to AND subsystems inoperable OPERABLE status, for reasons other than 176 hours from Condition B. riiscovery of failure to meet lb LC0 D. Required Action and D.1 Be in MODE 3. 12 hours associated Completion Time of Condition A, AND B, or C not met. D.2 Be in MODE 4. 36 hours /fb E. Two or more electrical power distribution E.1 Enter LCO 3.0.3. Immediately b O subsystems inoperable that result in a loss of function. t 9 Brunswick Unit 1 3.8-35 Amendment No. 1 i
Distribution Systems-Operat:ng 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems. SR 3.8.7.2 Verify no combination of more than two 7 days power conversion modules (consisting of either two lighting inverters or one A lighting inverter and one plant an uninterruptible power supply unit) are aligned to Division II bus B. 1 O 1
- \
Brunswick Unit ~1 3.8-36 Amendment No. ,
Distribution Systems--Shutd:wn ) ! 3.8.8 1 (T 3.8 ELECTRICAL POWER SYSTEMS
\~-)
3.8.8 Distribution Systems--Shutdown LCO 3.8.8 The necessary portions of the AC and DC electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. APPLICABILITY: MODES 4 and 5, 1 During movement of irradiated fuel assemblies in the I secondary containment. j ACTIONS
.............................--------NOTE-------------------------------------
LC0 3.0.3 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME r A. One or more required A.1 Declare associated Immediately AC or DC electrical supported required power distribution feature (s) subsystems inoperable. inoperable. OB A.2.1 Suspend CORE Immediately ALTERATIONS. I AND A.2.2 Suspend movement of Immediately 1 irradiated fuel assemblies in the j secondary ! containment. AND (continued) (% O Brunswick Unit 1 3.8-37 Amendment No.
Distribution Systems-Shutdown 3.8.8 go) ACTIONS \ CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel. AND A.2.4 Initiate actions to Innediately restore required AC and DC electrical power distribution subsystems to OPERABLE status. AND A.2.5 Declare associated Immediately required shutdown cooling subsystem (s) inoperable and not in (,__,'s operation. v I i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution i subsystems. U Brunswick Unit 1 3.8-38 Amendment No.
AC S:urces-Operating B 3.8.1
- BASES LCO separation criteria.' If the preferred offsite circuit g
.(continued) -(i.e...the circuit path from a 230 kV bus through the SAT to the associated onsite Class IE emergency buses) is not connected to an emergency bus, the circuit.is required to have OPERABLE fast transfer capability to two emergency buses to support OPERABILITY of that circuit.
- APPLICABILITY The AC sources are required to be OPERABLE-in MODES 1, 2, and 3 to ensure that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
- b. . Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.
The AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS 8d The offsite circuits for two of the four 4.16 kV emergency buses utilize the opposite unit's SAT and UAT. Therefore, this Required Action provides a 45 day time period to perform maintenance on one of the opposite unit's transformers. This is acceptable because performing
- maintenance on the transformer will increase the reliability of the offsite circuit. However, if a second Unit 1 or 2 offsite circuit becomes inoperable, Conditions B and D are entered.
h The 45 day Completion Time takes into account the capacity and capability of the remaining AC sources and a reasonable time for performance of maintenance. The Note to Condition A only allows the 45 day Completion Time to be used when the opposite unit is in MODE 4 or 5. When a Unit 2 offsite circuit becomes inoperable while .. Unit 2.istin MODE 1, 2,-or 3, Condition B of Unit 1 . Specification 3.8.1 must be entered and the associated i
. Required Actions performed. i (continued)
- Brunswick Unit 1 B 3.8-5 Revision No.
( . WL : :-- -._ L:_.__2_-__ _ :_ -
AC Sources-Operating ! B 3.8.1 BASES ACTIONS M (continued) To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies
" perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition D, for two or more offsite -
circuits inoperable, is entered. g M Required Action B.2, which only applies if one 4.16 kV b emergency bus cannot be poweref from an offsite source, is intended to provide assurance that an event with a coincident single failure of the associated DG does not result in a complete loss of safety function of critical systems. Tlese features (e.g., system, subsystem, division, component, or device) are designed with redundant safety related 4.16 kV emergency buses. Redundant required feature (q'
'y failures consist of inoperable features associated with an I
I emergency bus redundant to the emergency bus that has no offsite power. The Completion Time for Required Action B.2 is intended to allow time for the operator to evaluate and repair any h discovered inoperabilities. This Completion Time also allows an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action the Completion Time only begins on discovery that both:
- a. A 4.16 kV emergency bus has no offsite power supplying its loads; and
- b. A redundant required feature on another emergency bus is inoperable.
If, at any time during the existence of this Condition (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time would begin to be tracked. (continued) bJ Brunswick Unit 1 B 3.8-6 Revision No.
AC S::urces-Operating B 3.8.1 BASES' ACTIONS M (continued)_ Discovering no offsite power to one 4.16 kV emergency bus of the onsite Class IE Power Distribution System coincident with one or more inoperable required support or supported features, or both,' that are associated with any other emergency bus that has offsite power, results in starting the completion Times for the Required Action.. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown. The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the_onsite Class IE Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour Completion Time takes into account the component _ OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour Completion Time takes into account the capacity,and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. M s According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition B for a period that should not exceed 72 hours. With one offsite circuit inoperable, the h reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety ' systems. In this condition, however, the remaining OPERABLE ; offsite circuits and DGs are-adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the-low probability of a DBA occurring during this period.
.The second Completion Time for Required Action B.3 establishes a limit on the maximum time allowed for any b
combination of required AC power sources to be inoperable , during any single contiguous occurrence of failing to meet { l (continued) Brunswick Unit 1 B 3.8 Revision No. j
l i AC S:urces-Operating B 3.8.1 BASES l ACTIONS U (continued) l LC0 3.8.1.a or b. If Condition B is entered while, for 61 instance, a DG is inoperable, and that DG is subsequently returned OPERABLE, the LCO may already have been not met for j up to 7 days. This situation could lead to a total of i 10 days, since initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERA 6LE, and an additional 7 days (for a total of 17 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LCO 3.8.1.a or b. This limit is considered reasonable for situations in which Conditions B and C are entered concurrently. The "AND" connector between the 72 hours and 10 day Completion Times h means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. As in Required Action B.2, the Completion Time allows for an exception to the normal " time zero" for beginning the h allowed outage time " clock." This exception results in p establishing the " time zero" at the time LC0 3.8.1.a or b h was initially nic met, instead of at the time that Condition B was entered. C.1 To ensure a highly reliable power source remains with one DG inoperable, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure to meet SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass : SR 3.8.1.1, it is inoperable. Upon offsite circuit ; inoperability, additional Conditions must then be entered. l l M l Required Action C.2 is intended to provide assurance that a bl l loss of offsite power, during the period that a DG is l inoperable, does not result in a complete loss of safety function of critical systems. These features are designed i to be powered from redundant safety related 4.16 kV (continued) l Brunswick Unit 1 B 3.8-8 Revision No. 1
l AC Sources-Operating B 3.8.1 BASES-ACTIONS M (continued) b emergency buses (i.e., s mgle division systems are not included). Redundant required feature failures consist of inoperable features associated with an emergency bus redundant to the emergency bus that has an inoperable DG. - The Completion Time is intended to allow the operator. time to evaluate and repair any discovered inoperabilities. This D Completion Time also allows for an exception to the normal-
" time zero" for beginning the allowed outage time " clock."
In this Required Action the Completion Time only begins on discovery that both:
- a. An inoperable DG exists; and
- b. A redundant required feature on another emergency bus is inoperable. .,
If, at any time during the existence of this Condition (one i DG inoperable), a required redundant feature subsequently H becomes . inoperable, this Completion Time begins to be tracked. Discovering one DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DGs results in starting the Completion Time for the Required Action. Four ! hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before ~ subjecting the unit to transients associated with shutdown. The remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The
'4 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour Completion Time l takes into account the capacity and capability of the
, remaining AC sources, a reasonable time for repairs, and the
. low probability of a.DBA occurring during this period.
(continued) Brunswick Unit l' B 3.8-9' Revision No.
AC Scurces-Operating B 3.8.1
. BASES ACTIONS C.3.1 and C.3.2 h (continued)
Required Action C.3.1 provides an allowance to avoid -. unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DGs, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on-other h DG(s), they are declared inoperable upon discovery, and Condition F or H of LCO 3.8.1.is entered, as applicable. Once the failure is repaired, and the common cause failure nol longer exists, Required Action C.3.1 is satisfied. If the cause of the initial inoperable-DG cannot be confirmed d not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those DGs. In the event the inoperable DG is restored to OPERABLE status prior to completing either C.3.1 or C.3.2 (i.e., the
~
inc;, rable DG has been restored to OPERABLE status but it has not yet been determined if-the cause of the inoperability is common to the other OPERABLE DGs), the CP&L d Corrective Action Program (CAP) will continue to evaluate
.O the common cause possibility. This continued evaluation, I however, is no longer required under the 24 hour constraint imposed while in Condition C. h According to Generic letter 84-15 (Ref. 10), 24 hours is a reasonable time to confirm that the OPERABLE DGs are not affected by the same problem as the inoperable DG.
C.4 h The 4.16 kV emergency bus design is sufficient to allow operation to continue in Condition C for a period that should not exceed 7 days. In Condition C, the remaining g OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class lE Distribution System. The 7 day Completion _ Time takes ~into account the capacity ! and capability of the remaining AC sources, a reasonable l time for repairs, and the low probability of a DBA occurring during this period.
._ .,.._ ;, (continued)
O
-Brunswick Unit l' B 3.8-10 Revision No.
l i c_______._____________._ . _ _ _ _ . _ _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _
AC Scurces-Operating B 3.8.1 BALES ACTIONS fo.1 (continued) The second Completion Time for Required Action C.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet LCO 3.8.1.a or b. If Condition C is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours. This situation could lead to a total of 10 days, since initial ~ failure of the LCO, to restore the DG. At this time, an offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours (for a total of 13 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LCO 3.8.1.a or b. This limit is considered reasonable for situations in which conditions B and C are entered concurrently. The "8lg}" connector between the 7 day and 10 day. Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met. I As in Required Action C.2, the Completion Time allows for an exception to the normal " time zero" for beginning the h allowed outage time " clock." This exception results in establishing the " time zero" at the time that LC0 3.8.1.a or b was initially not met, instead of the time that Condition C was entered. i D.1 and D.2 L g Required Action D.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with inoperability of two or more offsite l circuits. Required Action D.1 reduces the vulnerability to E l a loss of function. The Completion Time for taking these actions is reduced to 12 hours from that allowed with one g 4.16 kV emergency bus without offsite power (Required Action B.2). The rationale for the reduction to 12 hours is E that Regulatory Guide 1.93 (Ref. 9) allows a Completion Time of 24 hours for two offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE. While this Action allows more than two circuits (continued) ! ~vO Brunswick Unit 1 B 3.8-11 Revision No.
4 AC S:urces-Operating f B 3.8.1 O BASES V ACTIONS D.1 and 0.2 (continued) h to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two circuits are required by the LCO, and a loss of those two circuits results in a total loss of offsite power to the Class IE Electrical Power Distribution System. Thus, with the BNF electrical design, a loss of the four offsite 6 circuits results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9). When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours is appropriate. These features are designed with redundant safety related 4.16 kV emergency buses, (i.e., single division systems are not included in the list). Redundant required feature failures consist of 'any of these features that tre inoperable because l any inoperability is on an emergency bus redundant to an l emergency bus with inoperable offsite circuits. The Completion Time for Required Action D.1 is intended to allow the operator time to evaluate and repair any h discovered inoperabilities. This Completion Time also allows for an exception to the normal " time zero" for
- n beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that (V 4 both:
- a. Two or more offsite circuits are inoperable; and
- b. A redundant required feature is inoperable.
If, at any time during the existence of this Condition (any combination of two or more Unit I and 2 offsite circuits inoperable), a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked. According to Regulatory Guide 1.93 (Ref. 9), operation may , continue in Condition D for a period that should not exceed - 24 hours. This level of degradation means that the offsite . electrical power system may not have the capability to l effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power ; sources. (continued) O d Brunswick Unit 1 B 3.8-12 Revision No.
AC Sources-0perating B 3.8.1 BASES
~
ACTIO*lS D.1 and 0.2 (continued) ta l Because of the normally high availability of the offsite ' sources, this level of degradation may appear to be more i severe than other combinations of two AC sources inoperable j that involve one or more DGs inoperable. However, two factors tend to decrease the severity of this degradation level:
- a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure; and
- b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.
With two or more of the offsite circuits inoperable, l sufficient onsite AC sources are available to maintain the j unit in a safe shutdown condition in the-event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety
?O analysis. Thus, the 24 hour Completion Time provides a period of time to effect restoration of all but one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.
According to Regulatory Guide 1.93 (Ref. 9), with the L available offsite AC sources two less than required by the LCO, operation may continue for 24 hours. If all offsite sources are restored within 24 hours, unrestricted operation may continue. If all but one offsite source is restored within 24 hours, power operation continues in accordance with condition A or 8, as applicable. LLand E.2 Pursuant to LCO 3.0.6, the Distribution System-Operating ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition E are modified by a Note h ,~ (continued) O ! Brunswick Unit 1 B 3.8-13 Revision No.
p . AC Sources-Operating B 3.8.1
-BASES ACTIONS E.1 and E.2 '(continued) to indicate that when Condition E is entered with no AC b
source to any 4.16 kV emergency bus, ACTIONS for LCO 3.8.7,
" Distribution Systems-Operating," must be immediately -
entered. This allows Condition E to provide requirements for the loss of an offsite circuit and one DG without-regard to whether an emergency bus is.de-energized. LCO 3.8.7 E provides the appropriate restrictions for a de-energized emergency bus. According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition E for a period that should not exceed A 12 hours. In Condition E, individual redundancy is' lost in h both the offsite electrical power system and the onsite AC - electrical power system. Since power system redundancy is provided by two diverse sources of. power, however, the reliability of the power systems in this Condition.may appear _ higher than that in Condition D (loss of two or.more - offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour Completion Time takes into account the capacity and capability of the O remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. L1 b With two or more DGs inoperable and an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however the time allowed for continued operation is severely restricted. The intent here is to avoid the. risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation. (continued) O
. Brunswick Unit l1 B 3.8-14 Revision No. -: l
AC S:urces-0p: rating
.B 3.8.1 BASES ACTIONS E d (continued)
According to Regulatory Guide 1.93 (Ref. 9), with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours. While this Action allows more than two DGs to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two DGs are required by the LCO, and a l loss of those two DGs results in a total loss of onsite power to the Class IE Electrical Power Distribution System. Thus, with the BNP electrical design, a loss of the four DGs g results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9). G.1 and G.2 h j If the inoperable AC electrical power sources cannot be ) restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are p reasonable, based on operating experience, to reach the i required plant conditions from full power conditions in an orderly manner and without challenging plant systems. l l H.1 g Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been ; lost. At this severely degraded level, any further losses I in the AC electrical power system may cause a loss of ' function. Therefore, no additional time is justified for continued operation. The unit is required by LC0 3.0.3 to commence a controlled shutdown. SURVEILLANCE The AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features, especially those that have a standby function, in accordance with UFSAR Sections 8.2 and 8.3 (Ref. 2). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for (continued) Brunswick Unit 1 B 3.8-15 Revision No. [. . . . .
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE demonstrating the OPERABILITY of the DGs are consistent with. REQUIREMENTS the recommendations of Safety Guide 9 (Ref. 5), Regulatory (continued) Guide 1.9 (Ref.11), and Regulatory Guide 1.137 (Ref.12), as addressed in the UFSAR. g) Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable. The minimum steady state output voltage of 3750 V is derived ) froe the recossendations found in Safety Guide 9 (Ref. 5) and bounds the minimum steady state output voltage criteria of 3621 V associated with the 4.16 kV emergency buses analyzed in the AC Auxiliary Electrical Distribution ~ System Study. This value (3621 V) allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 3600 V. It also allows for voltage drops to motors and other equipment down through the 480 V level 1 where minimum operating voltage is-also usually specified as I 90% of name plate rating. The specified maximum. steady
- l. state output voltage of 4300 V ensures the maximum operating voltage at the safety related 480 V substations is no more l than the maximum rated steady state voltage criteria for the i 480 V motor control centers. The maximum steady state output voltage was determined taking into consideration the
,O voltage drop between the DGs and the 4.16 kV emergency buses and a 5% voltage boost at the 480 V substation transformers.
This maximum steady state output voltage also ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated steady state operating voltage. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Safety Guide 9 (Ref. 5). SR 3.8.1.1
-This SR ensures proper circuit continuity for the offsite AC j electrical power supply to the onsite distribution network i and availability of offsite AC electrical power. The !
breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads i are connected to their preferred power source and that appropriate independence of offsite circuits is' maintained. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room. (continued) Brunswick Unit.1 B 3.8-16 Revision No. - _=_ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ ____
AC Sources-Operating . B 3.8.1 BASES _ SURVEILLANCE SR 3.8.1.2 and SR' 3.8'.I'.7 REQUIREMENTS (continued). .These SRs help to ensure the availability of-the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition. To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified.by a Note (Note I for SR 3.8.1.2 and SR 3.8.1.7) to indicate that all DG starts for these Surve111ances may be preceded by an engine prelube period. For the purposes of this testing, the DGs are started from standby conditions. Standby. conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained. In order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed,.and the DGs are gradually accelerated to synchronous speed prior to loading. These start procedures p are the intent of Note 2 of SR 3.8.1.2. SR 3.8.1.7 requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The minimum voltage and frequency stated in the SR are those necessary to ensure the DG can accept DBA loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a. typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not dampened by load application. This period may be , extended beyond the 10 second acceptance criteria and could i be cause for failing the SR. In lieu of a time constraint in the SR, BNP will monitor. and trend the actual time to - reach steady state operation'as a means of ensuring there is , no voltage regulator or governor degradation which could I cause a DG to become inoperable. The 10 second start ! requirement supports and is conservative with respect to the ) assumptions in the design basis LOCA analysis of UFSAR, I Section 6.3..(Ref. 6). 'The 10 second start requirement is ! l (continued) A! Brunswick Unit 1 B 3.8-17 Revision No. l
- ~ -
AC S:urces-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7 (continued) REQUIREMENTS-not applicable to SR 3.8.1.2 (see Note 2 of SR 3.8.1.2), when a modified start procedure as described above is used. If.a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies. To minimize testing of the DGs, Note 3 to SR 3.8.1.2 and Note 2 to SR 3.8.1.7 allow a single test (instead of. two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. >
'The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref.11). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 10). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.
SR 3.8.1.3 This surveillance verifies that the DGs are capable of synchronizing and accepting a load approximately equivalent to the continuous rating of the DGs. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite srurce. Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is the generator design < limitation which if exceeded could lead to generator instability while in parallel with the offsite circuit. The i i load band is provided to avoid routine overloading of the .! l DG. Routine overloading may result in more frequent I teardown. inspections in order to maintain DG OPERABILITY. i 1 l .The 31 day Frequency for this Surveillance is consistent l with Regulatory Guide 1.9 (Ref.11). ! (continued)
. Brunswick Unit B 3.8-18 Revision No..
E__.__
AC S urces-Operating B 3.8.1 BASES i SURVEILLANCE SR 3.8.1.3- (continued) REQUIRDiENTS Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading so that mechanical stress and wear on the diesel engine are minimized. Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients outside the range normally used during the performance of. A i this Surveillance do not invalidate the test. E Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance. To minimize testing of the DGs, Note 5 allows a single test O (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. SR 3.8.1.4 This SR provides verification that the level of fuel oil in the engine mounted tank is slightly below the level at which the backup fuel oil transfer pump automatically starts. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for approximately 30 minutes of DG operation at rated load. This SR may be satisfied by verifying the absence of the associated low level alarm. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are E provided and facility operators would be aware of any large uses of fuel oil during this period. (continued) Brunswick Unit.1' B 3.8-19 Revision No. ___.-_.l____.-- ._.:.-------_-_.._---._,.
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE- SR 3.8.1.5-REQUIREMENTS (continued) Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel. oil and cause fouling, but all must have.a water. environment in order to survive. Removal of water from the engine mounted tanks once every 31 days eliminates the necessary environment for bacterial survival.- This is the most effective means of controlling microbiological fouling. In addition,'it eliminates the potential for water i entrainment in the fuel oil during DG operation. Water may ; come from any of several sources, including condensation, rain water, contaminated fuel oil, and breakdown of the fuel l -oil by bacteria. Frequent checking for and' removal. of accumulated water minimizes fouling. and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref.12). This SR.is for preventive maintenance. The presence of water does not necessarily represent a failure of this.SR provided that accumulated water is removed during performance of this Surveillance. Removal of accumulated water may be accomplished by draining a portion of fuel oil from the engine mounted fuel oil tank to the day fuel oil storage tank and draining any accumulated water from the day fuel oil storage tank in accordance with-SR 3.8.3.3. ~The draining evolution will continue until accumulated water is verified to be removed from the engine mounted fuel oil tank. SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its ! associated storage tank to its associated day tank. It is ' required to support continuous operation of standby power-sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is , intact, the fuel delivery piping is not obstructed, and the I controls and control systems for fuel transfer systems are ! L OPERABLE. (continued 1 0 ! Brunswick Unit-1 B 3.8-20 Revision'No. '
AC Sources-Opsrating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.6 (continued) REQUIREMENTS The Frequency for this SR is consistent with the Frequency-for testing the DGs in SR 3.8.1.3. DG operation for SR 3.8.1.3 is normally long enough that fuel oil level in the engine mounted tank will be reduced to the point where g the fuel oil transfer pump automatically starts to restore fuel oil level in the engine sounted tank. SR 3.8.1.8 Transfer of each 4.16 kV emergency bus power supply from the I normal circuit to the preferred offsite circuit and from the preferred offsite circuit to the alternate offsite circuit i demonstrates the OPERABILITY of the offsite circuit distribution network to power the shutdown loads. In lieu of actually initiating an automatic circuit transfer, testing that adequately shows the capability of the transfer is acceptable. The automatic transfer testing may include any series of sequential, overlapping, or total steps so that the entire transfer sequence is verified. The 24 month q Frequency of the Surveillance is based on engineering Q judgment taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed on the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. This SR is modified by three Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of SR 3.8.1.8.a, verification of automatic transfer capability of the unit power supply from the normal circuit to the preferred offsite circuit, could cause b perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. Note 1 is not applicable to
' SR 3.8.1.8.b, verification of manual transfer of the unit power supply from the preferred offsite circuit to the g
alternate offsite circuit, since this evolution does not cause perturbations of. the electrical distribution systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, bj 4 both units' offsite circuits are required to be OPERABLE to i g (continued) ) e Brunswick Unit 1 B 3.8-21 Revision No. ' l
AC Ssurces-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.8 (continued)- REQUIREMENTS supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need for a shutdown of both units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for the Unit 1 d offsite circuits when Unit 1 is in MODE 1 or 2. _During the performance of this Surveillance with Unit I not in MODE 1 or 2 and with Unit 2 in MODE.1, 2, or 3;.the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a Unit I offsite circuit is rendered inoperable by the performance of this Surveillance. Credit-may be taken for unplanned events that satisfy this SR.- As stated in Note 2, automatic transfer capability to the SAT is not required to be met when the associated 4.16 kV-emergency buses are powered from the preferred offsite circuit. This is acceptable since the automatic transfer capability function has been satisfied in this condition. To minimize testing, Note 3 allows a single test (instead of two tests, one for each unit) to satisfy the requirements O for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on a single unit. If an offsite circuit fails one of the A Surve111ances, the offsite circuit should be considered inoperable for both units. SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG capability to reject the largest single load without tripping. The largest single load for each DG is a core spray pump (1250 hp). This Surveillance may be accomplished by:-
- a. ' Tripping the DG output breaker with the DG carrying greater-than or equal to its associated core spray
' pump while paralleled to offsite power, or while solely supplying the bus; or (continued)
Brunswick Unit 1 B 3.8 Revision No.
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued) REQUIREMENTS
- b. Tripping its associated core spray pump with the DG solely supplying the bus.
The load rejection test is acceptable if the increase in diesel speed does not exceed the overspeed trip setpoint. The 24 month Frequency.is consistent with the recommendation of Regulatory Guide 1.9 (Ref. 11). This SR is modified by three Notes. . The reason for Noto 1 is that, during operation with the reactor critical, performance of this SR could.cause perturbations to the electrical distributic, systems that could challenge continued steady state operation and, as a result, plant safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERABLE to supply power to these systems when either one or both
-units are in MODE 1, 2, or 3. In order to reduce the consequences of- a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need to Os shutdown both units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for l
DG 1 and DG 2 when Unit 1 is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit I not in MODE 1, g 2, or 3 and with Unit 2 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if DG 1 or DG 2 is rendered inoperable by g the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factor s 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. To minimize testing of the DGs, Note 3 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit.- If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. (continued) l( Brunswick Unit 1 8 3.8-23 Revision No. d . -____li_.__ _ _ _ _ _ _ _ _ _
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.10 REQUIREMENTS
-(continued) Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g., high jacket water temperature) are bypassed on an ECCS initiation test signal and critical protective functions (engine overspeed, generator differential overcurrent, low lubricating oil pressure, reverse power, loss of field, and phase overcurrent-voltage restrained) trip the DG to avert-substantial damage to the DG unit. The non-critical trips are bypassd during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.
The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has l demonstrated that these components will pass the SR when I O performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. The SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, 8 one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG - should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. SR 3.8.1.11 Brunswick Nuclear Plant performs a 60 minute run greater than or equal to the continuous rating (3500 kW) which bounds the maximum expected post-accident DG loading. The DG starts for this Surveillance can be performed either from
- (continued) .
l h Brunswick Unit 1: B 3.8-24 Revision No. i i
j AC Sources-Operating F 3.8.1 BASES l SURVEILLANCE SR 3.8.1.11 (continued) REQUIREMENTS .
. standby or hot conditions. The provisions for prelube and warmup, discussed in the Bases-for SR 3.8.1.2, and for l gradual loading, discussed in the Bases for SR 3.8.1.3, are applicable to this SR.
In order to ensure that the DG is' tested under load conditions that are as close to design conditions as-possible,' testing must be performed using.a power factor
- s 0.9. This power factor is chosen to be representative of the actual design basis inductive-loading that the DG could, experience. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY.
The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9. (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths. This Surveillance has been modified by two Notes. Note 1 states that momentary transients.due to changing bus loads b do not invalidate this test. $1milarly, momentary power factor transients above the limit do not invalidate the test. To minimize testing of the DGs, Note 2 allows a single test (instead of two tests, one for each unit) to h satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. i SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref.11), paragraph C.2.2.13, demonstration of the test mode override feature ensures that the DG availability under accident conditions
.is not compromised as the result of testing. . Interlocks to u the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation l (continued) l
- O '
- Brunswick Unit I- ,
B 3.8-25 Revision No.
-.___1-_--- __ _
AC Sources-Operating B-3.8.1 BASES f SURVEILLANCE SR 3.8.1.12 (continued) REQUIREMENTS signal is received during operation in the test mode.
-Ready-to-load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.
These provisions for. automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.4(6). In lieu of actually returning the DG to ready-to-load status, testing that adequately shows the capability of the DG to perform this function is acceptable. 'This testing may include any series of sequential, overlapping, or total steps so that the entire sequence is verified. The 24 month Frequency is consistent with the recommendations of. Regulatory Guide 1.9 (Ref.11), Table 1; l takes into consideration plant conditions required to perform the Surveillance; and is intended-to be consistent with expected fuel cycle lengths. This SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, e one for each unit) to satisfy the requirements for both ( units. This is allowed since the main purpose of the , Surveillance can be met by performing the test on either i unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one l unit. SR 3.8.1.13 l Under accident conditions loads are sequentially connected to the bus by the automatic load sequence time delay relays. 1 The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to ! applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. I Reference 4 provides a summary of the automatic loading of l ESF buses. (continued)
- Brunswick Unit 1- B 3.8-26. Revision No.
4 O_ __________m__ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ _ _
AC Sources-0parating B 3.8.1 i BASES O
- SURVEILLANCE- SR 3.8.1.13 (continued)
REQUIREMENTS , The Frequency of 24 months is consistent with the recosmiendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required.to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths. This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs, and associated load sequence relays, are required to be OPERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce potential consequences associated with removing a required offsite circuit from service during the performance of.this Surveillance, reduce consequences of a potential perturbation to the electrical distribution systems during 8 the performance of this Surveillance, and reduce challenges A to safety systems, while at the same time avoiding the need 'id to shutdown both units to perform this Surveillance, the Note only precludes satisfying this Surveillance Requirement for the load sequence relays associated with'DG 1 and DG 2 when Unit 1 is in MODE 1, 2, or 3. During the performance , of this Surveillance with Unit I not in MODE 1, 2, or 3 and E with Unit 2 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 1, or DG 2 is g rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. SR 3.8.1.14 In the event of a DBA coincident with a loss of offsite power,.the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded. This Surveillance demonstrates DG operation during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal.- This test verifies all actions encountered from the event, including shedding of the 'C uJ (continued) Brunswick Unit 1 'B 3.8-27 Revision No. 4
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.I'14 (continued) REQUIREMENTS nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time. g The 10.5 second time period, which is allowed for the DG to auto-start and connect to its respective emergency bus, is conservatively derived from requirements of the accident analysis for responding.to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved. The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are O not capable of being operated at full flow, or RHR systems 1erforming a decay heat removal function are not desired to l
>e realigned to the ECCS mode of operation.
In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the i DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified. The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length. This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with procedural guidance. The reason for Note 2 , is that performing the Surveillance would remove a required ! offsite circuit from service, perturb the electrical (continued) g iBrunswick Unit 1 B 3.8 Revision No. L---_-__---_. -_
AC S:urces-Operating ! B 3.8.1 l BASES 1 SURVEILLANCE SR 3.8.1.14 (r.ontinued) 1 REQUIREMENTS distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERABLE to supply power to l these systems when either one or both units are in MODE 1, ! 2, or 3. In order to reduce the potential consequences l asscciated with removing a required offsite circuit from serv 6:e during the performance of this Surveillance, reduce
&j' consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to perform this Surveillance, Note 2 only precludes satisfying this Surveillance Requirement for DG 1 and DG 2 when Unit 1 l is in MODE 1, 2, or 3. During the performance of this l Surveillance with Unit I not in MODE 1, 2, or 3 and with Unit 2 in MODE 1, 2, or 3; the applicable ACTIONS of the b
l Unit I and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 1, DG 2, or other supported Technical Specification equipment is rendered q inoperable by the performance of this Surveillance. Credit Q may be taken for unplanned events that satisfy this SR. REFERENCES 1. UFSAR, Section 8.3.1.2.
- 2. UFSAR, Sections 8.2 and 8.3.
- 3. NRC Diagnostic Evaluation Team Report for Drunswick Steam Electric Plant dated August 2,1989, from J.M. Taylor (NRC) to S.H. Smith, Jr. (CP&L).
- 4. UFSAR, Table 8.3.1-6.
- 5. Safety Guide 9.
- 6. UFSAR, Chapter 6.
- 7. UFSAR, Chapter 15.
- 8. 10 CFR 50.36(c)(2)(ii).
- 9. Regulatory Guide 1.93, December 1974.
- 10. Generic Letter 84-15.
O (continued) V Brunswick Unit 1 B 3.8-29 Revision No.
AC Ssurces-0perating L 8 3.8.1 ( BASES
-REFERENCES 11. Regulatory Guide 1.9,' July 1993,- Revision 3.
(continued)
- 12. Regulatory Guide 1.137, January 1978.
- 13. IEEE Standard 308. b I IIIMI I I Ell I I I l
O l
<- )
T l Brunswick Unit 1 B 3.8-30 Revision No. i i
AC S:urces-Shutdown B 3.8.2 O v B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources-Shutdown BASES BACKGROUND A description of the AC sources is provided in the Basas for LCO 3.8.1, "AC Sources-Operating." APPLICABLE The OPERABILITY of the minimum AC sources during MODES 4 SAFETY ANALYSES and 5, and during movement of irradiated fuel assemblies in the seconde r containment ensures that:
- a. The facility can be maintained in the shutdown or refueling condition for extended periods;
- b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
- c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling I accident.
In general, when the unit is shutdown the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and l concurrent loss of all offsite power is not required. The j rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences. These deviations from DBA analysis : assumptions and design requirements during shutdown j conditions are allowed by the LCO for required systems.
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During MODES 1, 2, and 3, various deviations from the analysis assumptions and design requirements are allowed within the ACTIONS. This allowance is in recognition that certain testing and maintenance activities must be ! g_ (continued) \ Brunswick Unit 1 B 3.8-31 Revision No.
AC S:urces-Shutdown B 3.8.2
-BASES APPLICABLE conducted, provided an acceptable level of.rlsk is not SAFETY ANALYSES exceeded. During MODES 4 and 5, performance.of a (continued) significant number of required testing and maintenance-activities is also required. In MODES 4 and 5, the activities are generally planned and administrative 1y controlled. Relaxations from typical MODES 1, 2, and 3 LCO requirements are acceptable during shutdown MODES, based on:
- a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.
- b. Requiring appropriate compensatory measures for certain conditions. These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operation MODE analyses, or both.
- c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.
- d. Maintaining, to the extent practical, the ability to O perform required functions (even if not meeting MODES 1, 2, and 3 OPERABILITY requirements) with systems assumed to function during an event.
In the event of an accident during shutdown, this LCO ensures the capability of supporting systems necessary for avoiding immediate difficulty, assuming a loss of all offsite power. The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 1). LC0 One Unit 1 offsite circuit capable of supplying the onsite Class 1E power distribution subsystem (s) of LC0 3.8.8, A [ " Distribution Systems-Shutdown," ensures that all required Unit 1 loads are powered from offsite power. Two OPERABLE. g DGs, associated with distribution subsystem (s) required OPERABLE by LCO 3.8.8,. ensures that a diverse power source [g is available for providing electrical power support assuming a loss of the offsite circuit (s). In addition, some Unit 2 equipment may be required by Unit 1 (e.g., Control Room Emergency Ventilation (CREV) System components). Therefore, g one. Unit 2 qualified circuit between the offsite C J (continued) Brunswick Unit 1- B 3.8-32 Revision No. = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ - - _ - _ _ _ - - _ _ _ _ _ _ - _ . __.
AC Scurces-Shutdown B 3.8.2 BASES-LCO transmission network and the onsite Class IE AC electrical (continued) power distribution subsystem (s), needed to support the Unit 2 equipment required to be OPERABLE, must also be OPERABLE. Together, OPERABILITY of the required offsite circuit (s) and DGs ensures the availability of sufficient AC sources to operate the plant In a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and reactor vessel draindown). The qualified offsite circuit (s) must be capable of-maintaining rated frequency and voltage while connected to the respective emergency bus (es), and of accepting required loads during an accident. Qualified offsite circuits are-those that are described in the UFSAR and are part of the licensing basis for the unit. The Unit 1 qualified offsite circuit consists of the incoming breaker and disconnect to and including the associated startup auxiliary transformer , (SAT) or unit auxiliary transformer (UAT), the respective ! circuit path to and including the balance of plant bus (es), ' and the circuit path to associated 4.16 kV emergency bus (es) required by LC0 3.8.8. The Unit 2 qualified offsite circuit consists of the incoming breaker and disconnect to and O, including the associated SAT or UAT, the respective circuit path to and including the balance of plant bus (es), and the circuit path to associated 4.16 kV emergency bus (es) required by LCO 3.7.3, LCO 3.7.4 and LCO 3.8.5. The required DGs must be capable of starting, accelerating to minimum acceptable frequency and voltage, and connecting j to its respective 4.16 kV emergency bus on detection of bus undervoltage. This sequence must be accomplished within 10.5 seconds. Each required DG is required to have an OPERABLE air start system consisting of one air header, one receiver, associated air compressor, piping, valves, and ! instrument controls to ensure adequate starting and control ! air capacity. Additionally, each DG must be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the 4.16 kV emergency buses. These i capabilities are required to be met from a variety of 1 initial conditions such as DG in standby with engine at ! ambient'ronditions. Additional DG capabilities must be ! demonstrated to meet required Surveillance, e.g., i capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode. Proper l (continuedl I :. Brunswick Unit 1. B 3.8-33 Revision No. i l r _ _ _ - _
AC S:urces-Shutdown B 3.8.2 O BASES U _ LCO sequencing of loads, including tripping of nonessential (continued) loads, is required function for DG OPERABILITY. The necessary portions of the Nuclear Service Water System are also required to provide appropriate cooling to each required DG. It is acceptable for 4.16 kV emergency buses to be cross tied during shutdown conditions, permitting a single offsite power circuit to supply all required buses provided both units are shutdown. APPLICABILITY The AC sources are required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment to provide assurance that:
- a. Systems providing adequate coolant inventory makeup are available for the irradiated fuel assemblies in the ccre in case of an inadvertent draindown of tha reactor vessel;
- b. Systems needed to mitigate a fuel handling accident m are available;
- c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
- d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
AC power requirements for MODES 1, 2, and 3 are covered in ! LCO 3.8.1. ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, 1 since irradiated fuel assembly movement can occur in Mode 1, i 2, or 3, the ACTIONS have been modified by a Note stating i that LC0 3.0.3 is not applicable. If moving irradiated fuel i assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in i i MODE 1, 2, or 3, the fuel movement is independent of reactor ; operations. . Entering LC0 3.0.3, while in MODE 1, 2, or 3, ! would require the unit to be shutdown, but would not require n immediate suspension of movement of irradiated fuel 'S assemblies. The Note to the ACTIONS "LCO 3.0.3 is not (continuedl yd Brunswick Unit 1 B 3.8-34 Revision No. E-_ --_
1
-l AC S:urces-Shutdown B 3.8.2 BASES.
ACTIONS applicable," ensures that the actions for immediat'e (continued) suspension of-irradiated fuel assembly movement are not postponed due to entry into LC0 3.0.3. A.1 and B.1 With one or more required offsite circuits inoperable, or with one DG inoperable, the remaining required AC sources may be capable of supporting sufficient required features (e.g., system, subsystem, division, component, or device) to allow continuation of CORE ALTERATIONS, fuel movement, and l operations with a potential for draining the. reactor vessel. l l For example, if two 4.16 kV emergency buses are required per LCO 3.8.8, one emergency bus with offsite power available may be capable of supplying sufficient required features. l By the allowance of the option to declare required features inoperable that are not powered from offsite power (Required Action A.1) .or capable of being powered by the required DG (Required Action B.1), appropriate restrictions can be implemented in accordance with the affected required feature (s) LCOs' ACTIONS. Required features remaining powered from the qualified offsite power circuit, even if g the circuit is inoperable to other required features, are not declared inoperable by this Required Action. A.2.1. A.2.2. A.2.3. A.2.4. B.2.1. B.2.2. B.2.3. B.2.4. C.I. C.2. C.3. and C.4 With an offsite circuit not available to all required 4.16 kV emergency buses or one required DG inoperable, the option still exists to declare all required features inoperable (per Required Actions A.1 and B.1). Since this option may involva undesired administrative efforts, the allowance for su/ficiently conservative actions. is made. With two requirud DGs inoperable, the minimum required diversity of Ar, power sources is not available. It is, therefore, re uired s to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and activities that could result in inadvertent draining of the ; reactor vessel. l Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately (continued) Brunswick' Unit'l B 3.8-35 Revision No.
AC S:urces-Shutdown B 3.8.2 i BASES i ACTIONS A.2.1. A.2.2. A.2.3. A.2.4. B.2.1. B.2.2. B.2.3. B.2.4. C.1. C.2. C.3. and C.4 (continued) initiate action to restore the required AC sources and to { continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems. The Completion Time of immediately is consistent with the < required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may J be without sufficient power. i Pursuant to LC0 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required 4.16 kV emergency bus, ACTIONS for LC0 3.8.8 must be immediately entered. This Note allows Condition A p to provide requirements for the loss of the offsite circuit v whether or not a required bus is de-energized. LC0 3.8.8 provides the appropriate restrictions for the situation involving a de-energized bus. SURVEILLANCE SR 3.8.2.1 REQUIREMENTS i SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are ' necessary for ensuring the OPERABILITY of the required AC k sources in other than MODES 1, 2, and 3 to be met. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.12 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. Refer to the corresponding Bases for e LC0 3.8.1 for a discussion of each SR. This SR is modified by a Note. The reason for the Note is I to preclude requiring the OPERABLE DG(s) from being i paralleled with the offsite power network or otherwise
- rendered inoperable curing the performance of SRs, and to i preclude de-energizing a required 4.16 kV emergency bus or l
(continued) J l 6 l Brunswick Unit 1- B 3.8-36 Revision No.
AC S:urces-Shutdown , B 3.8.2 l BASES SURVEILLANCE SR 3.8.2.I' (continued) REQUIREMENTS disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit (s) and the DGs. It is the intent that these SRs must still be capable of being met, but actual performance is not required during seriods when the DGs and offsite circuit (s) are required to a OPERABLE unless Unit 2 Specification 3.8.1, "AC Sources-Operating," requires performance of these SRs. When Unit 2 Specification 3.8.1 requires performance of these SRs, AC sources availability is not limited due to the Unit 2 requirements for AC source OPERABILITY. Therefore, a A i single event, in this condition, is not expected to m compromise both the required offsite circuit (s) and the DG(s). REFERENCES 1. 10 CFR 50.36(c)(2)(ii). O l I l 3 (d Brunswick Unit 1 B 3.8-37 Revision No.
i Diesel Fuel Oil B 3.8.3 L
.B 3.8'LELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel 011 BASES II E IIII I I E I
-BACKGROUND Each diesel generator (DG) is provided with storage tanks having a fuel oil capacity sufficient to operate that DG for
.a period of approximately-7 days while the DG is operating at rated. load as discussed in UFSAR, Section 8.3.1.1.6.2 8 (Ref. 1). The fuel consumption rate is calculated using the assumption that four DGs are available. The diesel generator fuel oil capacity in the combination of the fuel-oil volumes of the Seismic Class I day fuel oil storage tanh -(one tank for each diesel generator) and the Seismic Class I engine mounted fuel tanks (one tank attached to each diesel generator) provide approximately four days of diesel generator operation at rated load. The main fuel oil storage tank provides approximately three additional days of diesel generator operation at rated load to each of the day fuel oil storage tanks. The main fuel oil storage tank is seismically designed but not seismically qualified.
Following the postulated loss of the main fuel oil storage tank, the onsite fuel oil capacity in seismically qualified storage tanks is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources as discussed in Reference 1. Fuel oil is transferred from the day fuel oil storage tank to the engine. mounted fuel tank by either of two transfer pumps associated with each day fuel oil storage tank. Fuel oil is gravity fed from the main fuel oil storage tank to the day fuel oil storage tanks through manual or automatic valves. However, level in the day fuel oil storage tanks is currently maintained through the use of the manual valves. Redundancy of pumps and piping, and the normally isolated gravity feed lines from the main fuel oil storage tank to the day fuel oil storage tanks, precludes the failure of one pump, or the rupture of any pipe, valve, or tank to result
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in the loss of more than one DG. All outside tanks, pumps, and piping (other than the main fuel oil storage tank and a portion of the associated piping) are located underground. (continued) O Brun'swick Unit 1 B 3.8-38 Revision No. ;
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Diesel Fuel Oil B 3.8.3 BASES BACKGk N.D For proper operation of the standby DGs, it is necessary to (continued) ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as modified by Reference 3. The fuel oil properties governed by SRs of this Specification are the water content, the kinematic viscosity, and impurity level. g APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in UFSAR, Chapter 6 (Ref. 4), and Chapter 15 (Ref. 5), assume Engineered Safety Feature (ESF) systems are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems to that reactor fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2,
" Power Distribution Limits"; Section 3.5, " Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling ,
(RCIC) System"; and Section 3.6, " Containment Systems." Since diesel fuel oil supports the operation of the standby O AC power sources, it satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 6). LC0 Stored diesel fuel oil is required to have sufficient supply for approximately 7 days of operation at rated load. It is also required to meet specific standards for quality. These requirements, in conjunction with an ability to obtain replacement supplies within approximately 7 days, support the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated ! i operational occurrence (A00) or a postulated DBA with loss i of offsite power. DG engine monnted tank fuel oil requirements, as well as transfer capability from the day fuel oil storage tank to the engine mounted tank, are addressed in LCO 3.8.1, "AC Sources-Operating," and LC0 3.8.2, "AC Sources-Shutdown." l (continued) l O t b) Brunswick Unit i B 3.8-39 Revision No. l _ _ ___
1 Diesel Fuel Oil j B 3.8.3 BASES (continued) i APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an A00 or a postulated DBA. Because stored diesel fuel oil supports LC0 3.8.1 and LCO 3.8.2, stored diesel fuel oil, is required to be within limits when the associated DG is required to be OPERABLE. ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem (s) governed by separate Condition entry and application of associated Required Actions. A.1 and B.1
,o With one or more required DGs with fuel oil level in the
( associated day fuel oil storage tanks < 22,650 gallons per required DG and a 17,000 gallons per required DG and the fuel oil level in the main fuel oil storage tank 2 20,850 gallons per required DG, the approximate 7 day fuel oil supply for a required DG is not available. However, Condition A is restricted to fuel oil level reductions that maintain at least an approximate 6 day supply (at least an approximate 3 day supply is available in the required day i fuel oil storage tanks and an approximate 3 day supply is I available in the main fuel oil storage tank). With one or more required DGs with fuel oil level in the main fuel oil storage tank < 20,850 gallons per required DG and a 13,900 gallons per required DG and the fuel oil level in the required day fuel oil storage tank (s) 2 22,650 gallons per required DG, the approximate 7 day fuel oil supply for a required DG is not available. However, Condition B is restricted to fuel oil level reductions that maintain at least an approximate 6 day supply (at least an approximate 2 day supply is available in the main fuel oil storage tank and an approximate 4 day supply is available in , the required day fuel oil storage tanks (s)). (continued) (J Brunswick Unit 1 B 3.8-40 Revision No. j l
L Diesel Fuel Oil B 3.8.3 , BASES ACTIONS A.1 and B.1 (continued) These circumstances may be caused by events such as:
- a. Full load operation required for an inadvertent start while at minimum required level; or
- b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
These restrictions (Required Actions A.1 and B.1) allow sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity (2: approximately 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. O O u This Condition is entered as a result of a failure to meet the acceptance criterion for particulate. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling), I contaminated sampling equipment, and errors in laboratory 1 analysis can produce failures that do not follow a trend. !' Since the presence of particulate does not mean failure of the fuel oil to burn properly in the diesel engine, since particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and since proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inegrable. The 7 day Completion Time allows for further evaluation, resampling, and re-analysis of the DG fuel oil. (continued) D V Brunswick Unit 1 B 3.8-41 Revision No.
Diesel Fuel Oil B 3.8.3 BASES ACTIONS M (continued) With a Required Action and associated Completion Time of Condition A, B, or C not met, or the stored diesel fuel oil not within limits for reasons other than addressed by Conditions A, B, or C, the associated DG may be incapable of perfoming its intended function and must be immediately declared inoperable. SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DG's operation for approximately 7 days at rated load. The approximate 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location. For the purposes of this SR, the verification of the main fuel oil storage tank fuel oil volume is performed on a per DG basis. This per DG volume is obtained using the following equation: A N,a _
+U, h!
; where M, -
measured fuel oil volume of the main fuel oil storage tank, U, - unusable fuel oil volume of the main i fuel oil storage tank, and N,o
- number of DGs required to be OPERABLE.
The results from this equation must be a: 20,850 gallons in order to satisfy the acceptance criteria of SR 3.8.3.1.b. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period. (continued) Brunswick Unit 1 B 3.8-42 Revision No. I a l I __-_____-______-________ - w
i Diesel Fuel Oil B 3.8.3 BASES SURVEILLANCE- SR 3.8.3.2 REQUIREMENTS-Once per 92 days, the stored fuel oil is sampled in accordance with ASTM D4057-88, (Ref. 7) and analyzed to establish that the viscosity limits specified in Table-1 of l - ASTM 0975-88 (Ref 7) are met for stored' fuel oil. The 92-day perted is acceptable because fuel oil viscosity, even if it was not within stated limits, would not-have an immediate effect on DG operation. This Surveillance, in $s combination with the fuel oil delivery certificate of compliance, ensures the availability of high quality fuel oil for the DGs. Fuel oil degradation during long term storage shows up as an increase in particulate, mostly due to oxidation. The presence of particulate does not mean that the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure. Particulate concentrations should be determined in accordance with ASTM D2276-89 (Ref. 7), Method A3. This method involves a gravimetric determination of total O particulate concentration in the fuel oil and has a limit of 10 mg/1. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. For the BNP design, the total volume of stored fuel oil is contained in more than two interconnected tanks. Therefore, each tank must-be considered and tested separately. The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals. The acceptability of new diesel fuel oil is verified by the use of a certificate of compliance provided by the diesel fuel oil supplier for each new fuel oil delivery. The certificate of compliance includes certification of each of the ASTM 2-D fuel oil properties included in Table 1 of ASTM
', D975-88 (Ref. 7) and API gravity are within required limits.
Therefore, the acceptability of new fuel oil for use prior to addition to the storage tanks is determined by verifying that the new fuel oil has not become contaminated with other products during transit, thus altering the quality of the (continued) O i Brunswick Unit 1 B 3.8 Revision No. l
Diesel Fuel Oil B 3.8.3 BASES SURVEILLANCE SR 3.8.3.2 -(continued) REQUIREMENTS fuel oil. This ensures new fue1~ oil quality is maintained consistent with that identified in the certificate of compliance. Once the verification is satisfactorily A-completed, the fuel oil may be added to the storage tanks 2 without concern for contaminating the entire volume of fuel oil in the storaga tanks. Failure to determine the acceptability of the new diesel fuel oil.is cause for. rejecting the new fuel oil, but does not represent a failure to meet the LCO since the fuel oil is not added to the storage tanks. SR 3.8.3.3 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel storage tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the ( most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel ' oil by bacteria. Frequent checking , for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance. The presence of water does not necessarily ! represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance. REFERENCES 1. UFSAR, Section 8.3.1.1.6.2.8. r
- 2. Regulatory Guide 1.137, January 1978.
- 3. UFSAR, Section 1.8.
- 4. UFSAR, Chapter 6.
(continued)- O g Brunswick Unit 1 B 3.8-44 Revision No. I:
Diesel Fuel Oil B 3.8.3-BASES j REFERENCES 5. UFSAR, Chapter 15. (continued)
- 6. 10 CFR 50.36(c)(2)(ii).
- 7. ASTM Standards: 04057-88; D975-88; and D2276-89.
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.Q Brunswick Unit 1 B 3.8-45 Revision No.
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DC S:urces-Operating B 3.8.4
-B'3.8 ELECTRICAL POWER. SYSTEMS B 3.8.4 DC Sources-Operating BASES BACKGROUND The DC electrical power system provides the AC emergency
-power system with control power. It also provides both motive and control' power to selected safety related I equipment.. Also, these DC subsystems provide a source of uninterruptible power to AC vital' buses. As required by design bases in UFSAR Section 8.3.2.1.1 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety. functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Safety Guide 6 (Ref. 2).
The DC power sources provide both motive and control power to selected safety related equipment, as well as power for circuit breaker control, relay operation, plant annunciation, and emergency lighting. There are two independent divisions per unit, designated Division I and Division II. Each division consists of a 250 VDC battery O center tapped to form two 125 VDC batteries. Each 125 VDC battery has an associated full capacity battery charger. The chargers are supplied from the same AC load groups for which the associated DC subsystem supplies the control power. During normal operation, the DC loads are powered from the battery chargers with the batteries floeting' on the system. In case of loss of normal power to the battery charger, the j DC loads are automatically powered from the station i batteries. The DC power distribution system is described in more detail in Bases for LC0 3.8.7, " Distribution System-Operating," and LCO 3.8.8, " Distribution System-Shutdown." Esch battery has adequate storage capacity to carry the required load continuously for I hour. l (continued) O ' l Brunswick Unit ~1 .
.B 3.8-46 Revision No.
l b DC S:urces-Operating B 3.A.4 BASES , BACKGROUND Each DC battery subsystem (division) is separately housed in (continued) a battery room with its associsted chargers and main DC distribution switchboard. This arrangement provides complete separation and isolation of the redundant DC subsystems to ensure that a single failure in one' subsystem does not cause a failure in a redundant subsystem. The batteries for DC electrical power subsysters are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The minimum design voltage limit is 105/210 V. Each battery charger of DC electrical power subsystem has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each station service battery charger has sufficient capacity to restore the battery from the design minimum charge to its fully charged state in approximately 8 hours while supplying normal steady state loads (Ref. 3). A description of the Unit 2 DC power sources is provided in O the Bases for Unit 2 LC0 3.8.4, "DC Sources-0perating". APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5), assume that Engineered Safety Feature (ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation. The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining DC sources OPERABLE during accident conditions in the event of:
- a. An assumed loss of all offsite AC power; and
- b. A worst case single failure.
The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 6). (continued) O Brunswick Unit B 3.8-47 Revision No.
DC S:urces-Operating B 3.8.4
. BASES _ (continued)
LCO The Unit 1 Division-I and Division II DC electrical power subsystems, with each DC subsystem consisting of two 125 Y batteries (Batteries IA-1 and 1A-2 for'Divisi_on I and 1 Batteries 18-1 and IB-2 for Division II), two battery l chargers (one per battery) and the corresponding control equipment and interconnecting cabling supplying power to the associated bus are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after at anticipated operational occurrence (A00) or a postulated DSA. In addition, DC control power for operation of two of the four 4.16 kV emergency buses and two of the four 480 V emergency buses, as well as control power for two of the four DGs, is provided by the Unit 2 DC electrical power subsystems. Therefore, Unit 2 Division I and Division II DC electrical power subsystems are also required to be OPERABLE. Unit 2 DC electrical power subsystem OPERABILITY requirements are the same as those required for a Unit 1 DC electrical power subsystem. Loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 1).
/?ollCABILITY The DC electrical power sources are reca b d to be OPERABLE in MODES 1, 2, and 3 to ensure safe unit operation and to ensure that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
- b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in
- the event of a postulated DBA.
The DC electrical power requirements for MODES 4 and 5 and other conditions in which the DC electrical power sources are required are addressed in LCO 3.8.5, "DC Sources-Shutdown." ACTIONS Ad Pursuant to LCO 3.0.6, the Distribution Systems-Operating ACTIONS would not be entered even,if the DC electrical power subsystem inoperability resulted.in de-energization of an AC
- t. electrical power distribution subsystem or a DC electrical (continued)
Brunswick Unit 1- B 3.8-48 Revision No.
DC Sources-0perating B 3.8.4 O~ BASES U ACTIONS A d (continued) power distribution subsystem. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when condition A results in de-energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem, Actions of LCO 3.8.7 must be immediately entered. This allows Condition A to provide requirements for the loss of a DC electrical power subsystem without regard to whether a distribution subsystem is de-energized. LC0 3.8.7 provides the appropriate restriction for a de-energized distribution subsystem. Condition A represents one division with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is l therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division. If one of the required DC electrical power subsystems is inoperable (e.g., inoperable battery, inoperable battery charger (s), or inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could,'however, result in the loss of minimum necessary DC electrical subsystems to mitigate a , worst case accident, continued power operation should not l l- exceed 7 days. The Completion time is based on the capacity ) and capability of the remaining DC Sources, including the enhanced reliability afforded by the capability to manually transfer DC loads to the opposite unit's DC electrical power distribution subsystems. B.1 and B,2 If the DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time or if two or more DC electrical power subsystems are inoperable, the unit must be brought to a MODE in which the LC0 does not l apply. To achieve this status, the unit must be brought to ' at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, (continued) h U Brunswick Unit 1 B 3.0-49 Revision No.
u DC Sources-Operating B 3.8.4
. BASES ACTIONS B.1 and B.2 (continued) based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).
SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for l the batteries helps to ensure the effectiveness of the l charging system and the ability of the batteries to perform I their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state. The voltage l requirements are based on the nominal design voltage of the battery. The 7 day Frequency is conservative when compared with manufacturer recommendations and IEEE-450 (Ref. 8). ; SR 3.8.4.2 Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each inter-cell and inter-rack connection, provides an indication of physical damage or abnormal deterioration that could k potentially degrade battery performance. The connection resistance limits are s 1.2 times the established benchmark resistance values for the connections A or s Spohes above the established benchmark resistance m values for the connections, whichever is higher. There connection resistance acceptance criteria were derived from L IEEE-450 (Ref. 8) and IEEE-484 (Ref. 9), respectively. The Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days. This Frequency is consistent with j manufacturers recommendations. (continued) Brunswick Unit l' B 3.8-50 Revision Nc.
DC S::urces-Operating B 3.8.4
>* BASES SURVEILLANCE SR 3.8.4.3 REQUIREMENTS (continued) Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of physical damage or deterioration does not necessarily represent a failure of this SR, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function).
The 18 month Frequency for the Surveillance is based on engineering judgement. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.8.4.4 Visual inspection of inter-cell and inter-rack connections b provides an indication of physical damage or abnormal deterioration that could indicate degraded battery O condition. The anti-corrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to' require removal of and inspection under each terminal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance, t The 18 month Frequency for the Surveillance is based on engineering judgement. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. L SB 3.8.4.5 Battery charger capability requirements are derived from the design capacity of the chargers. According to Reference 3, the battery charger supply is required to be based on the (continuedl Brunswick' Unit 1 B 3.8-51 Revision No.
DC S:urces-Op rating B 3.8.4 O BASES V
-SURVEILLANCE SR 3.8.4.5 (continued)
REQUIREMENTS largest combined demands of the various steady state loads ed the charging capacity to restore the battery from the design minimum charge state to the fully charged state, under any load condition. The minimum required amperes and duration ensures that these requirements can be satisfied. The Frequency is acceptable, given battery charger reliability and the other administrative controls existing to ensure adequate charger performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths. SR 3.8.4.6 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference 10. d ( The Frequency of 24 months is acceptable, given unit conditions required to perform the test and the other requirements existing to ensure adequate battery performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
. This SR is modified by three Notes. Note 1 allows the performance of a modified performance discharge test in lieu h
of a service test once per 60 months. This substitution is acceptable because a modified performance discharge test represents a more severe test of battery capacity than SR 3.8.4.6. The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, both Unit 1 and Unit 2 DC electrical power subsystems are required to supply 8, power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the potential consequences associated with removing a required DC electrical power subsystem from service during the (continued) gy Brunswick Unit 1 B 3.8-52 Revision No. l
.l:
DC S:urces-Operating B 3.8.4 { BASES SURVEILLANCE- -SR 3.8.4.6 (continued) - REQUIREMENTS performance of this Surveillance, reducs consequences of a potential perturbation to the electrical distribution systems'during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both. units to perform this Surveillance, Note 2 only precludes satisfying this A Surveillance for the Unit 1 DC electrical power subsystems QA when Unit 1 is in MODE.1 or.2. During the performance.of this Surveillance with Unit I not in MODE 1 or 2 and with Unit 2 in MODE 1, 2, or 3;-the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required DC electrical power subsystem or other supported Technical Specification equipment is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy the Surveillance. To minimize testing, Note 3 allows a single , test (instead of two tests, one for each unit) to satisfy l the requirements for.both units. This is allowed since the main purpose of the test can be met by performing the test i on a single unit. If a DC electrical power subsystem fails the Surveillance, the DC. electrical power subsystem should ; O be considered inoperable for both units. ' SR 3.8.4.7 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage. A battery modified performance discharge test is a simulated duty cycle consisting of just two rates; the one minute rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance discharge test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by v rated one _ minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. (continued) O Brunswick Unit.1 B 3.8-53 Revision flo. l L-1 _ __ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _i
l DC Scurces-Opsrating B 3.8.4 BASES SURVEILLANCE SR 3.8.4'.7. (continued) REQUIREMENTS The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in.the battery performance discharge test for the duration of time equ:.1 to that of the performance discharge test. A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical j period of the load duty cycle, in addition to determining ! its percentage of rated capacity. Initial conditions for 4 the modified performance discharge test should be identical to those specified for a performance discharge test. Either the battery performance discharge test or the modified l performance discharge test is acceptable for satisfying l SR 3.8.4.7; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.7 while satisfying the requirements of SR 3.8.4.6 at the same time. The acceptance criteria for this Surveillance is consistent j with IEEE-450 (Ref. 8) and IEEE-485 (Ref.11). These references recommend that the battery be replaced if its d capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration l is increasing, even if there is' ample capacity to meet the load requirements. 'I The Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% l of its expected life and capacity is < 100% of the ; manufacturer's rating, the Surveillance Frequency is reduced ' L to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance ! Frequency is only reduced to 24 months for batteries that retain capacity 2: 100% of the manufacturer's rating. 4 Degradation is indicated, according to IEEE-450 (Ref. 8), when the battery capacity drops by more than 10% relative to ; its capacity on the previous performance test or when it is l 10% below the manufacturer's rating. The 60 month Frequency
, is consistent with the recommendations in IEEE-450 (Ref. 8).
l The 12 month and 24 month Frequencies are derived from the recommendations in IEEE-450 (Ref. 8). (continued) O Brunswick Unit'1 B 3.8-54 Revision No.
DC Sources-Operating B 3.8.4 O J BASES SURVEILLANCE SR 3.8.4.7 (continued) ) REQUIREMENTS This SR is modified by two Notes. The reason for Note 1 is that performing the Surveillance would remove.a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety. I systems. Due to the shared configuration of certain systems 1 (required to mitigate DBAs and transients) between~BNP Units 1 and 2, both Unit I and Unit 2 DC electrical power i subsystems are required to supply power to these systems I when either one or both units are in MODE 1, 2, or 3. In order to reduce the potential consequences associated with removing a required DC electrical power subsystem from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical k distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to-perform this Surveillance, Note 1 only precludes satisfying this Surveillance for the Unit 1 DC electrical power subsystems when Unit 1 is in MODE 1 or 2. During the performance of this Surveillance with Unit I not in MODE 1 or 2 and with Unit 2 in MODE 1, 2, or 3; the applicable O ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required DC electrical power subsystem or other supported Technical Specification equipment is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned evenu that satisfy the Surveillance. To minimize testing, Note 2 alloc a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the test can be met by performing the test d on a single unit. If a DC electrical power subsystem fails the Surveillance, the DC electrical power subsystem should be considered inoperable for both units. REFERENCES 1. UFSAR, Section 8.3.2.1.1.
- 2. Safety Guide 6. )
- 3. UFSAR, Section 8.3.2.1.2.
- 4. UFSAR, Chapter 6.
- 5. UFSAR, Chapter 15.
(continued) Brunswick Unit 1 - B 3.8-55 Revision No. i 1 I
i ( DC S:urces-Operating B 3.8.4 BASES REFERENCES 6. 10 CFR 50.36(c)(2)(ii). (continued)
- 7. Regulatory Guide 1.93, December 1974.
- 8. IEEE Standard 450, 1987.
- 9. IEEE Standard 484, 1996.
i
- 10. UFSAR, Section 8.3.2. b
- 11. IEEE Standard 485, 1983.
10 V I 1
. Brunswick Unit-1 B 3.8-56 Revision No. j l
_ _ _ _ = _ _ _ _ _ _ =
l l DC S:urces-Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS I B 3.8.5 DC Sources-Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LC0 3.8.4, "0C Sources-Operating." l APPLICABLE The initial. conditions of Design Basis Accident and j i SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and l Chapter 15 (Ref. 2), assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel genera +w (DGs), emergency auxiliaries, and control . and switching curing all MODES of operation and during I movement of irradiated fuel assemblies in the secondary 1 containment. j The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. The OPERABILITY of the minimum DC electrical power sources V during MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment ensures that:
- a. The facility can be maintained in the shutdown or refueling condition for extended periods;
- b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
- c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident.
The DC sources satisfy Criterion 3 af 10 CFR 50.36(c)(2)(ii) (Ref. 3). LCD The Unit'l DC electrical power subsystems each consisting of two 125 V batteries in series, two battery chargers (one per i battery), and the corresponding control equipment and . interconnecting cabling supplying power to the associated I (') (continued) l Q 1 Brunswick Unit 1 B 3.8-57 Revision No. l =_-_: _ _ _ _ _ _ _ _ _ - - - -
DC S:urces-Shutdown B 3.8.5 O U BASES LC0 bus, needed to support required DC distribution subsystems ! (continued) required OPERABLE by LCO 3.8.8, " Distribution Systems-Shutdown," .are required to be OPERABLE. In addition, DC control power for operation of two of the four 4.16 kV emergency buses and two of the four 480 V emergency buses, as well as control power for two of the four DGs, is l provided by the Unit 2 DC electrical power subsystems. Therefore, the Unit 2 DC electrical power subsystems needed to support required components are also required to be i OPERABLE. Unit 2 DC electrical power subsystem OPERABILITY requirements are the same as those required for a Unit 1 DC electrical power subsystem. This requirement ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and inadvertent reactor vessel drafndown). APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment provide assurance that:
' a. Required features to provide adequate coolant i
inventory makeup are available for the irradiated fuel assemblies in the core in case of an inadvertent draindown of the reactor vessel;
- b. Required features needed to mitigate a fuel handling accident are available;.
- c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
- d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.4. (continued) I Brunswick Unit 1 B 3.8-58 Revision No. L u
- . DC Sources-Shutdown l l B 3.8.5 l l
BASES (continued) II ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5.. However, since~ irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have 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. Entering LCO 3.0.3, while in MODE-1, 2, or 3, _
l would require the unit to be shutdown, but would not require l immediate suspension of, movement of irradiated fuel A assemblies. The Note to the ACTIONS, "LCO 3.0.3 is not J^ applicable," ensures that the actions for immediate suspension of irradiated fuel assembly movement are not l postponed due to entry into LCO 3.0.3. l A.I. A.2.1. A.2.2. A.2.3. and A.2.4 L l If more than one DC distribution subsystem is required according to LCO 3.8.8, the DC electrical pc.ver subsystems
- remaining.0PERABLE with one or more DC electrical power subsystems inoperable may be capable of supporting sufficient required features to allow continuation of CORE iO ALTERATIONS, fuel movement, and operations with a potential for draining the reactor vessel. By allowance of the option to declare required features inoperable with associated DC electrical power subsystem (s) inoperable, appropriate restrictions are implemented in accordance with the affected system LCOs' ACTIONS. Howner, in many instances, this
( aption may involve undesired administrative efforts. [. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, j and any activities that could result in inadvertent draining l [ of the reactor vessel). l Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. 1. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to_ continue this action until restoration is 1 accomplished in order to provide the necessary DC electrical ! power to the plant-safety systems. (continued) , i O . l Brunswick Unit 1.. B 3.8-59 Revision No.
-___--:s _.aa--------1,-----,---,---a..-----. --_---,2--.---.---,.---------_--------.-_--.--1.--- - - - - - - . - - - - - -- - - - - - - - - - - - - - - - - m -.- - --.------a --_.---
l DC Sturces-Shutdown B 3.8.5 BASES ACTIONS A.I. A.2.1. A.2.2. A.2.3. and A.2.4 (continued) The Completion Time of immediately is consistent with the l required times for actions requiring prompt attention. The J restoration of the required DC electrical power subsystems l should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power. i SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires certain Surveillance required by f l LCO 3.8.4 to be met. Therefore, see the corresponding Bases ! for LCO 3.8.4 for a discussion of each SR. This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not q required unless Unit 2 Specification 3.8.4, "DC y Sources-Operating," requires performance of these SRs. When Unit 2 Specification 3.8.4 requires performance of these SRs, DC source availability is not limited, due to the 8 Unit 2 requirements for DC source OPERABILITY. Therefore, in this condition, other DC sources would be available to supply the required loads. I REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
l f3 O Brunswick Unit 1 B 3.8-60 Revision No. l
1 Battery Cell Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Cell Parameters 3ASES BACKGROUND This LC0 delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC electrical power subsystems batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources-Operating," and LCO 3.8.5, "DC Sources-Shutdown." APPLICABLE The initial conditions of Design Basis Accident (DBA) and ! SAFETY ANALYSES transient analyses in UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature systems are OPERABLE. The DC electrical power subsystems provide normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control ' and switching during all MODES of operation. The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based O upon meeting the design basis of the unit as discussed in the Bases for LCO 3.8.4 and LC0 3.8.5. Since battery cell parameters support the operation of the DC electrical powar subsystems, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). LC0 Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Electrolyte limits are conservatively established, allowing continued DC electrical system function even with Category A and B limits not met. ! APPLICABILITY The battery cell parameters are required solely for the support of the associated DC electrical power subsystem. , . Therefore, these cell parameters are only required when the associated DC electrical power subsystem is required to be l OPERABLE. Refer to the Applicability discussions in Bases for LCO 3.8.4 and LCO 3.8.5. L (continued) Brunswick Unit 1 B 3.8-61 Revision No.
Battery Cell Parameters B 3.8.6 BASES (continued) ACTIONS The ACTIONS Table is modified by a Note indicating that a separate Condition entry is allowed for each battery. This is acceptable, since the Required Actions for each condition provide appropriate compensatory actions for each battery with battery cell parameters not within limits. Complying with the Required Actions may allow for continued operation, and subsequent batteries with battery cell parameters not within limits are governed by subsequent Condition entry and application of associated Required Actions. A.I. A.2, and A.3 With parameters of one or more cells in one or more batteries not within limits (i.e., Category A limits not met or Category B limits not met, or Category A and B limits not met) but within the Category C limits specified in Table 3.8.6-1, the battery is degraded but there is still sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of Category A or 8 limits not met, and continued operation is permitted for a limited period. The pilot cell (s) electrolyte level and float voltage are required to be verified to meet the Category C limits within I hour (Required Action A.1). This check provides a quick indication of the status of the remainder of the battery cells. One hour provides time to inspect the electrolyte level and to confirm the float voltage of the pilot cell (s). One hour is considered a reasonable amount of time to perform the required verification. Verification that the Category C limits are met (Required Action A.2) provides assurance that during the time needed to restore the parameters to the Category A and B iimits, the battery is still capable of performing its intended function. A period of 24 hours is allowed to complete the initial verification because specific gravity measurements must be obtained for each connected cell. Taking intc consideration both the time required to perform the required verification and the assurance that the battery cell parameters are not severely degraded, this time is considered reasonable. The verification is repeated at (continued) O Brunswick Unit 1 8 3.8-62 Revision No.
Battery Cell Parameters B 3.8.6 BASES- , ACTIONS A.I. A.2. and A.3 (continued) 7 day intervals until the parameters are. restored to Category A and B limits. This periodic verification is consistent with the normal Frequency of pilot cell Surve111ances. Continued operation prior to declaring the affected batteries inoperable is permitted for 31 days- before battery cell parameters must be restored to within Category A and B limits. Taking into consideration that, while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable for operation prior to declaring the DC batteries
' inoperable.
fld When any battery parameter is outside the Category C limit for any connected cell, sufficient capacity to supply the , maximum expected load requirement is not ensured and the O corresponding DC electrical power subsystem must be declared inoperable. Additionally, other potentially extreme conditions, such as any Required Action of Condition A and associated Completion Time not met or average electrolyte temperature of representative cells < 60*F, also are cause for immediately declaring the associated DC electrical power subsystem inoperable. SURVEILLANCE SR 3.8.6.1 REQUIREMENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 4), which recommends regular battery inspections (at least one per month) including voltage, specific gravity, and electrolyte temperature of pilot cells. SR 3.8.6.2 l The quarterly inspection of specific gravity and voltage is consistent with IEEE-450 (Ref. 4). l~ . . _ (continued) Brunswick Unit 1.- B 3.8-63 Revision No. ! l i
Battery Cell Parameters B 3.8.6
/ BASES , C)'
SURVEILLANCE SR 3.8.64 REQUIREMENTS (continued) This Surveillance verification that the average temperature l of representative cells is within limits is consistent with a recommendation of IEEE-450 (Ref. 4) that states that the l temperature of electrolytes in representative cells should be determined on a quarterly basis. Lower than normal temperatures act to inhibit or reduce battery capacity. This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on manufacturer's recommendations and the battery sizing calculations. Table 3.8.6-1 This Table delineates the limits on electrolyte level, float voltage, and specific gravity for three different categories. The meaning of each category is discussed below, j p Category A defines the normal parameter limit for each
- i designed pilot cell in each battery. The cells selected as U pilot cells are those whose temperature, voltage, and electrolyte specific gravity approximate the state of charge of the entire battery.
J The Category A limits specified for electrolyte level are based on manufacturer's recommendations and are consistent with the guidance in IEEE-450 (Ref. 4), with the extra i inch allowance above the high water level indication for operating margin to account for temperature and charge effects. In addition to this allowance, Footnote (a) to Table 3.8.6-1 permits the electrolyte level to be temporarily above the specified maxim.9 level during and following equalizing charge (i.e., for up to 3 days following the completion of an equalize charge), provided it is not overflowing. These limits ensure that the plates suffer no physical damage, and that adequate electron transfer capability is maintained in the event of transient conditions. IEEE-450 (Ref. 4) recommends that electrolyte l level readings should be made only after the battery has been at float charge for at least 72 hours. (continued) g Li Brunswick Unit 1 B 3.8-64 Revision No.
Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE Table 3.8.6-1 (continued) REQUIREMENTS The Category A limit specified for float voltage is a 2.13 Y
.per cell. This value is based on the manufacturer's recossendations and on the recommendation of IEEE-450 (Ref. 4), which states that prolonged operation of cells below 2.13 Y can reduce the life expectancy of cells. The Category A limit specified for specific gravity for each pilot cell is a 1.200 (0.015 below the manufacturer's fully charged nominal specific gravity or a battery charging current that had stabilized at a low value). This value is characteristic of a charged cell with adequate capacity.
According to IEEE-450 (Ref. 4), the specific gravity readings are based on a temperature of 77'F (25*C). The specific gravity readings : e corrected for actual electrolyte temperature and level. For each 3*F (1.67'C) above 77'F (25'C), I point (0.001) is added to the reading; I point is subtracted for each 3*F below~77'F. The specific gravity of the electrolyte in a cell increases with a loss of water due to electrolysis or evaporation. Level correction will be in accordance with manufacturer's recommendations. Category B defines the normal parameter limits for each connected cell. The term " connected cell" excludes any battery cell that may be jumpered out. The Category B limits specified for electrolyte level and float voltage are the same as those specified for Category A and have been discussed above. The Category B limit specified for specific yavity for each connected cell is 2 1.195 (0.020 below the manufacturer's fully charged, nominal specific gravity) with the average of all connected l' cells a 1.205 (0.010 below the manufacturer's fully charged, nominal specific gravity). These values are based on manufacturer's recommendations. The minimum specific , gravity value required for each cell ensures that a cell with a marginal or unacceptable specific gravity is_ not masked by averaging cells having higher specific gravities. Category C defines the limits for each connected cell. These values, although reduced, provide assurance that l sufficient capacity exists te perform the intended function (continued) Brioswick Unit 1 B 3.8-65 Revision No.
Battery Cell Parameters B 3.8.6 BASES l l SURVEILLANCE Table 3.8.6-1 (continued) REQUIREMENTS and maintain a margin of safety. When any battery parameter is outside the Category C limits, the assurance of sufficient capacity described above no longer exists, and the battery must be declared inoperable. The Category C limit specified for electrolyte level (above the top of the plates and not overflowing) . ensures that the plates suffer no physical damage and maintain adequate electron transfer capability. The Category C limit for voltage is based on IEEE-450, Appendix C (Ref. 4), which l states that a cell voltage of 2.07 Y or below, under float conditions and not caused by elevated temperature of the cell, indicates internal cell problems and may require cell , replacement. The Category C limit on average specific gravity 2: 1.195, is based on manufacturer's recommendations (0.020 below the manufacturer's recommended fully charged, nominal specific gravity). In addition to that limit, it is required that the specific gravity for each connected cell must be no less than 0.020 below the average of all connected cells. This O. . limit ensures that a cell with a marginal or unacceptable specific gravity is not masked by averaging with cells having higher specific gravities. The footnotes to Table 3.8.6-1 that apply to specific gravity are applicable to Category A, B, and C specific gravity. Footnote (b) requires the above mentioned correction for electrolyte level and temperature, with the exception that level correction is not required when battery charging current, while on float charge, is < 2 amps. This current provides, in general, an indication of acceptable overall battery condition. Because of specific gravity gradients that are produced l during the recharging process, delays of several days may ! occur while waiting for the specific gravity to stabilize. l A stabilized charging current is an acceptable alternative to specific gravity measurement for determining the state of , charge of the designated pilot cell. This phenomenon is l discussed in IEEE-450 (Ref. 4). Footnote (c) allows the ; float charge current-to-be used as an alternate to specific
. (continued)
-O l Brunswick Unit-1 ~ B 3.8-66 Revision'No.
Battsry Cell Parametcrs B 3.8.6 BASES SURVEILLANCE Table 3.8.6_1. (continued) REQUIREMENTS gravity for up to 7 days following a battery recharge. Within 7 days, each connected cell's specific. gravity must be measured to confirm the state of charge.- Following a minor battery recharge (such as equalizing charge that does not follow a deep discharge) specific gravity gradients are not significant, and confirming measurements may be made in less than 7 days. REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
- 4. IEEE Standard 450, 1987.
O f
- (.-
Brunswick Unit 1 B 3.8-67 Revision No. l
Distribution Systems-Op3 rating B 3.8.7 8 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Distribution Systems-Operating BASES BACKGROUND The onsite Class IE AC and DC electrical power distribution system is divided into redundant and independent AC and DC electrical power distribution subsystems. The Class IE AC electrical distribution system is divided into four load groups. Each load group consists of a
- primary emergency bus, its down::tream secondary emergency bus,120 VAC vital bus, and transformers and interconnecting cables. The buses associated with each of the four load groups are defined as follows:
Load group El consists of 4.16 kV bus El, 480 V bus E5, and 120 VAC vital bus IE5. Load group E2 consists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus IE6.
/m Load group E3 consists of 4.16 kV bus E3, 480 V b
bus E7, and 120 VAC vital bus 2E7. Load group E4 consists of 4.16 kV bus E4, 480 V bus E8, and 120 VAC vital bus 2E8. The El and E2 load groups are supplied from Unit 1 balance of plant (B0P) buses and primarily serve Unit 1 loads. The E3 and E4 load groups are supplied from Unit 2 B0P buses and primarily serve Unit 2 loads. In some instances _ loads associated with one unit are actually supplied from the opposite unit's load group buses. 3 Each primary emergency bus (4.16 kV emergency bas) has access to two offsite sources of power via a common circuit path from its associated upstream B0P bus (master / slave breakers and interconnecting cables). In addition, each 4.16 kV emergency bus can be provided power from an onsite diesel generator (DG) source. The upstream B0P bus associated with each 4.16 kV emergency bus is normally connected to the main generator output via the unit auxiliary transformer. During a loss of the normal _ power source to the 4.16 kV B0P bus, the preferred source supply breaker attempts to close.. If all offsite sources are (continued) Brunswick Unit 1 B 3.8-68 Revision No.
i Distribution Systems-Operating B 3.8.7 (] w/ BASES BACKGROUND (continued) unavailable, the affected 4.16 kV emergency bus is isolated from its associated upstream 4.16 kV B0P bus and the onsite Al) emergency DG will supaly power to the 4.16 kV emergency bus. Control power for eacii 4.16 kV emergency bus is supplied from a Class IE battery with manual transfer capability to another Class IE battery. Additional descriptions of this system may be found in the Bases for Specification 3.8.1, ;
"AC Sources-Operating," and the Bases for l Specification 3.8.4, "DC Sources-Operating". I The secondary plant distribution system includes 480 VAC emergency buses ES, E6, E7, and E8 and associated motor control centers (MCCs), transformers, and interconnecting cables. Secondary emergency buses ES, E6, E7, and E8 are g
supplied from primary emergency buses El, E2, E3, and E4, respectively. Control power for each 480 VAC emergency bus is supplied from a Class IE battery with manual transfer capability to another Class IE battery. Additional descriptions of this system may be found in the Bases for Specification 3.8.4, "DC Sources-Operating". The 120 VAC vital buses IES, IE6, 2E7, and 2E8 are arranged
.e in four load groups and are powered from secondary emergency Al buses ES, E6, E7, and E8, respectively.
There are two independent 125/250 VDC electrical power distribution subsystems. I The list of required distribution buses is presented in l Table B 3.8.7-1. - APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC and DC electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, " Power Distribution Limits"; Section 3.5, " Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System"; and Section 3.6, " Containment Systems." (continued) xd Brunswick Unit 1 B 3.8-69 Revision No. w_-__-_
i Distribution Systems-Operating B 3.8.7 l BASES
- APPLICABLE The OPERABILI11 of the AC and DC electrical power L SAFETY ANALYSES distribution subsystems is consistent with the initial l (continued)- assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining distribution systems OPERABLE during accident conditions in the event of
- a. An assumed loss of all offsite power; and
- b. A worst case single failure.
The AC and DC electrical power distribution system satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). LC0 The required electrical power distribution subsystems listed
-in Table B 3.8.7-1 ensure the availability of AC and DC electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an l
. anticipated operational occurrence (A00) or a postulated DBA. The Unit 1 AC and DC electrical power distribution subsystems are required to be OPERABLE. In addition, since some components required by Unit I receive power through I. Unit 2 DC electrical power distribution subsystems (e.g.,
control sower for two of the four 4.16 kV emergency buses, two of tie four 480 VAC emergency buses, and for two of the DGs, and two of four engineered safeguard system (ESS) panels), the Unit 2 DC electrical power distribution subsystems needed to support the required equipment must also be OPERABLE. As stated in Table B 3.8.7-1, each division of the AC and DC electrical power distribution systems is a subsystem. Maintaining the Division I and II AC and DC electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor. The AC electrical power distribution subsystems require the associated buses and electrical circuits to be energized to i their proper voltages. The DC electrical power distribution ' subsystems require the associated buses to be_ energized to their proper voltage from either the associated batteries or . chargers. (continued) Brunswick Unit'1- B 3.8-70 Revision No.
F Distribution Systems-Operating B 3.8.7
- BASES LCO Based on the number of safety significant electrical loads (continued) associated with each bus listed in Table B 3.8.7-1, if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LCO 3.8.7 is required. Other buses, such as McCs and distribution panels, which nelp comprise the AC and DC distribution-systems are not listed in Table B 3.8.7-1. The loss of electrical loads associated with these buses may not result in a complete loss of_a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in i
Table B 3.8.7-1 (e.g., a breaker supplying a single MCC ! fails open), the individual loads on the bus must be declared inoperabic, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., loss of a 4.16 kV emergency bus, which results in de-energization of all buses powered from the 4.16 kV emergency bus), then although the individual loads are still considered inoperable, the Conditions and kequired Actions of the LCO for the O individual loads are not required to be entered, since LCO 3.0.6 allows this exception (i.e., the loads are inoperable due to the inoperability of a support system governed by a Technical Specification; the 4.16 kV emergency bus). In addition, tie breakers and transfer switches between redundant safety related AC and DC power distribution subsystems, if they exist, must be open. This includes control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, which could cause the failure of a redundant subsystem and a loss of essential safety function (s). If any tie breakers are closed or transfer switches aligned to the alternate supply, the affected redundant electrical power distribution subsystems are considered inoperable. . This applies to the onsite, safety related, redundant electrical power distribution subsystems. It does not, however, preclude redundant J Class IE 4.16 kV emergency buses from being powered from the I same offsite circuit. (continued) l Brunswick Unit 1 B 3.8-71 Revision No.
Distribution Systems-Operating B 3.8.7 BASES (continued) APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
- b. Adequate core cooling is provided, and containment-OPERA 8ILITY and other vital functions are maintained in the event of a postulated DBA.
Electrical power distribution subsystem requirements for MODES 4 and 5 and other conditions in which AC and DC electrical power distribution subsystems are required are covered in the Bases for LCO 3.8.8, " Distribution
. Systems-Shutdown. "
ACTIONS &._]. b With one or more required AC buses or distribution panels in one division inoperable, the remaining AC electrical power distribution subsystems are capable of supporting the h O minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining AC electrical power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses and distribution panels must be restored to OPERABLE status within 8 hours. The Condition A worst scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit and restoring power to the affected division. The 8 hour time limit before requiring a unit shutdown in this Condition is acceptable because of: (continued) Brunswick Unit 1 B 3.8-72 Revision No. y
Distribution Systems-Operating B 3.8.7 (~ BASES ACTIONS L1 (continued)
- a. The potential for decreased safety if the unit operators' attention is d'"erted from the evaluations-and actions necessary to u tore power to the affected division to the actions associated with taking the unit to shutdown within this time limit,
- b. The low potential for an event. in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.11, " Safety Function Determination Program (SFDP).")
The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any h combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition.A is entered while, Yb for instani.e a DC bus is inoperable.and subsequently returned OPERABLE, this LC0 may already have been not met for up to 7 days. This situation could lead to a total O duration of 176 hours, since initial failure to meet the LCO, to restore the AC electrical power distribution system. At this time-a DC bus could again become inoperable, and the AC electrical power distribution system could be restored OPERABLE. This could continue indefinitely. This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This results in establishing the " time zero" at the time this LC0 was initially not met, instead of at the time Condition A was entered. The 176 hour Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely. B.I. B.2. B.3 and B.4 h With one or more DC electrical power distribution subsystems inoperable due to loss of normal DC source, the remaining DC electrical power distribution subsystem (s) are capable of supporting the minimum safety functions necessary to shutdown the reactor and maintain it in a safe shutdown - condition, provided safety function is not lost and assuming . no single failure. However, the overall reliability is W fcontinued) M Brunswick-Unit I- B 3.8-73 Revision No.
Distribution Systems-Operating B 3.8.7 BASES ACTIONS B.I. B.2. B.3 and B.4 (continued) reduced because a single failure in the DC electrical power distribution system could result in a loss of two of four AC electrical load groups and the minimum required ESF-functions not being supported. Therefore, action must be immediately initiated to transfer the DC electrical power distribution system to its alternate source and the.affected supported equipment immediately declared inoperable. Upon completion of the transfer of the affected supported equipment's DC electrical power distribution subsystem to its OPERABLE alternate DC source, the affected supported equipment may be declared OPERABLE again. The ESS logic cabinets transfer automatically upon loss of the normal source. For an iSS logic cabinet, verification that the automatic transfer has occurred and alternate power is available to the ESS logic cabinet will satisfy Required Action B.2. By allowance of the option to declare affected supported equipment inoperable with associated DC electrical power distribution subsystems inoperable due to loss of normal DC source, more conservative restrictions are implemented in accordance with the affected system LCOs' _c ACTICNS. When any control power transfer switch associated with the 4.lti kV and 480.-V emergency buses or any transfer. switch associated with the ESS and DG panels is transferred to the alternate source, a single failure in the DC system could render two of four AC electrical load groups inoperable. Therefore, to prevent indefinite operation in this degraded condition, power from the normal DC source must be restored in 7 days. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. Required Actions B.1 and 8.2 should be completed as quickly as possible. The 7 day Completion Time of Required Action B.4 is considered to be acceptable due to the low potential for an event in conjunction with a single failure h of a redundant component and is consistent with the allowed Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-Operating." The second Completion Time for Required Action B.4 establishes a limit on the maximum time allowed for. any h combination of required electrical power distribution subsystems to be inoperable during any single contiguous . occurrence of failing to meet the LCO. If Condition B is f (continued)
' Brunswick Unit 1 B 3.8-74 Revision No.
Distribution Systems-Op: rating B 3.8.7 1 BASES ACTIONS B.I. B.2. B.3 and B.4 (continued) b entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours. This situation could lead to a total duration of 176 hours, since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and tb DC electrical power distribution i system could be restored OPERABLE. lhis could continue indefinitely. This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
i This allowance results in establishing the " time zero" at l the time the LCO was initially not met, instead of at the time Condition B was entered. The 176 hour Completion Time is an acceptable limitation on this potential of failing to h' meet the LCO indefinitely. E.d b With one DC electrical power distribution subsystem inoperable for reasons other than Condition B, the remaining DC electrical power distribution subsystem is capable of h supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown . condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC electrical power distribution subsystem must be restored to OPERABLE status within 7 days by powering the bus from the associated 1 batteries or chargers. ' Condition C represents one division without adequate DC power, potentially with both the battery (s) significantly h degraded and the associated charger (s) nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division. (continued) Brunswick Unit 1 B 3.8-75 Revision No.
Distribution Systems-Operating B 3.8.7 BASES ACTIONS L 1 (continued)- b
.The 7 day Completion Time is consistent with the allowed-Completion Time for an inoperable DC electrical power I subsystem specified in Specification 3.8.4, "DC j Sources-Operating". Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 7 days, is acceptable because of:
- a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to ~
continue;
- b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division;
- c. The low potential for an event in conjunction with a single failure of a redundant component.
The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any b combination of required electrical power distribution sut, systems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is - entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been rot met for up to 8 hours. This situation could lead to a total duration of 176 hours, since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be restored OPERABLE. This could continue indefinitely. This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock." ,
This allowance results in establishing the " time zero"'at l the time the LCO was initially not met, instead of at the time Condition C was entered. The 176 hour Completion Time 1s an acceptable limitation on this potential of failing to h;l l meet the LCO indefinitely.
'(continuedi Brunswick Unit 1 B 3.8-76 Revision No.
)
Distribution Systens-Opsrating B 3.8.7 BASES ACTIONS . D.1 and D.2 b (continued) If the inoperable electrical power distribution subsystem (s) cannot be restored to OPERA 8LE status within the associated Completion Time, the unit must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and.to MODE 4 within 36 hours. 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. L1
$5 Condition E corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one AC or.DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the plant is in !
a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. ' LCO 3.0.3 must be entered immediately to commence a controlled shutdown. SURVEILLANCE SR 3.8.7.1 1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. This includes verifying that distribution bus tie breakers are open and control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels are aligned to their normal DC sources. The correct breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained, and power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for h l l motive as well as control functions for critical system l loads connected to these buses. This may be performed by
- verification of absence of low voltage alarms or by l verifying a load powered from the_ bus is operating. The
( (continued) ( . ll Brunswick Unit 1 B 3.8-77 Revision No.
Distribution Systems-Operating B 3.8.7 BASES SURVEILLANCE SR 3.8.7.1 (continued) REQUIREMENTS 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, and other indications available in the control room that l alert the operator to subsystem malfunctions. SR 3.8.7.2 This Surveillance verifies that no combination of more than two power conversion modules (consisting of either two lighting inverters or one lighting inverter and one plant uninterruptible power supply unit) are aligned to A Division II (bus B). Two power conversion modules aligned to Division II (bus B) was an initial assumption in the DC battery load study. Limiting two power conversion modules to be aligned to Division II ensures the associated batteries will supply DC power to safety related equipment during a design basis event. The 7 day Frequency takes into account the redundant capability of the DC electrical power distribution subsystems and indications available in the /a\ control room to alert the operator of power conversion F module misalignment. g REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
f)
' (/.
.' Brunswick Unit 1 B 3.8-78 Revision No.
Distribution Systems-0perating B 3.8.7 Table B 3.8.7-1 (page 1 of 1) \ AC and DC Electrical Power Distribution Systems TYPE VOLTAGE DIVISION I(a) DIVISION II(a) AC emergency 4160 V Emergency Buses Emergency Buses buses El, E3 E2, E4 480 V Emergency Buses Emergency Buses E5, E7 E6, E8 AC vital buses 120 V Distribution Distribution Panels Panels IES, 2E7 IE6, 2E8 DC buses 250 V Switchboard 1A Switchboard IB 125 V ESS logic ESS logic Cabinets Cabinets H58, H60 H59, H61 125 V DG Panels DG Panels DG-1, DG-3 DG-2, DG-4 DC control 125 V 4.16 kV Switchgear 4.16 kV Switchgear power buses El, E3 E2, E4 125 V 480 V s 480 V Switchgear Switchgear E5, E7 E6, E8 (a) Each division of the AC and DC electrical power distribution systems is a subsystem. O - Brunswick Unit 1 B 3.8-79 Revision No.
i Distribution Systems-Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Distribution Systems-Shutdown BASES I I II II Ill ll BACKGROUND A description of the AC and DC electrical power distribution system is provided in the Bases for LCO 3.8.7, " Distribution Systems-Operating." APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in.the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC and DC electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure l the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. The OPERABILITY of the AC and DC electrical power distribution system is consistent with the initial-assumptions of the accident analyses and the requirements O for the supported-systems' OPERABILITY. l l The OPERABILITY uf the minimum AC and DC electrical pcwer i sources and associated power distribution subsystems during l MODES 4 and 5, and during movement of irradiated fuel assemblies in the secondary containment ensures that:
- a. The facility can be maintained in the shutdown or refueling condition for extended periods; ,
- b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
- c. Adequate power is provided to mitigate events ;
postulated during shutdown, such as an inadvertent ' draindown of the vessel or a fuel handling accident. The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). (continued) O LBrunswick Unit 1 ' B 3.8-80 Revision No. b
r Distribution Systems-Shutdown B 3.8.8
-BASES (continued)
LCO Various combinations of subsystems, equipment, and components are-required OPERABLE by other LCOs, depending on
. the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of Technical Specifications required systems, equipment, and components-both specifically addressed by their own LCO, and implicitly required by the definition of OPERABILITY. In addition, DC control power for operation of two of the four 4.16 kV emergency buses and two of the four 480 V emergency buses, as well as control power for two of the four diesel
. generators, is provided by the Unit 2 DC electrical power l subsystems. Therefore, the Unit 2 DC electrical power l distribution subsystems needed to support required components are also required to be OPERABLE. -l
[ In additicn, it is acceptable for required buses to be l cross-tied during shutdown conditions, permitting a single-source to supply multiple redundant buses, provided the source is capable of maintaining proper frequency (if required) and voltage. O Maintaining these portions of the distribution system energized ensures the availability of sufficient power to i operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and inadvertent reactor vessel draindown). APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment provide assurance that:
- a. Systems to provide adequate coolant inventory makeup are available-for the irradiated fuel in the core in case of an inadvertent draindown of the reactor vessel;
- b. Systems needed to mitigate a fuel handling accident' are available; (continued)
O Brunswick Unit l~ B 3.8-81 Revision-No.
4 Distribution Systens-Shutdown l B 3.8.8 BASES APPLICABILITY c. Systems necessary to mitigate the effects of (continued) events that can lead to core damage during shutdown are available; and
- d. Instrumentation and control capability is available
.for monitoring and maintaining the unit in-a cold shutdown condition or refueling condition.
The AC and DC electrical power distribution subsystem requirements for MODES 1, 2, and 3 are covered in LC0 3.8.7. ACTIONS 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, the ACTIONS have 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. Entering LCO 3.0.3, while in MODE 1, 2, or 3, would require the unit to be shutdown, but would not require immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3.0.3 is not applicable," ensures that the actions for immediate g ( suspension of irradiated fuel assemoly movement are not postponed due to entry into LCO 3.0.3. A.I. A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 Although redundant required features may require redundant divisions of electrical power distribution subsystems to be OPERABLE,~one OPERABLE distribution subsystem division may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for draining the reactor vessel. By allowing the option to declare required features. associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected. distribution subsystem LCO's 4 Required Actions. In many instances this option may involve I undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made, (i.e., to i suspend CORE ALTERATIONS, movement of irradiated fuel I assemblies in the secondary containment, and any activities ; that could result 'in inadvertent draining of the reactor vessel). l, (continued) Brunswick Unit 1 B 3.8-82 Revision No. - l
' Distribution Systems-Shutdown 8 3.8.8 RASES ACTIONS A.I. A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 (continued) Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate ar.tlon to restore the required AC and DC electrical power distribution subsystems and to continue this action i until restoration is accomplished in order to provide the l necessary power to the plant safety systems. Notwithstanding performance of the above conservative Required Actions, a required residual heat removal-shutdown cooling (RHR-SDC) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LC0 3.0.6, the RHR-SDC ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR-SDC inoperable and not in operation, which results in taking the appropriate RHR-SDC ACTIONS. The Completion Time of immediately is consistent with the O required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power. SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution subsystems are functioning properly, with the correct breaker alignment. The correct breaker alignment ensures power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. This may be performed by verification of the absence of low voltage alarms or by verifying a load powered from the bus is operating. The 7 day Frequency takes into account the redundant capability of the electrical power distribution subsystems, as well as other indications available in the control room that alert the operator to subsystem malfunctions.
~
(continued) O Brunswick Unit 1 B 3.8-83 Revisicn No.
l Distribution Systens-Shutdown B 3.8.8 BASES (continued) REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
l O l l l' l l l l i l l ~ Brunswick Unit 1 B 3.8-84 Revision No. l ? l
t. l AC S:urces-Op* rating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS
- 2. 8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLC:
- a. Two I.init 2 qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Pcwer Distribution System;
- b. Four diesel generators (DGs); and
- c. Two Unit 1 qualified circuits between the offsite transmission network and the onsite Class IE AC Electrical Power Distribution System.
l APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITI6N REQUIRED ACTION COMPLETION TIME O A. ---------NOTE--------- A.1 Restore Unit 1 45 days Only Applicable when Unit 1 is in MODE 4 offsite circuit to OPERABLE status. g or 5. One Unit 1 offsite circuit inoperable. b B. One offsite circuit B.1 Perform SR 3.8.1.1 2 hours inoperable for reasons 'or OPERABLE offsite other than circuit (s). AND Condition A. Once per g 12 hours thereafter AND (continued) h (O Brunswick Unit 2 3.8-1 Amendment No.
1 l AC Scurces-Opsrating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Declare required 24 hours from discovery of no b feature (s) with no offsite power offsite power to available inoperable one 4.16 kV when the redundant emergency bus required feature (s) concurrent with t are inoperable. inoperability of redundant required feature (s) bhQ B.3 Restore offsite circuit to OPERABLE 72 hours b' status. AND 10 days from discovery of failure to meet LC0 3.8.1.a or b C. Que DG inoperable. C.1 Perform SR 3.8.1.1 for OPERABLE offsite 2 hours d circuit (s). AND Once per 12 hours thereafter AND C.2 Declare required 4 hours from A feature (s), supported discovery of by the inoperable DG, Condition C E inoperable when the concurrent with redundant required incperability of feature (s) are redundant inoperable. required feature (s) AND , (continued) h' hy)
-Brunswick Unit 2 3.8-2 Amendment No.
l n AC S:urcas-0perating 3.8.1 '
' ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.3.1 Detsemine OPERABLE 24 hours b DG(s) are not l inoperable due to common cause failure.
98 C.3.2 Perform SR 3.8.1.2 24 hours b for OPERABLE DG(s). 8ND C.4 Restore DG to OPERABLE status. 7 days b AND 10 days from discovery of failure to meet LCO 3.8.1.a or b D. Two or more offsite D.1 Declare required 12 hours from lb l circuits inuperable, feature (s) inoperable discovery of ' when the redundant required feature (s) Condition D concurrent with 8l are inoperable. inoperability of redunaant required feature (s) i AND D.2 Restore all but one offsite circuit to 24 hours A OPERABLE status. (continued)
\ _ ,'
Brunswick. Unit 2 3.8-3 Amendment No. I
AC S:urces-Operating ; 3.8.1 T ACTIONS (continued) (O CONDITION REQUIRED ACTION COMPLETION TIME E. One offsite circuit ------------NOTE------------- inoperable. Enter applicable Conditions and Required Actions of b MQ LCO 3.8.7, " Distribution Systems-Operating," when 1 One DG Inoperable. Condition E is entered with i no AC power source to any 4.16 kV emergency bus. E.1 Restore offsite circuit to OPERABLE 12 hours b status. QE E.2 Restore DG to 12 hours b, OPERABLE status. I F. Two or more DGs F.1 Restore all but one ? hours b inoperable. DG to OPERABLE status. G. Required Action and associated Completion G.1 Be in MODE 3. 12 hours b Time of Condition A, MQ B, C, D, E, or F not met. G.2 Be in MODE 4. 36 hours b (continued) lrx Brunswick Unit 2 3.8-4 Amendment No.
AC S:urces-0perating 3.8.1 fl ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME H. One or more offsite circuits and two or H.1 Enter LC0 3.0.3. Immediately b more DGs inoperable. 98 Two or more offsite circuits and one DG inoperable. A SURVEILLANCE REQUIREMENTS A SURVEILLANCE FREQUENCY n SR 3.8.1.1 Vertfy correct breaker alignment and 7 days indicated power availability for each (V) offsite circ.uit. (continued) l I I i l , o k_) Brunswick Unit 2 3.8-5 Amendment No. l 1 l
t AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.2 -------------------NOTES-------------------
- 1. All DG starts may be preceded by an engine prelube period. g
- 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.
- 3. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG starts from standby 31 days conditions and achieves steady state voltage a 3750 V and s 4300 V and frequency 2 58.8 Hz and s fd .2 Hz. (continued) O Brunswick Unit 2 3.8-6 Amendment No.
AC Sources-Operating 3.8.1 O SURVE!LLANCE REQUIREMENTS (continued) b SURVEILLANCE FREQUENCY SR 3.8.1.3 -------
-----------NOTES-------------------
- 1. DG loadings may include gradual loading.
- 2. Momentary transients outside the load range do not invalidate this test.
- 3. This Surveillance shall be conducted on only one DG at a time.
- 4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.
- 5. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG is synchronized and loaded 31 days O V and operates for 2 60 minutes at a load 2 2800 kW and s 3500 kW. SR 3.8.1.4 Verify each engine mounted tank contains 31 days a 150 gal of fuel oil. 1 SR 3.8.1.5 Check for and remove accumulated water from 31 days each engine mounted tank. SR 3.8.1.6 Verify the fuel oil transfer system 31 days /A\ operates to transfer fuel oil from the day fuel oil storage tank to the engine mounted tank. (continued) n v Brunswick Unit 2 3.8-7 Amendment No. 1 _ - 9
AC Scurces-Operating 3.8.1
. SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.8.1.7 -------------------NOTES-------------------
- 1. All DG starts may be preceded by an engine prelube period.
- 2. A single test at the specified frequency will satisfy this Surveillance for both units.
Verify each DG starts from r+andby 184 days condition and achieves, in s 10 seconds, voltage a 3750 V and frequency a 58.8 Hz, and after steady state conditions are reached, maintains voltage a 3750 V and s 4300 V and frequency 2 58.8 Hz and s 61.2 Hz. (continued) O i i l 'O Brunswick Unit 2 3.8-8 Amendment No.
AC Scurces-0p: rating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) _ SURVEILLANCE FREQUENCY SR 3.8.1.8 -------------------NOTES-------------------
- 1. SR 3.8.1.8.a shall not be performed in g
1 MODE 1 or 2 for the Unit 2 offsite circuits. However, credit may be g taken for unplanned events that satisfy this SR. I i
- 2. SR 3.8.1.8.a is not required to be met if the unit power supply is from l the preferred offsite circuit. '
- 3. A single test at the specified Frequency will satisfy this Surveillance for both units. 4 Verify: 24 months
- a. Automatic transfer capability of the unit power supply from the normal circuit to the preferred offsite circuit; and
- b. Manual transfer of the unit power supply from the preferred offsite circuit to the alternate offsite circuit.
(continued) l l l i i
./
t
\_.
Brunswick Unit 2 3.8-9 Amendment No.
AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) , SURVf WCE FREQUENCY SR 3.8.1.9 -------------------NOTES-------------------
- 1. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 3 b and DG 4. However, credit may be taken for unplanned events that g
satisfy this SR.
- 2. If performed with the DG synchronized I with offsite power, it shall be l
1 performed at a power factor s 0.9.
- 3. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG rejects a load greater than 24 months or equal to its associated core spray pump without tripping. (continued) O Brunswick Unit 2 3.8-10 Amendment No.
1 I 4 AC Scurces-Operating 3.8.1 l SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY SR 3.8.1.10 --------------------NOTE---------------- -- a A single test at the specified Frequency (D will satisfy this Surveillance for both units. Verify each DG's automatic trips are 24 months bypassed on an actual or simulated ECCS initiation signal except:
- a. Engine overspeed;
- b. Generator differential overcurrent;
- c. Low lube oil pressure;
- d. Reverse power;
- e. Loss of field; and i
- f. Phase overcurrent (voltage ,
restrained). l (continued) (VD Brunswick Unit 2 3.8-11 Amendment No.
I \ AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.11 -------------------NOTES-------------------
- 1. Momentary transients outside the load and power factor ranges do not invalidate this test.
- 2. A single test at the specified b
' frequency will satisfy this Surveillance for both units. l Verify each DG operating at a power factor 24 months l s 0.9 operates for a 60 minutes loaded to a 3500 kW and s 3850 kW. SR 3.8.1.12 -------------------NOTE-------------------- A single test at the specified frequency will satisfy this Surveillance for both units. Verify an actual or simulated ECCS 24 months initiation signal is capable of overriding the test mode feature to return each DG to ready-to-load operation. (continued) O Brunswick Unit 2 3.8-12 Amendment No.
AC Sources-0perating ( 3.8.1 l SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.13 -------------------NOTE-------------------- This Surveillance shall not be performed in MODE 1, 2, or 3 for the load sequence b ,' l relays associated with DG 3 and DG 4. However, credit maybe taken for unplanned g events that satisfy this SR. Verify interval between each sequenced load 24 months block is within i 10% of design interval for each load sequence relay. (continued) I O f i
,O JLJ l Brunswick Unit 2 3.8-13 Amendment No.
T AC Sources-Operating 3.8.1 (D SURVEIll;ANCE REQUIREMENTS (continued)
%) SURVEILLANCE FREQUENCY l
l SR 3.8.1.14 --------------------NOTES------------------- l 1. All DG starts may be preceded by an l engine prelube period.
- 2. This Surveillance shall not be performed in MODE 1, 2, or 3 for DG 3 g and DG 4. However, credit may be taken for unplanned events that g-satisfy this SR.
Verify, on actual or simulated loss of 24 months offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
- a. De-energization of emergency buses;
- b. Load shedding from emergency buses; and
- c. DG auto-starts from standby condition and:
(
- 1. energizes permanently connected loads in s 10.5 seconds,
- 2. energizes auto-connected emergency loads through load sequence relays,
- 3. maintains steady state voltage a 3750 V and s 4300 V,
- 4. maintains steady state frequency 1 2 58.8 Hz and s 61.2 Hz, and
- 5. supplies permanently connected and auto-connected emergency loads for a 5 minutes, b
l f
\
v Brunswick Unit 2 3.8-14 Amendment No. 1 l
l AC Sources-Shutdown l 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE: I
- a. One Unit 2 qualified circuit between the offsite transmission network and the onsite Class IE AC electrical power distribution subsystem (s) required by LCO 3.8.8, " Distribution Systems-Shutdown";
- b. Two diesel generators (DGs) capable of supplying onsite Class IE AC electrical power distribution subsystem (s) b required by LC0 3.8.8; and
- c. One Unit 1 qualified circuit between the offsite transmission network and the onsite Class IE AC electrical power distribution subsystem (s) needed to support the Unit 1 equipment required to be OPERABLE by LC0 3.7.3, " Control Room Emergency Ventilation (CREV)
System," LC0 3.7.4, " Control Room Air Conditioning (AC) estem," and LC0 3.8.5, "DC Sources-Shutdown." APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment. l 4 Brunswick Unit 2 3.8-15 Amendment No.
AC Sources-Shutdown 3.8.2 ACTIONS
-------------------------------------NOTE------------------------------------- '00 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required -----
------NOTE-------------
offsite circuits Enter applicable Condition inoperable. and Required Actions of LC0 3.8.8, with one or more required 4.16 kV emergency buses de-energized as a result of Condition A. A.1 Declare affected Imediately required feature (s), with no offsite power available, inoperable. O A.2.1 Suspend CORE Imediately ALTERATIONS. AND A.2.2 Suspend movement of Imediately irradiated fuel assemblies in the secondary containment. AND A.2.3 Initiate action to Imediately suspend operations with a potential for draining the reactor vessel (0PDRVs). AND (continued) O Brunswick Unit 2 3.8-16 Amendment No.
AC Scurcos-Shutdown 3.8.2 l O ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME > A. (continued) A.2.4 Initiate action to Immediately restore required offsite power circuit-to OPERABLE status. 1 B. One required DG B.1 Declare affected Immediately inoperable, required feature (s) with no DG available l- inoperable. I QB B.2.1 Suspend CORE Immediately ALTERATIONS. M B.2.2 Suspend movement of Immediately irradiated fuel , O- assemblies in secondary containment. M B.2.3 Initiate action to Immediately suspend OPDRVs. AND B.2.4 Initiate action to Immediately restore required DG to OPERABLE status. (continued) O Brunswick Unit 2 3.8-17 Amendment No. 1
AC S:urces-Shutdown 3.8.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Two required DGs C.1 Suspend CORE Immediately inoperable. ALTERATIONS. l M ; C.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment. E C.3 Initiate action to Immediately suspend OPDRVs. AND l C4 Initiate action to Immediately restore required DGs , to OPERABLE status. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Sr. 3.8.2.1 -------------------NOTE-------------------- Unless required to be performed by Unit 1 g Specification 3.8.1, the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.14. h For AC sources required to be OPERABLE, the SRs of Specification 3.8.1, except In accordance with applicable d SR 3.8.1.8 and SR 3.8.1.12, are applicable. SRs b Q Brunswick Unit 2 3.8-18 Amendment No.
i Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel 011 l LCO 3.8.3 The stored diesel fuel oil shall be within limits for each required diesel generator (DG). 1 APPLICABILITY: When associated DG is required to be OPERABLE. ACTIONS 1
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .......... NOTE-------------------------------------
Separate Condition entry is allowed for each DG. CONDITION REQUIRED ACTION
- COMPLETION TIME A. One or more required A.1 Restore required day 48 hour:s DGs with fuel oil fuel oil storage tank level in the level to within associated day fuel Os oil storage tank (s) limit.
< 22,650 gal per required DG and a 17,000 gal per required DG. 1 AND Fuel oil level in the !
main fuel oil storage 1 tank 2 20,850 gal per required DG. j (continued) O
.\j .
Brunswick Unit 2 3.8-19 Amendment No.
Diesel fuel Oil 3.8.3 l ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Restore main fuel oil 48 hours DGs with fuel oil storage tank level to level in the main fuel within limit. oil storage tank )
< 20,850 gal per j required DG and 2 13,900 gal per required DG.
)
Fuel oil level in the required day fuel oil storage tank (s) 2 22,650 gal per required DG, C. One or more DGs with C.1 Restore stored fuel 7 days stored fuel oil total oil total particulate not particulate to within limit, within limit. D. Required Action and D.1 Declare associated DG Immediately i associated Completion inoperable. 1 Time Condition A, B, or C not met. I 9E One or more DGs with diesel fuel oil not l within limits for l reasons other than Condition A, B, or C. > LJ Brunswick Unit 2 3.8-20 Amendment No. <
I ) Diesel Fuel Oil 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.I' For each required DG, verify: 31 days
- a. The associated day fuel oil storage tank contains 2 22,650 gal; and
- b. The main fuel oil storage tank contains a 20,850 gal per required DG.
SR 3.8.3.2 Verify fuel oil properties of stored fuel In accordance oil are tested in accordance with, and with the Diesel maintained within the limits of, the Diesel Fuel Oil Fuel'011 Testing Program. Testing Program SR 3.8.3.3 Check for and remove accumulated water from 31 days each day fuel oil tank and the main fuel oil storage tank. O ! Brunswick Unit 2 3.8-21 Amendment No.
DC Sources-Operating . 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources-Operating i LC0 3.8.4 The following DC electrical power subsystems shall be OPERABLE:
- a. Unit 2 Division I and Division II DC electrical power subsystems; and
- b. Unit 1 Division I and Division II DC electrical power I subsystems.
I I APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One DC electrical A.1 --------NOTE--------- power subsystem Enter applicable ( inoperable. Conditions a.7d Required Actions of i LC0 3.8.7,
" Distribution Systems-Operating,"
when Condition A results in de- 1 energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem. Restore DC electrical 7 days power subsystem to OPERABLE status. (continued)
^\
(V Brunswick Unit 2 3.8-22 Amendment No.
/,
DC Sources-Operating 3.8.4
.O 7 V ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME
- B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time of Condition A 6N_Q not met.
B.2 Be in MODE 4. 36 hours E Two or more DC electrical power subsystems inoperable. b
'l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is 2: 130 V 7 days on float charge.
SR 3.8.4.2 Verify no visible corrosion at battery 92 days terminals and connectors. M Verify battery connection resistance is s 23.0 ohms for inter-cell connections and s 82.8 ohms for inter-rack connections. d SR 3.8.4.3 Verify battery cells, cell plates, and 18 months racks show no visual indication of physical ; damage or abnormal deterioration that ' degrades performance. (continued) G('N Brunswick Unit 2 3.8-23 Amendment No.
DC Sources-0perating 3.8.4 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosinn and verify battery 18 months cell to cell and terminal connections are coated with anti-corrosion material. SR 3.8.4.5 Verify each required battery charger 24 months supplies a 250 amps at a 135 V for 2 4 hours. SR 3.8.4.6 -------------------NOTES-------------------
- 1. The modified performance discharge test in SR 3.8.4.7 may be performed in lieu of the service test in SR 3.8.4.6 once per 60 months.
- 2. This surveillance shall not be performed in MODE 1 or 2 for the Unit 2 DC electrical power subsystems. 4 v However, credit may be taken for unplanned events that satisfy this SR.
- 3. A single test at the specified /A Frequency will satisfy this E Surveillance for both units.
Verify battery capacity is adequate to 24 montns supply, and maintain in OPERABLE status, the required emergency loads for th.e design duty cycle when subjected to a batt'ery service test. (ccatinued) A U Brunswick Unit 2 3.8-24 Amendment No. N________________.
l DC Sources-Operating 3.8.4 , SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.4.7 -------------------NOTES-------------------
- 1. This Surveillance shall not be /\
performed in MODE 1 or 2 for the C' Unit 2 DC electrical pewer subsystems. However, credit may be taken for unplanned events that satisfy this SR.
- 2. A single test at the specified Frequency will satisfy this g
Surveillance for both units. Verify battery capacity is a 80% of the 60 months manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test. 12 months when battery shows degradation or has reached 85% of the expected life with capacity i
< 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity 2 100% of manufacturer's rating l
i b l , O l Brunswick Unit 2 3.8-25 Amendment No. , l l l
DC Sources-Shutdown 3.8.5 3.8 -ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LC0- 3.8.5 The following DC electrical power subsystems shall be OPERABLE:
- a. The Unit 2 DC electrical power subsystems needed to support the DC electrical power distribution subsystem (s) required by LCO 3.8.8, " Distribution Systems-Shutdown;" and
- b. The Unit l' DC electrical power subsystem needed to support the DC electrical power distribution subsystem (s) required by LCO 3.8.8, " Distribution Systems-Shutdown."
~ APPLICABILITY: MODES 4 and 5,
'During movement of irradiated fuel assemblies in the secondary containment.
ACTIONS
-------------------------------------NOTE-------------------------------------
LCO 3.0.3 is not applicable.
.............................................................................. 1 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more' required A.1 Declare affected Immediately DC electrical power required feature (s) subsystems inoperable. inoperable.
9E A.2.1 Suspend CORE Immediately ALTERATIONS. AND
- l. (continued) I
\
l j Brunswick Unit 2 3.8-26 Amendment No. I ! 1' l l
- lJ DC Scurces-Shutdown i-3.8.5 l
ACTIONS , CONDITI0f3 REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment. E A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel. M A.2.4 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status. O Brunswick Unit 2 3.8-27 Amendment No.
DC Sources-Shutdown l 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.8.5.1 -------------- ----NOTE-------------------- Unless required to be performed by Unit I Specification 3.8.4, the following SRs are g not required to be performed: SR 3.8.4.6 and SR 3.8.4.7. For DC electrical power subsystems required to be OPERABLE the following SRs are. In accordance with applicable d applicable: SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, SR 3.8.4.4, SR 3.8.4.5, SR 3.8.4.6, and SR 3.8.4.7. b O O Brunswick Unit 2 3.8-28 Amendment No.
)
Battery Cell Parameters j 3.8.6 1 71 3.8 ELECTRICAL POWER SYSTEMS V 3.8.6 Battery Cell P;rameters LC0 3.8.6 Battery cell parameters for the Unit 2 Division I and II batteries and the Unit 1 Division I and II batteries shall be within the limits of Table 3.8.6-1. AND Battery cell average electrolyte temperature for the Unit 2 Division 1 and II batteries and the Unit 1 Division I and II batteries shall be within required limits. APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE. ACTIONS
-------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each battery. I %
%- J CONDITION REQUIRED ACTION COMPLETION TIME A. One or more batteries A.1 Verify pilot cells I hour with one or more electrolyte level and I battery cell float voltage meet j parameters not within Table 3.8.6-1 i Category A or B Category C limits.
limits. AND A.2 Verify battery cell 24 hours parameters meet Table 3.8.6-1 AND Category C limits. Once per 7 days i thereafter i AND (continued) w I Brunswick Unit 2 3.8-29 Amendment No. I u-_ _____.
Battery Cell Parameters 3.8.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore battery cell 31 days parameters to Category A and 8 limits of Table 3.8.6-1. B. Required Action and B.1 Declare associated Immediately associated Completion battery inoperable. Time of Condition A not met. E One or more batteries with average electrolyte temperature of the representative cells : rm not within limits. ! a One or more batteries with one or more battery cell parameters not within Category C limits. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.8.6.1 Verify battery cell parameters meet 7 days Table 3.8.6-1 Category A limits. i (continued) lv{') Brunswick Unit 2 3.8-30 Amendment No. l _ __. __ . _ _ _ - _ _ _ _ _ - - _ _ _ _ - _ _ - _ _ _ _
Battery Cell Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Cell Parameters LCO 3.8.6 Battery cell parameters for the Unit 2 Division I and II batteries and the Unit 1 Division I ant II batteries shall be within the limits of Table 3.8.6-1. M Battery cell average electrolyte temperature for the Unit 2 Division 1 and II batteries and the Unit 1 Division I and II batteries shall be within required limits. APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE. ACTIONS
--.----------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each battery. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more batteries A.1 Verify pilot cells I hour with one or more electrolyte level and battery cell float voltage meet parameters not within Table 3.8.6-1 Category A or B Category C limits, limits. AND A.2 Verify battery cell 24 hours parameters meet Table 3.8.6-1 AND Category C limits. Once per 7 days thereafter M (continued) O Brunswick Unit 2- 3.8-29 Amendment-No.
Battery Cell Paramet:rs 3.8.6 (^) ~' ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B limfts of Table 3.8.6-1. B. Required Action and 8.1 Declare associated Immediately associated Completion battery inoperable. Time of Condition A not met. One or more batteries l with average ) electrolyte J temperature of the ' representative cells em not within limits. l
/
n One or more batteries with one or more i battery cell parameters not within i Category C limits. l SURVEILLANCE REQUIREMENTS _ SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet 7 days
- Table 3.8.6-1 Category A limits.
(continued)
, ~-)
( v Brunswick Unit 2 3.8-30 Amendment No.
Battery Call Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet 92 days Table 3.8.6-1 Category B limits. l SR 3.8.6.3 Verify average electrolyte temperature of 92 days representative cells is 2: 60'". O Brunswick Unit 2 3.8-31 Amendment No, l-l L_ - - -
Battery Cell Parameters
]
3.8.6 f) Table 3.8.6-1 (page 1 of 1) d Battery Cell Parameter Requirements CATEGORY A: CATEGORY B: CATEGORY C: LIMITS FOR EACH LIMITS FOR EACH LIMITS FOR DESIGNATED PILOT CONNECTED CELL EACH CONNECTED PARAMETER CELL CELL j i Electrolyte > Minimum level > Minimum level Above top of , Level indication mark, and indication mark, plates, and not i s i inch above and s 1 inch above werflowing ! maximum level maximum level indication mark (a) indication mark (a) { Float Voltage 2 2.13 V 2 2.13 V 2 2.07 V J i Specifi 2 1.200 2 1.195 Not more than Gravity b)(c) 0.020 below AND average of all connected cells O) ( Average of all connected cells AND 2 1.205 Average of all connected cells 2 1.195 l (a) It is acceptable for the electrolyte levr~ ;o temporarily increase above j the specified maximum level during and fi iowing equalizing charges l provided it is not overflowing. 1 (b) Corrected for electrolyte temperature and level. However, level correction is not required when on float charge and battery charging current is < 2 amps. 1 (cl A battery charging current of < 2 amps when on float charge is ; acceptable for meeting specific gravity limits following a battery < recharge, for a maximum of 7 days. When charging current is used to satisfy specific gravity requirements, specific gravity of each connected cell shall be measured prior to expiration of the 7 day allowance. p V Brunswick Unit 2 3.8-32 Amendment No.
( Distributer. Systems-Operating 3.8.7 l , 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems-Operating LCO 3.8.7 Division I and Division II AC and DC electrical power distribution subsystems shall be OPERABLE. APPLICABILITY: MODES I, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.I Restore AC electrical 8 hours electrical power power distribution distribution subsystems to AND subsystems inoperable. OPERABLE status. 176 hours from discovery of failure to meet j LCD , (continued) I l l l R
.U Brunswick Unit 2 3.8-33 Amendment No.
Distribution Systems-0perating 3.8.7 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. One or more DC electrical power B.1 Declare required feature (s), supported Immediately b distribution by the inoperable DC subsystems inoperable electrical power due to loss of normal distribution DC source. subsystem, inoperable, b B.2 Initiate action to transfer DC Immediately h electrical power distribution subsystem to its alternate DC source. AND g B.3 Declare required feature (s) supported Upon completion of transfer of d O by the inoperable DC electrical power distribution the required feature's DC electrical power subsystem OPERABLE. distribution k subsystem to its OPERABLE alternate DC source AND B.4 Restore DC electrical 7 days b power distribution subsystem to OPERABLE AND status. 176 hours from discovery of failure to meet , the LC0 (continued) 4 O'uJ Brunswick Unit 2 3.8-34 Amendment No.
Distribution Systems-Operating ) 3.8.7 l [ ACTIONS (continued) CONDITION COMPLETION TIME REQUIRED ACTION C. One or more DC electrical power C.1 Restore DC electrical power distribution 7 days b distribution subsystems to AND subsystems inoperable OPERABLE status. for reasons other than 176 hours from Condition B. discovery of failure to meet h LC0 D. Required Action and 0.1 Be in MODE 3. 12 hours associated Completion Time of Condition A, AND B, or C not met. D.2 Be in MODE 4. 36 hours E. Two or more electrical E.1 Enter LC0 3.0.3. Immediately b power distribution (' subsystems inoperable that result in a loss I of function. I i \v) Brunswick Unit 2 3.8-35 Amendment No.
Distribution Systems-0perating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems. SR 3.8.7.2 Verify no combination of more than two 7 days power conversion modules (consisting of either two lighting inverters or one lighting inverter and one plant g uninterruptible power supply unit) are aligned to Division II bus B. O O Brunswick Unit 2 3.8-36 Amendment No.
Distribution Systems-Shutdown 3.8.8 3.8 -ELECTRICAL POWER. SYSTEMS
'3.8.8 Distribution Systems-Shutdown _
LCO 3.8.8 The necessary portions of the AC and DC electrical power _- distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment. ACTIONS
.................. .................. NOTE-------------------------------------
LCO 3.0.3 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.I Declare associated Immediately AC or DC electrical supported required power distribution feature (s) subsystems inoperable. inoperable. g i A.2.1 Suspend CORE Immediately ALTERATIONS. I AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment. AND (continued) 1 LBrunswick Unit 2 3.8-37 Amendment No. l-l U .- - __r.--__,a---x,-- ------__----x__---u____----
Distribution Systcs-Shutdown 3.8.8 l I ACTIONS V) CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations witn a potential for draining the reactor vessel. AND A.2.4 Initiate actions to Immediately restore required AC and DC electrical power distribution subsystems to OPERABLE status. AND A.2.5 Declare associated Immediately required shutdown cooling subsystem (s) e inoperable and not in operation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and 7 days indicated power availability to required AC and DC electrical power distribution subsystems.
,, m\
G Brunswick Unit 2 3.8-38 Amendment No.
AC _ Scurces-Operating B 3.8.1 BASES LCO separation criteria. If the preferred offsite circuit (continued) (i.e., the circuit path from a 230 kV bus through the SAT to the associated onsite Class IE emergency buses) is not g connected to an emergency bus, the circuit is required to have OPERABLE fast transfer capability to two emergency buses to support OPERABILITY of.that circuit. APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
- b. Adequate core cooling is provided and containment OPERA 8ILITY and other vital functions are maintained in the event of a postulated DBA.
The AC power requirements for MODES 4 and 5 and other conditions in which AC_ sources are required are covered in LCO 3.8.2, "AC Sources-Shutdown." O ACTIONS Ad The offsite circuits for two of the four 4.16 kV emergency buses utilize the opposite unit's SAT and UAT. Therefore, this Required Action provides a 45 day time period to perfom maintenance on one of the opposite unit's transformers. This is acceptable because performing maintenance on the transformer will increase the reliability of the offsite circuit. However, if a second Unit 1 or 2 offsite circuit becomes inoperable, Conditions B and D are entered. h The 45 day Completion Time takes into account the capacity and capability of the remaining AC sources and a reasonable time for performance of maintenance. The Note to Condition A only allows the 45 day Completion Time to be used when the opposite unit is in_ MODE 4 or 5. When a Unit 1 offsite circuit becomes inoperable while Unit.1 is in MODE 1, 2, or 3, Condition B of Unit 2 Specification 3.8.1 must be entered and the associated h Required Actions performed. (continued) Brunswick Unit 2 B 3.8-5 Revision No. __w.______m_ _ _ - - - -
E~ AC Ssurces-Operating B~3.8.1
. BASES ACTIONS M (continued)
To ensure a highly reliable power source remains with one offsite circuit inoperabla, it is necessary to verify the availability of the_ remaining offsite circuits on a more ~ frequent basis. Since the Required Action only specifies -
" perform," a . failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a _
second circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Cordition D, for_ two or more offsite circuits inoperable, is entered.- g M' Required Action B.2, which only applies if one 4.16 kV b. emergency bus cannot be powered from an offsite source, is intended to provide assurance that an event with a coincident single failure of the associated DG does not result in a complete loss of safety function of critical systems. These features (e.g., system, subsystem,' division, component, or device) are designed with redundant safety related 4.16 kV ennrgency buses. Redundant required feature O failures consist of inoperable features associated with an emergency bus redundant to the emergency bus that has no offsite power. The Completion Time for Required Action B.2 is intended to allow time for the operator to evaluate and repair any h discovered inoperabilities. This Completion Time also allows an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action the Completion Time only begins on discovery that both:
- a. A 4.16 kV emergency bus has no offsite power supplying its loads; and
- b. A redundant required feature on another emergency bus is inoperable.
If, at any time during the existence of this Condition (one offsite circuit inoperable) a redundant required feature
, ' subsequently becomes inoperable, this Completion Time would begin to be tracked.
(continued)
-Brunswick Unit 2 B 3.8-6 Revision No.
i AC Sources-Operating B 3.8.1 i h)v BASES ACTIONS M (continued) Discovering no offsite power to one 4.16 kV emergency bus of the onsite Class lE Power Distribution System coincident with one or more ino>erable required support or su) ported features, or both, t1at are associated with any otler l emergency bus that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown. ! The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the n low probability of a DBA occurring during this period. (_) According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition B for a period that should not exceed 72 hours. With one offsite circuit inoperable, the % reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class IE Distribution System. The 72 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. The second Completion Time for Required Action B.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet
, (continued)
)
Brunswick Unit 2 B 3.8-7 Revision No. I
AC S:urcos-Operating B 3.8.1 BASES ACTIONS B J .(continued) 6 LC0 3.8.1.a or b. If Condition B is entered while', for instance, a DG is inoperable, and that DG is subsequently returned OPERABLE, the LCO may already have been not met for up.to 7 days. This situation could lead to a total of 10 days, since initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 7 days (for a total of 17 days) allowed prior to complete restoration of the LCO. The 10 day. Completion Time provides ,. a limit on the time allowed in a specified condition after ! discovery of failure to meet LCO 3.8.1.a or b. This licit L is considered reasonable for situations in which Conditions B and C are entered concurrently. The "8E" connector between the 72 hours and 10 day Completion Times h means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met. As in Required Action B.2, the Completion Time allows for an exception to the normal " time zero" for beginning the h allowed outage time " clock." This exception results in establishing the " time zero" at the time LCO 3.8.1.a or b O was initially not met, instead of at the time that Condition B was entered.
.0.d To ensure a highly reliable power source remains with one DG inoperable, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure to meet SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass 1
SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered. . s. b Required Action C.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed to be' powered from redundant safety related 4.16 kV (continued) Brunswick Unit'2 B 3.8-8 Revision No. n* - - - - - - - - - . - - - _ - - - - - - - - _ - - _
AC Sources-Operating B 3.8.1 BASES ACTIONS M (continued) b emergency buses (i.e., single division systems are not included). Redundant required feature failures consist of inoperable features associated with an emergency bus redundant to the emergency bus that has an inoperable DG. The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
In this Required Action the Completion Time only begins on discovery that both:
- a. An inoperable DG exists; and
- b. A redundant required feature on another emergency bus is inoperable.
If, at any time during the existence of this Condition (one DG inoperable), a required redundant feature subsequently becomes inoperable, this Completion Time begins to be tracked. Discovering one DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DGs results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to j transients associated with shutdown. The remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. (continued) O Brunswick Unit 2 B 3.8-9 Revision No.
AC S:urces-Operating B 3.8.1 BASES ACTIONS C.3.1 and C.3.2 b (continued) Required Action C.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be h determined that the cause of the inoperable DG does not exist-on the OPEP,ABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other h DG(s), they are declared inoperable upon discovery, and Condition F or H of LC0 3.8.1 is entered, as applicable, once the failure is repaired, and the common cause failure h no longer exists, Required Action C.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed h not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued 3 OPERABILITY of those DGs. j In the event the inoperable DG is restored to OPERABLE status prior to ccmpleting either C.3.1 or C.3.2 (i.e., the inoperable DG has been restored to OPERABLE status but it hlf has not yet been determined if tne cause of the inoperability is e,ommon to the other OPERABLE DGs), the CP&L g' Corrective Action Drogram (CAP) will continue to evaluate i O the common cause possibility. This continued evaluation, j i however, is no longer required under the 24 hour constraint imposed while in Condition C. b According to Generic Letter 84-15 (Ref. 10), 24 hours is a reasonable time to confirm that the OPERABLE DGs are not affected by the same problem as the inoperable DG CA A The 4.16 kV emergency bus design is sufficient to allow operation to continue in Condition C for a period that should not exceed 7 days. In Condition C, the remaining g OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class IE Distribution System. The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. (continued) l l s Brunswick Unit 2 B 3.8-10 Revision No. l l L _ - _______.__.______.____._ _ _______ _ .____ _ -
AC S:urces-Operating B 3.8.1 v ACTIONS C.4 (continued) The second Completion Time for Required Action C.4 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet LC0 3.8.1.a or b. If Condition C is entered while, for - instance, an offsite circuit is inoperable rad that circuit is subsequently restored OPERABLE, the LC0 may already have been not met for up to 72 hours. This situation could lead to a total of 10 days, since initial failure of the LCO, to restore the DG. At this time, an offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours (for a total of 13 days) allowed prior to complete restoration of the LCO. The 10 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet LC0 3.8.1.a or b. This limit is considered reasonable for situations in which Conditions B and C are entered concurrently.
"AND" connector between the 7 day and 10 day Completion The h Times means that both Completion Times apply simultaneously, and the more restrictive must be met.
() As in Required Action C.2, the Completion Time allows for ari exception to the normal " time zero" for beginning the h allowed outage time " clock." This exception results in establishing the " time zero" at the time that LC0 3.8.1.a or b was initially not met, instead of the time that Condition C was entered. D.1 and D.2 Required Action D.1 addresses actions to be taken in the b event of inoperability of redundant required features concurrent with inoperability of two or more offsite circuits. Required Action D.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced to 12 hours from that allowed with one 4.16 kV emergency bus without offsite power (Required Action B.2). The rationale for the reduction to 12 hours is that Regulatory Guide 1.93 (Ref. 9) allows a Completion Time of 24 hours for two offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE. While this Action allows more than two circuits (continued) n Brunswick Unit 2 B 3.8-11 Revision No. l _ _ _ _ _ _ _ _ _ ~
AC Sources-Operating B 3.8.1 BASES ACTIONS p h _(LZ (continued) h to be inoperable, Regulatory Guide 1.93 (Ref. 9) assumes only two circuits are required by the LCO, and a loss of those two circuits results in a total loss of offsite power to the Class lE Electrical Power Distribution System. Thus, with the BNP electrical design, a loss of the four offsite circuits results in the same condition assumed in Regulatory h ! Guide 1.93 (Ref. 9). When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours is appropriate. These features are designed with redundant safety related 4.16 kV ] emergency buses, (i.e., single division systems are not I included in the list). Redundant required feature failures z consist of any of these features that are inoperable because any inoperability is on an emergency bus redundant to an emergency but with inoperable offsite circuits. The Completion Time for Required Action D.1 is intended to allow the operator time to evaluate and repair any b m discovered inoperabilities. This Completion Time also d allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required G Action, the Completion Time only begins on discovery that both:
- a. Two or more offsite circuits are inoperable; and
- b. A redundant required feature is inoperable.
If, at any time during the existence of this Condition (any combination of two or more Unit 1 and 2 offsite circuits inoperable), a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked. According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition D for a period that should not exceed 24 hours. This level of degradation means that the offsite h electrical power system may not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources. ___ (continued) Brunswick Unit 2 B 3.8-12 Revision No.
AC Ssurces-Operating B 3.8.1
-BASES ACTIONS D.1 and D,1 (continued) b
.Because of the normally high availability of the.offsite sources, this level of degradation may~ appear to be more severe than other combinations of two AC- sources inoperable i that involve one or more DGs inoperable. ~ However, two factors. tend to decrease the severity of this degradation level:'
- a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure; and
- b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.
With two or more of the offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were O postulated as a part of the design basis in the safety analysis. Thus, the 24 hour Completion Time provides a period of time to effect restoration of all but one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria. According to Regulatory Guide 1.93 (Ref. 9), with the , available offsite AC sources two less than required by the LCO, operation may continue for 24 hours. If-all offsite sources'are restored within 24 hours, unrestricted operation may continue. If all but one offsite source is restored within 24 hours, power operation continues in accordance - with Condition A or B, as applicable. E.1 and E.2 b Pursuant to LC0 3.0.6, the Distribution System-Operating ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition E are modified by a Note 6 (continued) O Brunswick Unit 2 B 3.8-13 Revision No.
AC S:urces-Operating B 3.8.1
/9 BASES V
ACTIONS E.1 and E.2 (continued) to indicate that when Condition E is entered with no AC b source to any 4.16 kV emergency bus, ACTIONS for LCO 3.8.7,
" Distribution Systems-Operating," must be immediately entered. This allows Condition E to provide requirements E for the loss of an offsite circuit and one DG without regard to whether an emergency bus is de-energized. LC0 3.8.7 provides the appropriate restrictions for a de-energized emergency bus.
According to Reg'41atory Guide 1.93 (Ref. 9), operation may continue in Condition E for a period that should not exceed 12 hours. In Condition E, individual redundancy is lost in g both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition D (loss of two or more offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour Completion g- Time takes into account the capacity and capability of the i remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. l l M b 1 With two or more DGs inoperable and an assumed loss of ! offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offrite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation
.for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation i is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.
(continued) p V Brunswick Unit 2 B 3.8-14 Revision No.
- - - -o
e , a u l AC Sources-0perating 1 B 3.8.1 BASES ACTIONS f_d (continued) According to Regulatory Guide 1.93 (Ref. 9), with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours. While this Action allows more than two DGs to be inoperable, Regulatory Guide 1.93 l (Ref. 9) assumes only two DGs are required by the LCO, and a I loss of those two DGs results in a total loss of onsite power to the Class 1E Electrical Power Distribution System. A Thus, with the BNP electrical design, a loss of the four DGs E l results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9). l G 1 and G.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LC0 does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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. H.1 Condition H corresponds to a level of degradation in which bl ! ali redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system may cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LC0 3.0.3 to commence a controlled shutdown. SURVEILLANCE Re AC sources are designed to permit inspection and REQUIREMENTS testing of all important areas and features, especially those that have a standby function, in accordance with UFSAR Sections 8.2 and 8.3 (Ref. 2). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for (continued) i Brunswick Unit 2 B 3.8-15 Revision No. l -._ - _ _ _ - - - . _ _ - _ _ _ _ .- ___ ______---_________._________________ _ ___ _ m
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE demonstrating the OPERABILITY of the DGs are consistent with REQUIREMENTS the recommendations of Safety Guide 9 (Ref. 5), Regulatory (continued) Guide 1.9 (Ref.11), and Regulatory Guide 1.137 (Ref.12), as addressed in the UFSAR. d Where the SRs discussed herein specify voltLge and frequency tolerances, the following summary is applicable. The i minimum steady state output voltage of 3750 V is derived from the recommendations found in Safety Guide 9 (Rs' 5) and bounds the minimum steady state output voltage criteria of 3621 V associated with tha 4.16 kV emergency buses i analyzed in the AC Auxiliary Electrical Distribution System I Study. This value (3621 V) allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 3600 V. It also allows for voltage drops to motors and other equipment down through the 480 V level where minimum operc. ting voltage is also usually specified as 90% of name plate rating. The specified maximum steady state output voltage of 4300 V ensures the maximum operating voltage at the safety related 480 V substations is no more than the maximum rated steady state voltage criteria for the 480 V motor control centers. The maximum steady state output voltage was determined taking into consideration the O voltage drop between the DGs and the 4.16 kV emergency buses and a 5% voltage boost at the 480 V substation transformers. This maximum steady state output voltage also ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated , steady state operating voltage. The specified minimum and , maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, , respectively. These values are equal to i 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Safety Guide 9 (Ref. 5). SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room. (continued) Brunswick Unit 2 B 3.8-16 Revision No.
AC S:urces'-Operating B 3.8.1 BASES SURVEILLANCE- SR 3.8.1.2 and SR 3.8.1.7 REQUIREMENTS
. (continued) These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.
To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs.have been modified by a Note (Note 1 for SR 3.8.1.2 and SR 3.8.1.7) to indicate that all DG starts for these Surve111ances may be preceued by an engine'prelube perie L For the purposes of this testing, the DGs are started from standby conditions. Standby conditions'for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained. In order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the-starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs.are gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2 of SR 3.8.1.2. SR 3.8.1.7 raquires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The minimum voltage and frequency stated in the SR are those necessary to ensure the DG can accept DBA loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential to establishing DG OPERABILITY, but a time constraint is not imposed. This is because a typical DG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not dampened by load application. This period may be extended beyond the 10 second acceptance criteria and could be cause for failing the SR. In lieu of a time constraint in the SR, BNP will monitor and trend the actual time to reach steady state operation as a means of ensuring there is no voltage regulator or governor degradation which could cause a DG to become inoperable. The 10 second start requirement supports and is conservative with respect to the assumptions in the design basis LOCA analysis of UFSAR, Section 6.3 (Ref. 6). The 10 second start requirement is (continued) O
. Brunswick Unit 2. B 3.8-17 Revision No.
AC S:urcas-Opsrating B 3.8.1-BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.l d, (continhed) REQUIREMENTS not applicable to SR 3.8.1.2 (see Note 2 of SR 3.8.1.2), when a modified start procedure as described above is used. If a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies. To minimize testing of the DGs, Note 3 to SR 3.8.1.2 and Note 2 to SR 3.8.1.7 allow a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the ft.ilure can be directly related to only one unit. The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref. 11). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter _84-15 (Ref.10). These Frequencies provide adequate assurance of DG OPERA 8ILITY, while minimizing degradation resulting from testing. O p SR 3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing and accepting a load approximately equivalent to the continuous rating of the DGs. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source. Although no power factor requirements are established by' this SR, the DG is normally operated at a power factor between 0.3 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is the generator design limitation which if exceeded could lead to generator instability while in parallel with the offsite circuit. ibe < load band is provided to avoid routine overloading of the { DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY. The 31 day Frequency for this Surveillance is consistent-
- with Regulatory Guide 1.9 (Ref. II).
(continued _), 'O h Brunswick Unit'2 B 3.8-18' Revision No, h l
AC S urces-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.3 (continued) REQUIREMENTS Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading so that mechanical stress and wear on the diesel engine are minimized. Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients outside the range normally used during the performance of this Surveillance do not invalidate the test. b Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from effsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for perforriance of this SR. A successful DG start must precede this test to credit satisfactory performance. To minimize testing of the DGs, Note 5 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by p'erforming the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. SR 3.8.1.4 This SR provides verification that the level of fuel oil in the engine mounted tank is slightly below the level at which the backup fuel oil transfer pump automatically starts. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for approximately 30 minutes of DG operation at rated load. This SR may be satisfied by verifying the absence of the associated low level alarm. The 31-day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are , provided and facility operators would be aware of any large uses of fuel oil during this period. (continued) Brunswick Unit 2 .B 3.8-19 Revision No.
AC S:urces-Operating B 3.8.1 BASES i SURVEILLANCE SR 3.8.1.5 REQU.IREMENTS . (continued) Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the engine mounted. tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by. Regulatory Guide 1.137 (Ref.12). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance. ' Removal of accumulated water may be accomplished by draining a portion of fuel oil from the engine mounted fuel oil tank O to the day fuel oil storage tank and draining any accumulated water from the day fuel oil storage tank in accordance with SR 3.8.3.3. The draining evolution will continue until accumulated water is verified to be removed from the engine mounted fuel oil tank. SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides' assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system _is intact, the fuel delivery piping is not obstructed, and the ; , ' controls and control systems for fuel transfer systems are L' OPERABLE. 1 (continued) l O Brunswick-Unit 2 B 3.8-20 Revision No. o
AC Scurces-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.6 (continued) REQUIREMENTS . The Frequency for this SR is consistent with the Frequency for testing the DGs-in SR 3.8.1.3. DG operation for SR 3.8.1.3 is normally lon enough that fuel oil level in the engine mounted tank wi 1 be reduced to the point where the fuel oil transfer pump automatically starts to restore b fuel oil level in the engine mounted tank. SR 3.8.1.8 Transfer of each 4.16 kV emergency bus power supply from the normal circuit to the preferred offsite circuit and from the preferred offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the offsite circuit distribution network to power the shutdown loads. In lieu of actually initiating an automatic circuit transfer, testing that adequately shows the capability of the transfer is acceptable. The automatic transfer testing may include any series of sequential, overlapping, or total steps so that the entire transfer sequence is verified. The 24 month Frequency of the Surveillance is based on engineering O judgment taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when performed on the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a-reliability standpoint. This SR is modified by three Notes. The reason for Note 1 is that, during 9peration with the reactor critical, performance of SR 3.8.1.8.a, verification of automatic A transfer capability of the unit power supply from the normal E circuit to the preferred offsite circuit, could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and,-as a result, plant safety systems. Note 1 is not applicable to
.SR.'3.8.1.8.b, verification of manual transfer of the unit power supply from the preferred offsite circuit to the g'
alternate offsite circuit, since this evolution does not cause perturbations of the electrical distribution systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2 both units' offsite circuits are required to be OPERABLE to k
'(continued)
Brunswick Unit 2 B 3.8-21 'I
, Revision No.
1
AC Scurces-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.8 (continued)
-REQUIREMENTS supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need for a shutdown.of both
-units to perform this Surveillance, Note 1 only precludes g
satisfying this Surveillance Requirement for the Unit 2' offsite circuits when Unit 2 is in MODE 1:or 2. During the; performance of this Surveillance with Unit 2 not in MODE 1 or 2 and with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a Unit 2 offsite circuit is rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. As stated in Note 2, automatic transfer capability to the SAT is not required to be met when the associated 4.16 kV emergency buses are powered from the preferred offsite circuit. This is acceptable since the automatic transfer capability function has been satisfied in this condition. To minimize testing, Note 3 allows a single test (instead of two tests, one for each unit) to satisfy the requirements
- O for both units. This is allowed sin a the main purpose of the Surveillance can be met by performing the test on a A single unit. If an offsite circuit fails one of the Surveillance, the offsite circuit should be considered inoperable for both units.
SR 3.8.1.9 Each DG is )rovided with an engine overspeed trip to prevent damage to tie engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of J the engine. This Surveillance demonstrates the DG capability to reject the largest single load without tripping. The largest single load for each DG is.a core spray pump (1250 hp). This Surveillance may be accomplished by: a.- Tripping the DG output breaker with the DG carrying 9reater than or equal to its associated core spray pump while paralleled to offsite power, or while solely supplying the bus; or (continued) Brunswick Unit 2' B 3.8-22 Revision No. L _
L
]
AC S2urces-Operating B 3.8.1 BASES , l l SR 3.8.1.9 SURVEILLANCE (continued) REQUIREMENTS
- b. Tripping its associated core spray pump with the DG solely supplying the bus.
The load rejection test is. acceptable if the increase in diesel speed does not exceed the overspeed trip setpoint. The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref. 11). This SR is modified by three Notes. The reason for Note 1 is that, during operation with the reactor critical, performance of this SR could cause perturbations to the < electrical distribution systems that could challenge { continued steady state operation and, as a result, plant safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERABLE to supply power to these systems when either one or both gI units are in MODE.1, 2, or 3. In order to reduce the , consequences of a potential perturbation to the electrical ! distribution systems during the performance of this I i Surveillance, while at the same time avoiding the need to shutdown both units.to perform this Surveillance, Note 1 only precludes satisfying this Surveillance Requirement for DG 3 and DG 4 when Unit 2 is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit 2 not in MODE 1, 2, or 3 and with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if DG 3 or DG 4 is rendered inoperable by A the performance of this Surveillance. Credit may be taken m for unplanned events that satisfy this SR. In order to 1 ensure that the DG is tested under load conditions that are as close to desian basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing must be performed using a power factor :s; 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. To minimize testing of the DGs, Note 3 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed.since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surve111ances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
._ (continued Brunswick' Unit2 ~ B 3.8-23 Revision No.
R . . . .- . . .
. . . . . . . . . . . . . . . . . . . . ..1. . . _ .
w--w-AC Snurcss-Op rating B 3.8.1
.VO BASES SURVEILLANCE SR 3.8.1.10' REQUIREMENTS.
(continued) Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g., high jacket' water
-temperature) are bypassed on an ECCS initiation test signal
-and critical protective functions (engine overspeed, generator differential overcurrent, low lubricating oil pressure, reverse power, loss of field, and phase overcurrent-voltage restrained) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alare on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.
The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has demonstrated that these components will pass the SR when g performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. The SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test-(instead of two tests, g one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. SR 3.8.1.11 ll Brunswick Nuclear Plant performs a 60 minute run greater than or equal to the continuous rating (3500 kW) which bounds the maximum expected post-accident DG loading. The DG starts for this Surveillance can be performed either from (continued) cO
-Brunswick'Onit2 B 3.8-24 Revision No.-
I h-
AC S:urces-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.11 (continued) REQUIREMENTS standby or hot . editions. The provisions for prelube and warmup, discussed .h the Bases for SR 3.8.1.2, and for gradual loading, discussed in the Bases for SR 3.8.1.3, are applicable to this SR. In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor
- s; 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG cc,uld ,
experience. A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in order to maintain DG OPERABILITY. The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to l perform the Surveillance; and is intended to be consistent ! with expected fuel cycle lengtns. - l This Surveillance has been modified by two Notes. Note I states that momentary transients due to changing bus loads h do not invalidate this test. Similarly, momentary power i factor transients above the limit do not invalidate the ) test. To minimize testing of the DGs, Note 2 allows a ; single test (instead of two tests, one for each unit) to i satisfy the requirements for both units. This is allowed ' since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. SR 3.8.1.12 Consistent with Regulatory Guide 1.9 (Ref. 11), paragraph C.2.2.13, demonstration of the test mode override feature ensures that the DG availability under accident conditions is not compromised as the result of testing. Interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation (continued)
.p b I Brunswick Unit 2 8 3.8-25 Revision No.
L
AC Scurces-Operating B 3.8.1 BASES SURVE1LLANCE SR 3.8.1.12 (continued) REQUIREMENTS signal is received during operation in the test mode. Ready-to-load operation is defined as the DG running at rated speed and voltage with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.4(6). b In lieu of actually returning the'DG to ready-to-load status, testing that adequately shows the capability of the DG to perform this function is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire sequence is verified. The 24 month Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths. This SR is modified by a Note. To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both ( units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surve111ances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one un.it. SR 3.8.1.13 Under accident conditions loads are sequentially connected to the bus by the automatic load sequence time delay relays. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 4 provides a summary of the automatic loading of ESF buses. l (continuedl
~
Brunswick Unit 2- B 3.8-26 Revision No.
AC S:urces-Operating B 3.8.1 A-
'Q BASES SURVEILLANCE SR 3.8.1.13 (continued)
REQUIREMENTS The Frequency of 24 months is consistent with the recommendations of Regulatory Guide 1.9 (Ref.11), Table 1; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths. This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs, and associated load sequence relays, are required to be OPERA 8LE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In. order to reduce potential consequences associated with removing a required offsite circuit from service during the performance of this Surveillance, reduce consequences of a potential g perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges
/^g to safety systems, while at the same time avoiding the need V to shutdown both units to perform this Surveillance, the Note only precludes satisfying this Surveillance Requirement ;
for the load sequence relays associated with DG 3 and DG 4 when Unit 2 is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit 2 not in MODE 1, 2, or 3 and g with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 3, or DG 4 is g rendered inoperable by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy this SR. l SR 3.8.1.14 ' In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to l ESF systems so that the fuel, RCS, and containment design l limits are not exceeded. l l This Surveillance demonstrates DG operation during a loss of offsite power actuation test signal in conjunction with an l ECCS initiation signal. This test verifies all actions encountered from the event, including shedding of the (continued) Brunswick Unit 2 B 3.8-27 Revision No.
~
.____________________________.____________._______j
?
1 r AC S:urcos-Opsrating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued) REQUIREMENTS nonessential. loads and energization of the emergency buses and respective loads.from the DG. 'It further demonstrates the capability of the DG to automatically achieve the'. required voltage and frequency within the specified time. g l The 10.5 second time period, which is allowed for the DG to auto-start and connect to its respective emergency bus, is conservatively derived from requirements of the accident analysis for- responding to a design basis:larg3 break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved. The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are O not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified. The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle { 1ength. j This SR is modified by two Notes. The reason for Note 1'is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from st.andby. conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with procedural guidance. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical (continued) 4
. Brunswick Unit 2- B 3.8-28 Revision No.
1 AC Sources-Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued) REQUIREMENTS distribution system, and challenge safety systems. Due to , the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units I and 2, all four DGs are required to be.0PERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the potential consequences associated with removing a required offsite circuit from service during the performance of this Surveillance, reduce a consequences of a potential perturbation to the electrical 7tu distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to perform this Surveillance, Note 2 only precludes satisfying this Surveillance Requirement for DG 3 and DG 4 when Unit 2 is in MODE 1, 2, or 3. During the performance of this A Surveillance with Unit 2 not in MODE 1, 2, or 3 and with 'E Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required offsite circuit, DG 3, DG 4, or other supported Technical Specification equipment is rendered A inoperable by the performance of this Surveillance. Credit O may be taken for unplanned events that satisfy this SR. j REFERENCES 1. UFSAR, Section 8.3.1.2.
- 2. UFSAR, Sections 8.2 and 8.3.
- 3. NRC Diagnostic Evaluation Team Report for Brunswick l Steam Electric Plant dated August 2,1989, from- {
J.M. Taylor (NRC) to S.H. Smith, Jr. (CP&L).
- 4. UFSAR, Table 8.3.1-6.
- 5. Safety Guide 9.
- 6. UFSAR, Chapter 6.
- 7. UFSAR, Chapter 15,
- 8. 10 CFR 50.36(c)(2)(ii).
- 9. Regulatory Guide 1.93, December 1974.
- 10. _ Generic Letter 84-15.
(continued) Brunswick Unit 2-B 3.8-29 Revision No.
AC Sources-Operating B 3.8.1 BASES REFERENCES 11. Regulatory Guide 1.9, July 1993, Revision 3. (continued) 12.- Regulatory Guide 1.137, January 1978.
- 13. IEEE Standard 308.
O l LO
-Brunswick. Unit 2 B 3.8-30 Revision No.
l AC S:urces--Shutdown B 3.8.2
; B 3.8 ELECTRICAL POWER SYSTEMS l- B 3.8.2 AC Sources-Shutdown l'
L 1 BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources-Operating." l APPLICABLE The OPERABILITY of the minimum AC sources during MODES 4 l SAFETY ANALYSES and 5, and during movement of irradiated fuel assemblies in I the secondary containment ensures that:
- a. The facility can be maintained in the shutdown or refueling condition for extended periods;
- b. Sufficient instrumentation and control capability is i available for monitoring and maintaining the unit status; and
- c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as an p inadvertent draindown of the vessel or a fuel handling d accident.
In general, when the unit is shutdown the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, and 3 have no specific analyses in MODES 4 and 5. Worst case bounding events are deemed not credible in MODES 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure., and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LC0 for required systems. During MODES 1, 2, and 3, various deviations from the analysis assumptions and design requirements are allowed within the ACTIONS. This allowance is in recognition that certain testing and maintenance activities must be '
- (continued)
V,S I Brunswick Unit 2 B 3.8-31 Revision No. ! _ ______ - _ - _ _ _ _ ___ --__- _ a
AC S:urces-Shutd:wn B 3.8.2 BASES APPLICABLE conducted, provided al acceptable level of risk is not SAFETY ANALYSES exceeded. During MODES 4 and 5, performance of a (continued) significant number of required. testing and maintenance activities is also required. In MODES 4 and 5, the activities are enerally planned and administrative 1y controlled. Re axations from typical MODES 1, 2; and 3 LCO requirements are acceptable during shutdown MODES, based on:
- a. The fact that-time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.
- b. Requiring appropriate compensatory measures for-certain conditions. These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operation MODE analyses, or both.
- c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.
- d. Maintaining, to the extent practical, the ability to O perform required functions (even if not meeting MODES 1, 2, and 3 OPERABILITY requirements) with systems assumed to function during an event.
In the event of an accident during shutdown, this LCO ensures the capability of supporting systems necessary for avoiding immediate difficulty, assuming a loss of all offsite power. The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 1). LCO One Unit 2 offsite circuit capable of supplying the onsite Class IE power distribution subsystem (s) of LC0 3.8.8, b
" Distribution Systems-Shutdown," ensures that all required Unit 2 loads are powered from offsite power. Two OPERABLE .
DGs, associated with distribution subsystem (s) required OPERABLE by LC0 3.8.8, ensures that a diverse power source is available for. providing electrical power support assuming a loss of- the offsite circuit (s). In addition, some Unit I equipment may be required by Unit 2 (e.g., Control Room Emergency Ventilation (CREV) System components). Therefore, g one Unit I qualified circuit between the offsite q O U (continued)
' Brunswick Unit 2 8 3.8-32 Revision No.
l
AC Ssurces-Shutdown B 3.8.2 BASES LCO transmission network and the onsite Class IE AC electrical (continued) power distribution subsystem (s), needed to support the Unit 1 equipment required to be OPERABLE, must also be OPERABLE. Together, OPERABILITY of the required offsite circult(s) and DGs ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and reactor vessel draindown). The qualified offsite circuit (s) must be capable of maintaining rated frequency and voltage while connected to the respective emergency bus (es), and of accepting required loads during an cccident. Qualified offsite circuits are those that are described in the UFSAR and are part of the licensing basis for the unit. The Unit 2 qualified offsite circuit consists of the incoming breaker and disconnect to and including the associated startup auxiliary transformer (SAT) or unit auxiliary transformer (UAT), the respective circuit path to and including the balance of plant bus (es), and the circuit path to associated 4.16 kV emergency bus (es) required by LCO 3.8.8. The Unit 1 qualified offsite circuit consists of the incoming breaker and disconnect to and O . including the associated SAT or UAT, the respective circuit path io and including the balaiice of plant bus (es), and the circuit path to associated 4.16 kV emergency bus (es) required by LC0 3.7.3, LCO 3.7.4, and LCO 3.8.5. The required DGs must be capable of starting, accelerating to minimum acceptable frequency and voltage, and connecting to its respective 4.16 kV emergency bus on detection of bus undervoltage. This sequence must be accomplished within 10.5 seconds. Each required DG is required to have an OPERABLE air start system consisting of one air header, one receiver, associated air compressor, piping, valves, and instrument controls to ensure adequate starting and control air capacity. Additionally, each DG must be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the 4.16 kV emergency buses. These capabilities are. required to be met from a variety of initial conditions such as DG in standby with engine at ambient conditions. Additional DG capabilities must be demonstrated to it required Surveillance, e.g., capability of th. G to revert to standby status on an ECCS signal while operating in parallel test mode. Proper (continued) Brunswick' Unit-2 B 3.8-33 Revision No.
AC Sources-Shutdown - B 3.8.2 O v BASES LCO sequencing of loads, including tripping of nonessential (continued) loads, is required function for DG OPERABILITY. The necessary portions of the Nuclear Service Water System are also required to provide appropriate cooling to each required DG. It is acceptable for 4.16 kV emergency. buses to be cross tied during shutdown conditions, permitting a single offsite power circuit to supply all required buses provided both units are shutdown. , APPLICABILITY The AC sources are required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment to provide assurance that:
- a. Systems providing adequate coolant inventory makeup 4 are available for the irradiated fuel assemblies in I the core in case of an inadvertent draindown of the reactor vessel;
- b. Systems needed to mitigate a fuel handling accident p are available;
- c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
- d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
AC power requirement; for MODES 1, 2, and 3 are covered in LCO 3.8.1. I ACTIONS 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, the ACTIONS have been modified by a Note stating , that LC0 3.0.3 is not applicable. If moving irradiated fuel l 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. Entering LC0 3.0.3, while in MODE 1, 2, or 3, would require the unit to be shutdown, but would not require i immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3.0.3 is not 19 V (continued) Brunswick Unit 2 B 3.8-34 Revision No.
AC Sourcas-Shutdown B 3.8.2 A Q BASES ACTIONS applicable," ensures that the actions for immediate n (continued) suspension of irradiated fuel assembly movement are not 2L\ postponed due to entry into LC0 3.0.3. A.1 and B.1 With one or more required offsite circuits inoperable, or with one DG inoperable, the remaining required AC sources may be capable of supporting sufficient required features (e.g., system, subsystem, division, component, or device) to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for draining the reactor vessel. For example, if two 4.16 kV emergency buses are required per LCO 3.8.8, one emergency bus with offsite power available may be capable of supplying sufficient required features. By the allowance of the option to declare required features inoperable that are not powered from offsite power (Required Action A.1) or capable of being powered by the required DG (Required Action B.1), appropriate restrictions can be implemented in accordance with the affected required feature (s) LCOs' ACTIONS. Required features. remaining 1 O powered from the qualified offsite power circuit, even if
) the circuit is inoperable to other required features, are not declared inoperable by this Required Action.
1 I A.2.1. A.2.2. A.2.3. A.2.4. B.2.1. B.2.2. B.2.3. B.2.4. C.I. C.2. C.3. and C.4 With an offsite circuit not available to all required 4.16 kV emergency buses or one required DG inoperable, the option still exists to declare all required features inoperable (per Required Actions A.1 and B.1). Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With two required DGs inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and activities that could result in inadvertent draining of the reactor vessel. l Suspension of these activities shall not preclude completion L of actions to establish a safe conservative condition. l These actions minimize the probability of the occurrence of l postulated events. It is further required to immediately D (J (continued) Brunswick Unit 2 B 3.8-35 Revision No.
AC S:urces-Shutdown B 3.8.2 BASES ACTIONS A.2.1. A.2.2. A.2.3. A.2.4. B.2.1.'B.2.2. B.2.3. B.2.4. C.I. C.2. C.3. and C.4 (continued) initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power. Pursuant to LC0 3.0.6, the Distribution System ACTIONS would
-not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required 4.16 kV emergency bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss-of the offsite circuit ;O whether or not a required bus is de-energized.
provides the appropriate restrictions for the situation LCO 3.8.8 .. involving a de-energized bus. SURVEILLANCE SR 3.8.2.1 L REQUIREMENTS i SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are I necessary for ensuring the OPERABILITY of the required AC sources in other than MODES 1, 2, and 3 to be met. SR b l' 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.12 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. Refer to the corresponding Base 2 for g LCO 3.8.1 for a discussion of each SR. This.SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being l paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4.16 kV emergency bus or (continued)
.O Brunswick Unit 2 B 3.8-36 Revision No. j
~
i f 1 _ _ _ . _
AC Sturcss-Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 (continued) REQUIREMENTS . . disconnecting a required offsite circuit during performance of SRs. With. limited AC sources available, a_ single event-could compromise both the required circult(s) and the DCs. It is the intent that these SRs must still be capable of being met, but actual performance is not required during
- periods when the DGs and offsite circuit (s) are required to be OPERA 8LE unless Unit 1 Specification 3.8.1, "AC Sources-Operating," requires performance of these SRs.
When Unit 1 Specification 3.8.1 requires performance of these SRs, AC sources availability is not limited due to the Unit I requirements for AC source OPERABILITY. Therefore, a g single event, in this condition, is not expected to compromise both the required offsite circuit (s).and the DG(s). REFERENCES 1. 10CFR50.36(c)(2)(ii). 4 qf Brunswick Unit 2 B 3.8-37 Revision.No.' t
Diesel Fuel Oil B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil i l BASES BACKGROUND Each diesel generator (DG) is provided with storage tanks , having a fuel oil capacity sufficient to operate that DG for j a period of approximately 7 days while the DG is operating 1 at rated load as discussed in UFSAR, Section 8.3.1.1.6.2.8 J (Ref. 1). The fuel consumption rate is calculated using the i assumption that four DGs are available. The diesel ] generator fuel oil capacity in the combination of the fuel j oil volumes of the Seismic Class I day fuel oil storage j tanks (one tank for each diesel generator) and the seismic Class I engine mounted fuel tanks (one tank attached to each diesel generator) provide approximately four days of diesel generator operation at rated load. The main fuel oil storage tank provides.approximately three additional days of diesel generator operation at rated load to each of the day fuel oil storage tanks. The main fuel oil storage tank is seismically designed but not seismically qualified. I Following the postulated loss of the main fuel oil storage l G tank, the onsite fuel oil capacity in seismically qualified V storage tanks is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources as discussed in Reference 1. Fuel oil is transferred from the day fuel oil storage tank to the engine mounted fuel tank by either of two transfer pumps associated with each day fuel oil storage tank. Fuel oil is gravity fed from the main fuel oil storage tank to the day fuel oil storage tanks through manual or automatic i valves. However, level in the day fuel oil storage tanks is ! currently maintained through the u::e of the manual valves. Redundancy of pumps and piping, and the normally isolated l gravity feed lines from the main fuel oil storage tank to the day fuel oil storage tanks, precludes the failure of one pump, or the rupture of any pipe, valve, or tank to result in the loss of more than one DG. All outside tanks, pumps, . and piping (other than the main fuel oil storage tank and a portion of the associated piping) are located underground. (continued) l A
)
Brunswick Unit 2 B 3.8-38 Revision No.
4 Diesel Fuel Oil ) B 3.8.2 4 BASES ! BACKGROUND For proper operation of the standby DGs, it is necessary to (continued) ensure the proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as modified by Reference 3. The fuel oil properties governed by SRs of this Specification are the water content, the kinematic viscosity, and impurity level. g APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in UFSAR, Chapter 6 (Ref. 4), and Chapter 15 (Ref. 5), assume Engineered Safety Feature (ESF) systems are OPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that reactor fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2,
" Power Distribution Limits"; Section 3.5, " Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System"; and Section 3.6, " Containment Systems."
Since diesel fuel oil supports the operation of the standby AC power sources, it satisfies Criterion 3 of (O 10 CFR 50.36(c)(2)(ii) (Ref. 6). LC0 Stored diesel fuel oil is required to have sufficient supply for approximately 7 days of operation at rated load. It is also required to meet specific standards 'for quality. These requirements, in conjunction with an ability to obtain replacement supplies within approximately 7 days, support the availability of DGs required to shut down the reactor ); and to maintain it in a safe condition for an anticipated operational occurrence (A00) or a postulated DBA with loss I of offsite power. DG engine mounted tank fuel oil requirements, as well as transfer capability from the day fuel oil storage tank to the engine mounted tank, are addressed in LCO 3.8.1, "AC Sources-Operating," and i LC0 3.8.2, "AC Sources-Shutdown." (continued) ! A V Brunswick Unit 2 B 3.8-39 Revision No. I _ __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - -
Diessl Fuel Oil B 3.8.3 BASES'(continued) APPLICA8ILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down 4 the reactor and maintain it in a safe shutdown condition after an A00 or a postulated DBA. Because stored diesel fuel oil supports LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, is required to be within limits when the associated DG is required to-be OPERABLE. ACTIONS The ACTIONS Table 'is modified by La Note indicating that separate Condition entry-is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one
' inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem (s) governed by separate Condition entry and application of associated Required Actions.
A.1 and B.1 With one or more required OGs with fuel oil level in the i associated day fuel oil storage tanks < 22,650 gallons per ( required DG and 2 17,000 gallons per required DG and the i fuel oil level in the main fuel oil storage tank 2 20,850 gallons per required DG, the approximate 7 day fuel oil supply for a required DG is not available. However, j Condition A is restricted to fuel uit level reductions that 1 maintain at least an approximate 6 day supply ~(at least an I approximate 3 day supply is available in the requirM day fuel oil storage tanks and an approximate 3 day supply is { available in the main fuel oil storage tank). ) With one or more required DGs with fuel oil level ~in the main fuel oil storage tank < 20,850 gallons per r? quired DG and 2 13,900 gallons per required DG and the fuel cil level in.the required day fuel oil storage tank (s) 2 22,650. gallons per required DG, the approximate 7 day fuel oil supply for a required DG is not available. However,
'F m
Condition B is restricted to fuel oil level reductions that maintain at least an approximate 6 day supply (at least an approximate 2 day supply is available in the main fuel oil storage tank.and an approximate 4 day supply isJ available in the required day fuel oil storage tanks (s)). (continued) O Brunswick Unit 2. B 3.8-40 Revision No. m j
Diesel Fual Oil B 3.8.3 BASES ACTIONS A.1 and B.1 (continued) These circumstances may be caused by events such as:
- a. Full load operation required ~for an. inadvertent start while at minimum required level; or-
- b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
These restrictions (Required Actions A.1 and B.1) allow sufficient time for obtaining the requisite replacement volume and performing the-analyses required prior to addition of the fuel oil to the tank. A period of 48 hours is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable. This period is acceptable based on the remaining capacity-(2: approximately 6 days), the. fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. O u This Condition is entered as a result of a failure to meet H the acceptance criterion for particulate. Normally, trending of particulate. levels allows. sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling), contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the. presence of particulate does not mean failure of the fuel oil to burn properly in the diesel engine, since particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and since proper engine performance has been recently demonstrated-(within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, resampling, and re-analysis of the DG fuel oil. (continued) 10 l Brunswick' Unit 2 B 3.8-41 ' Revision No.
Diesel Fuel Oil B 3.8.3 BASES ACTIONS D.d (continued) With a Required Action and associated Completion Time of Condition A, B, or C not met, or the stored diesel fuel oil not within limits for reasons other than addressed by Conditions A, B, or C, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable. [ SURVEILLANCE SR 3.8.3.1 REQUIREMENTS . This SR provides verification that there is an adequate inventory of fuel oil in the storage tanks to support each DG's operation for approximately 7 days at rated load. The approximate 7 day period is sufficient time to place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location. For the purposes of this SR, the verification of the main fuel oil storage tank fuel oil volume'is performed on a per DG basis. This per DG volume ~is obtained using the fo1~ lowing equation: d
~ ~
My - U, N,, _
; where M, -
measured fuel oil volume of the main b fuel oil storage tank, 0, - unusable fuel oil volume of the main fuel oil storage tank, and N,o
= number of DGs required to be OPERABLE.
The results from this equation must be :t: 20,850 gallons in order to satisfy the acceptance criteria of SR 3.8.3.1.b. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period. (continued) f-~ Brunswick Unit 2' B 3.8-42 Revision No.
Diesel Fuel Oil B 3.8.3 BASES SURVEli.LAWCE SR 3.8 R REQUIREMENTS Once per 92 days, the stored fuel oil is sampled in accordance with ASTM D4057-88, (Ref. 7) and analyzed to establish that the viscosity limits specified in Table 1 af ASTM D975-88 (Ref. 7) are met for stored fuel oil. The 92 day period is acceptable because fuel oil viscosity, even if it was not within stated limits, would not have an A immediate effect on DG operation. This Surveillance, in E combination with the fuel oil delivery certificate of compliance, ensures the availability of high quality fuel oil for the DGs. Fuel oil degradation during long term storage shows up as an increass in particulate, mostly due to oxidation. The presence of particulate does not mean that the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure. Particulate concentrations should be determined in accordance with ASTM D2276-89 (Ref. 7), Method A3. This method involves a gravimetric determination of total O particulate concentration in the fuel oil and has a limit of 10 mg/1. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. For the BNP design, the total volume of stored fuel oil is contained in more than two interconnected tanks. Therefore, each tank must be considered and tested separately. The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals. The acceptability of new diesel fuel oil is verified by the l use of a certificate of compliance provided by the diesel fuel oil supplier for each new fuel oil delivery. The certificate of compliance includes certification of each of the ASTM 2-D fuel oil properties included in Table 1 of ASTM D975-88 (Ref. 7) and API gravity are within required limits. Therefore, the acceptability of new fuel oil for use prior to addition to the storage tanks is determined by verifying that the new fuel oil has not become contaminated with other products during transit, thus altering the quality of the (continued) O Brunswick Unit 2 B 3.8-43 Revision No.
& 4 '
Diesel Fuel Oil B 3.8.3 BASES SURVEILLANCE SR 3.8.3.2 (continued) REQUIREMENTS fuel oil. This ensures new fuel oil quality is maintained consistent with that identified in the certificate of compliance. Once the verification is satisfactorily completed, the fuel oil may be added to the storage tanks g without concern for contaminating the entire volume of fuel oil in the storage tanks. ] Failure to determine the acceptability of the new diesel l fuel oil is cause for rejecting the new fuel oil, but does I not represent a failure to meet the LCO since the fuel oil is not added to the storage tanks. i l SR 3.8.3.3 . l Microbiological fouling is a major cause of fuel oil : degradation. There are numerous bacteria that can grow in I fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel storage tanks once every 31 days eliminates the necessar.v environment for bacterial survival. This is the O most effedive means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the Surveillance. REFERENCES 1. UFSAR, Section 8.3.1.1.6.2.8.
- 2. Regulatory Guide 1.137, January 1978.
- 3. UFSAR, Section 1.8.
- 4. UFSAR, Chapter 6.
(continued) Brunswick Unit 2 0 3.8-44 Revision No. I l
Diesel Fuel Oil B 3.8.3 BASES REFERENCES 5. UFSAR, Chapter.15. (continued)
- 6. 10CFR50.36(c)(2)(ii).
- 7. ASTM Standards: D4057-88; D975-88; and D2276-89.
O O Brunswick Unit 2 B 3.8-45 Revision No. l i l
i I DC Sources--Operating B 3.8.4 f3 () B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources--Operating BASES BACKGROUND The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety related equipment. Also, these DC subsystems provide a source of uninterruptible power to AC vital buses. As required by design bases in UFSAR Section 8.3.2.1.1 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC slectrical power system also conforms to the recommendations of Safety Guide 6 (Ref. 2). The DC power sources provide both motive and control power to selected safety related equipment, as well as power for circuit breaker control, relay operation, plant annunciation, and emergency lighting. There are two independent divisions per unit, designated Division I and
/ Division II. Each division consists of a 250 VDC battery center tapped to form two 125 VDC batteries. Each 125 VDC battery has an associated full capacity battery charger.
The chargers are supplied from the same AC load groups for which the associated DC subsystem su,nplies the control power. During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC loads are automatically powered from the station batteries. The DC power distribution system is described in more detail in Bases for LC0 3.8.7, " Distribution System--Operating," and LC0 3.8.8, " Distribution System--Shutdown." Each battery has adequate storage capacity to carry the required load continuously for 1 hour. (continued) l 10
\- J Brunswick Unit 2 B 3.8-46 Revision No.
l l l . . . ..,, ,. . .
DC Sources-Operating B 3.8.4 BASES BACKGROUND Each DC battery subsystem (division) is separately housed in (continued) a battery room with its associated chargert and main DC distribution switchboard. This arrangement provides complete separation and isolation of the redundant DC subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. The batteries for DC electrical power subsystems are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The minimum design voltage limit is 105/210 V. Each battery charger of DC electrical power subsystem has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each station service battery charger has sufficient capacity to restore the battery from the design minimum charge to its fully charged state in approximately 8 hours while supplying normal steady state loads (Ref. 3). A description of the Unit 1 DC power sources is provided in i ( the Bases for Unit 1 LCO 3.8.4, "DC Sources-Operating". APPLICABLE The initial conditions of Design Basis Accident (DdA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5), assume that Engineered Safety Feature (ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation. The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based , upon meeting the design basis of the unit. This includes I maintaining DC sources OPERABLE during accident conditions ! in the event of:
- a. An assumed loss of all offsite AC power; and
- b. A worst case single failure.
The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 6). (continued)
/%
U Brunswick Unit 2 B 3.8-47 Revision No. l l
.___ __________ _____ A
DC Sources-0perating B 3.8.4 i ( BASES (continued) LCO The Unit 2 Division I and Divisten II DC electrical power subsystems, with each DC subsystem consisting of two 125 V batteries (Batteries 2A-1 and 2A-2 for Division I and Batteries 2B-1 and 28-2 for Division II), two battery , chargers (one per battery) and the corresponding control ) equipment and interconnecting cabling supplying power to the I associated bus are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (A00) or a postulated DBA. In addition, DC control power for operation of two of the four 4.16 kV emergency buses and two of the four 480 V emergency buses, as well as control power for two of the four DGs, is provided by the Unit 1 DC electrical power subsystems. Therefore, Unit 1 Division I and Division II DC electrical power subsystems are also required to be OPERABLE. Unit 1 DC electrical power subsystem OPERABILITY requirements are the same as those required for a Unit 2 DC electrical power subsystem. Loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 1). O
!,") APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1 1 2, and 3 to ensure safe unit operation and to ensure that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and
- b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.
The DC electrical power requirements for MODES 4 and 5 and other conditions in which the DC electrical power sources are required are addressed in LC0 3.8.5, "DC Sources-Shutdorn." ACTIONS ad Pursuant to LC0 3.0.6, the Distribution Systems-Operating ACTIONS would not be entered even if the DC electrical power subsystem inoperability resulted in de-energization of an AC electrical power distribution subsystem or a'DC electrical (continued) O Brunswick Unit 2 B 3.8-48 Revision No.
DC S:urces-Operating B 3.8.4 j BASES ACTIONS A d (continued) power distribution subsystem. Therefore, the Required-Actions of Condition A are modified by a Note'to indicate-that when Condition A results in de-energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem, Actions'of LCO 3.8.7 must be immediately entered. This allows Condition-A to. provide requirements for the loss of a DC electrical power ' subsystem without regard to whether a distribution subsystem is de-energized. LCO 3.8.7 provides the appropriate restriction for a de-energized distribution subsystem. Condition A represents one division with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division. If one of the required DC electrical power subsystems is inoperable (e.g., inoperable battery, inoperable battery charger (s), or inoperable battery charger and associated O inoperable battery), the remaining DC electrical. power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems.to mitigate a worst case accident, continued power operation should not exceed 7 days. The Completion time is based on the capacity and capability of the remaining DC Sources, including the enhanced reliability afforded by the capability to manually transfer DC loads to the opposite unit's DC electrical power distribution subsystems. B.1 and B.2 If the DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time or if two or more DC electrical power subsystems are inoperable, the unit must be brought to a MODE in which the LC0 does not apply. To. achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, l (continued)- Brunswick Unit 2 - B 3.8-49 Revision No. 1
DC S:urces-Operating B 3.8.4 BASES ACTIONS B.1 and B.2 (continued) based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7). SURVEILL.ANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage'while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery. The 7 day Frequency is conservative when compared with manufacturer recommendations and IEEE-450 (Ref. 8). O Q SR 3.8.4.2 Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each inter-cell and inter-rack connection, provides an indication of physical damage or abnormal deterioration that could h potentially degrade battery performance. The connection resistance limits are s 1.2 times the established benchmark resistance values for the connections or s 5 ohms above the established benchmark resistance values for the connections, whichever is higher. These d connection resistance acceptance criteria were derived from IEEE-450 (Ref. 8) and IEEE-484 (Ref. 9), respectively. The Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days. This Frequency is consistent with manufacturers recommendations. (continued) I O U ) e Brunswick Unit 2 B 3.8-50 Revision No.
DC S:urces-0perating , B 3.8.4 ! ( BASES l SURVEILLANCE SR 3.8.4.3 REQUIREMENTS (continued) Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of physical damage or deterioration does not necessarily. represent a failure of this SR, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of : the battery (its ability to perform its design function). The 18 month Frequency for the Surveillance is based on engineering judgement. Operating experience has shown that these components usually pass the SR Hi en performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.8.(.4 Visual inspection of inter-cell and inter-rack connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery O condition. The anti-corrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance. The 18 month Frequency for the Surveillance is based on engineering judgement. Operating experience has shown that i these components usually pass the SR when performed at the l 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.8.4.5 Battery charger capability requirements are derived from the design capacity of the chargers. According to Reference 3, the battery charger suppiy is required to be based on the (continued) n b
. Brunswick Unit 2 B 3.8-51 Revision No.
DC Sturces-Operating B 3.8.4. BASES SURVEILLANCE SR 3.8.4.5 (continued) REQUIREMENTS largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, under any load condition. The minimum required amperes and. duration ensures that these requirements can be satisfied. The Frequency is acceptable, given battery charger - relirM11ty and the other administrative controls existing to ensure adequate charger performance during these 24 month intervals. In addition, this frequency is intended to be consistent with expected fuel cycle lengths. SR 3.8.4.6 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference 10. The Frequency of 24 months is acceptable, given unit conditions required to perform the test and the other requirements existing to ensure adequate battery performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths. This SR is modified by three Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test once per 60 months. This substitution is acceptable because a modified performance discharge test represents a more severe test of battery capacity than SR 3.8.4.6. The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, both Unit I and g Unit 2 DC electrical power subsystems are required to supply-power to these systems when either one or both' units are in MDDE 1, 2, or 3. In order to reduce the~ potential consequences associated with removing a required DC electrical power subsystem from service during the n (continued) O Brunswick Unit 2- -
.B 3.8-52 Revision No.
lt ,
a DC Scurces-Operating S 3.8.4
. BASES SURVEILLANCE SR 3.8.4.6 (continued)
REQUIREMENTS performance of this Surveillance, reduce consequences of a potential' perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems,- while at the same time avoiding the need to shutdown both units to perform this Surveillance, Note 2 only precludes satisfying this-Surveillance for the Unit 2 DC electrical power subsystems when Unit 2 is in MODE 1 or 2. During the performance of g-this Surveillance with Unit 2 not in MODE 1 or 2 and with Unit 1 in MODE 1, 2, or 3; the applicable ACTIONS of the udt I and Unit 2 Technical Specifications must be entered if a required DC electrical power subsystem or other supported Technical Specification equipment is rendered inoperable by the performance'of this Surveillance. Credit may be taken for unplanned events that satisfy the Surveillance. To minimize testing, Note 3 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the niain purpose of the test can be met by performing the test on a single unit. If a DC electrical power subsystem fails b the Surveillance, the DC electrical power subsystem should O be considered inoperable for both units. SR 3.8.4.7 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found
- condition, after having been in service, to detect any change in the capacity determined by the acceptance test.
The test is intended to determine overall battery degradation due to age and usage. A battery modified performance discharge test is a simulated duty cycle consisting of just two rates; the one minute rate published for the battery or the largest current load of the duty' cycle, followed by the test rate employed for the performance discharge test, both of which envelope the duty
- cycle of the service test. Since the ampere-hours removed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of.the performance discharge test.
(continued) O Brunswick Unit 2 B 3.8-53 Revision No. _m.___-_ . - . _ _- _ _ _ _ _ _ _ _
--.--2..--,
DC S:urces-Opsrating B 3.8.4 i BASES SURVEILLANCE SR 3.8.4.7 (continued) REQUIREMENTS The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery performance discharge test for the duration of time equal to that of the performance discharge test. A modified discharge test is' a test of the battery capacity and its ability tn provide a high rate, short duration load (usually the highest rate of the duty cycle). This will oftea confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions.for the modified performance dischargo test should be identical to those specified for a performance discharge test. Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.7; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.7 while satisfying the requirements of SR 3.8.4.6 at the same time. The acceptance criteria for this Surveillance is consistent O with IEEE-450 (Ref. 8) and IEEE-485 (Ref. 11). These references recommend that the battery be replaced if its b capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements. The Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 2: 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 8), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is 10% below the manufacturer's rating. The 60 month Frequency is consister.t with the. recommendations in IEEE-450 (Ref. 8). The 12 month and 24 month Frequencies are derived from the recommendations in IEEE-450 (Ref. 8). (continued) O
' Brunswick Unit 2 B 3.8-54 Revision No.
l DC Sources-Operating B 3.8.4 i O O BASES SURVEILLANCE SR 3.8.4.7 (continued) REQUIREMENTS This SR is modified by two Notes. The reason for Note 1 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units I and 2, both Unit I and Unit 2 DC electrical power subsystems are required to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the potential consequences associated with removing a required DC electrical power subsystem from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical g distribution systems during the performance of this 1 Surveillance, and reduce challenges to safety systems, while j at the same time avoiding the need to shutdown both-units to perform this Surveillance, Note 1 only precludes satisfying this Surveillance for the Unit 2 DC electrical power subsystems when Unit 2 is in MODE 1 or 2. During the performance of this Surveillance with Unit 2 not in MODE 1 i or 2 and with Unit 1 in MODE 1, 2, or 3; the applicable i O. ACTIONS of the Unit I and Unit 2 Technical Specifications must be entered if a required DC electrical power subsystem , or other supported Technical Specification equipment is ' rendered inoperaSle by the performance of this Surveillance. Credit may be taken for unplanned events that satisfy the Surveillance. To minimize testing, Note 2 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the /A main purpose of the test can be met by performing the test 'Z B on a single unit. If a DC electrical power subsystem fails the Surveillance, the DC electrical power subsystem should be considered inoperable for both units. REFERENCES 1. UFSAR, Section 8.3.2.1.1.
- 2. Safety Guide 6.
- 3. UFSAR, Section 8.3.2.1.2.
- 4. UFSAR, Chapter 6. l S. UFSAR, Chapter 15. I l (continued) b I l
Brunswick Unit 2 B 3.8-55 Revision No. I i l _ __ _
DC Ssurces-Operating B 3.8.4 BASES REFERENCES 6. 10 CFR 50.36(c)(2)(ii). (continued)
- 7. Regulatory Guide 1.93, December 1974.
- 8. IEEE Standard 450, 1987.
- 9. IEEE Standard 484, 1996.
- 10. UFSAR, Section 8.3.2. b
- 11. IEEE Standard 485, 1983.
1 1 O i i I l I 1- . Brunswick Unit 2 B 3.8-56 Revision No.
t DC Sources-Shutdown B 3.8.5 8 3.8' ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources-Shutdown BASES
;8ACKGROUND A description of the DC sources is provided 'in' the Bases for LCO 3.8.4, "DC Sources-Operating."
APPLICASLE.' The initial conditions of Design Basis Accident and SAFETY ANALYSES' transient analyses in the UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the
-diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation and during movement of irradiated fuel assemblies in the secondary containment.
The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. The OPERABILITY of the minimum DC electrical power sources during MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment ensures that:
- a. The facility can be maintained in the shutdown or refueling condition for extended periods;
- b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
- c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident.
The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). LCO The Unit 2 DC electrical power subsystems each consisting of two 125 V batteries in series, two battery chargers (one per battery), and the corresponding control equipment and interconnecting cabling supplying power to the: associated (continued) Brunswick' Unit'2' B 3.8-57 Revision No. z--- --------.------:---.-----------_---
DC S:urces-Shutdown B 3.8.5 i BASES LCO bus, needed to support required DC distribution subsystems (continued) required OPERABLE by LCO 3.8.8, " Distribution Systems-Shutdown," are required to be OPERABLE. In addition, DC control power for operation of two of.the four 4.16 kV emergency buses and two of the four 480 V emergency buses, as well as control power for two of the four DGs, is provided by the Unit 1 DC electrical power subsystems. Therefore, the Unit 1 DC electrical power subsystems needed to support required components are also required to be OPERABLE. Unit 1 DC electrical power subsystem OPERABILITY requirements are the same as those required for a Unit 2 DC electrical power subsystem. This requirement ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents and inadvertent reactor vessel draindown). APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment provide assurance that:
- a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core in case of an inadvertent draindown of the reactor vessel;
- b. Required features needed to mitigate a fuel handling accident are available;
- c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
- d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
The DC electrical power requirements for MODES 1, 2, and 3 are covered in LC0 3.8.4. (continued) l i
#'] I .b Brunswick Unit 2 B 3.8-58 Revision No.
1
7 DC Sources-Shutdown B 3.8.5 BASES (continued) ACTIONS LCO 3.0.3 is not applicable while in M0DE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have 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. Entering LCO 3.0.3, while in N0DE 1, 2, or 3, would require the unit to be shutdown, but would not require l immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3.0.3 is not g applicable," ensures that the actions for immediate suspension of irradiated fuel assembly movement are not postponed due to entry into LC0 3.0.3. A.I. A.2.1. A.2.2. A.2.3. and A.2.4 If more than one DC distribution subsystem is required , according to LC0 3.8.8, the DC electrical power subsystems .. remaining OPERABLE with one or more DC electrical power subsystems inoperable may be capable of supporting sufficient eequired features to allow continuation of CORE O ALTERATION >, fuel movement, and operations with a potential for draining the reactor vessel. By allowance of the option to declare required features inoperable with associated DC electrical power subsystem (s) inoperable, appropriate restrictions are implemented in a:cordance with the affected system LCOs' ACTIONS. However, in many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and any activities that could result in inadvertent draining of the reactor vessel). Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is i accomplished in order to provide the necessary DC electrical power to the plant safety systems. . (continued) O . Brunswick Unit 2 B 3.8-59 Revision No.
DC Sources-Shutdown B 3.8.5 BASES ACTIONS- A.I. A.2.1. A.2.2. A.2.3 and A.2.4 (continued) The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during.which the plant safety systems may be without sufficient power. SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires certain Surveillance required by LCO 3.8.4 to be met. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR. This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required unless Unit 1 Specification 3.8.4, "DC s Sources-Operating," requires performance of these SRs. A j When Unit 1 Specification 3.8.4 requires performance of m these SRs, DC source availability is not limited, due to the , Unit I requirements for DC source OPERABILITY. Therefore, in this condition, other DC sources would be available to supply the required loads. I REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
1 l .A 1.) Brunswick Unit 2 B 3.8-60 Revision No. l l
Battery Cell Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Cell Parameters BASES BACKGROUND This LC0 delineates the limits on electrolyte temperature, level, float voltage, and specific gravity for the DC electrical power subsystems batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources-Operating," and LCO 3.8.5, "DC Sources-Shutdown." APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature systems are OPERABLE. The DC electrical power subsystems provide normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation. The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based O upon meeting the design basis of the unit as discussed in the Bases for LC0 3.8.4 and LC0 3.8.5. Since battery cell parameters support the operation of the DC electrical power subsystems, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). LCO Battery cell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Electrolyte limits are conservatively established, allowing continued DC electrical system function even with Category A and B limits not met. APPLICABILITY The battery cell parameters are required solely for the ' support of the associated DC electrical power subsystem. Therefore, these cell parameters are only required when the associated DC electrical power subsystem is required to be OPERABLE. Refer to the Applicability discussions in Bases for LCO 3.8.4 and LCO 3.8.5. (continued) Brunswick Unit 2 B 3.8-61 Revision No.
Battery Cell Parameters B 3.8.6 [ BASES (continued) ACTIONS The ACTIONS Table is modified by a Note indicating that a - separate Condition entry is allowed for each battery. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each battery with battery cell parameters not within limits. Complying with the Required Actions may allow for continued operation, and subsequent batteries with battery cell parameters not within limits are governed by subsequent Condition entry and application of associated Required Actions. A.I. A.2. and A 3 With parameters of one or more cells in one or more batteries not within limits (i.e., Category A limits not met or Category B limits not met, or Category A and B limits not met) but within the Category C limits specified in Table 3.8.6-1, the battery is degraded but there is still sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of Category A or B limits not met, and continued operation is permitted for a limited period. O The pilot cell (s) electrolyte level and float voltage are required to be verified to meet the Category C limits within I hour (Required Action A.1). This check provides a quick indication of the status of the remainder of the battery cells. One hour provides time to inspect the electrolyte level and to confirm the float voltage of the pilot cell (s). One hour is considered a reasonable amount of time to perform the required verification. Verification that the Category C limits are met (Required ' Action A.2) provides assurance that during the time needed to restore the parameters to the Category A and B limits, the battery is still capable of performing its intended function. A period of 24 hours is allowed to complete the initial verification because specific gravity measurements must be obtained for each connected call. Taking into , consideration both the time required to perform the required i verification and the assurance that the battery cell l parameters are not severely degraded, this time is considered reasonable. The verification is repeated at (continued) O l C/ I Brunswick Unit 2 B 3.8-62 Revision No.
Battery Cell Parameters B 3.8.6 BASES MT' WS A.I.-A.2. and A.3 (continued) 7 day intervals until the parameters are restored to Category A and B limits. This periodic verification is consistent with the normal Frequency of pilot cell Surveillance. Continued operation prior to declaring the affected batteries inoperable is permitted for 31 days before battery cell parameters must be restored to within Category A'and B limits. Taking into consideration that, while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable for operation prior to declaring the DC batteries inoperable. jkl When any battery parameter is outside the Category C limit for any connected cell, sufficient capacity to supply the maximum expected load requirement is not ensured and the corresponding DC electrical power subsystem must be declared inoperable. Additionally, other potentially extreme conditions, such as any Required Action of Condition A and associated Completion Time not met or average electrolyte temperature of representative cells < 60*F, also are cause for immediately declaring the associated DC electrical power subsystem inoperable. SURVEILLANCE SR 3.8.6.1 REQUIREMENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 4), which recommends regular battery inspections (at least one per month) including voltage, specific gravity, and electrolyte temperature of pilot cells. SR 3.8.6.2 The quarterly inspection of specific gravity and voltage is consistent with IEEE-450 (Ref. 4). (continued). O Brunswick Unit 2 B 3.8-63 Revision No.
=; . . .
'l 4
Battsry Cell Parameters B 3.8.6 l l BASES SURVEILLANCE SR 3.8.6.3 REQUIREMENTS . (continued) This Surveillance verification that the average temperature of representative cells is within limits is consistent with a recossendation of IEEE-450 (Ref. 4) that etates that the
. temperature of electrolytes-in represerAative cells should be detemined on a quarterly basis.
Lower than normal temperature's act to inhibit or reduce battery capacity. This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on pr.ufacturer's recommendations and the battery sizing calculations. Table 3.8.6-1 This Table delineates the limits on electrolyte level, float voltage, and specific gravity for three different categories. The meaning of each category is discussed below. Category A defines the normal parameter limit for each O designed pilot cell in each battery. The cells selected as pilot cells are those whose temperature, voltage, and electrolyte specific gravity approximate the state of charge of the entire battery. The Category A limits specified for electrolyte level are based on manufacturer's recommendations and are consistent with the guidance in IEEE-450 (Ref. 4), with the extra i inch allowance above the high water level indication for operating margin to account for temperature and charge effects. In addition to this allowance, Footnote (a) to Table 3.8.6-1 permits the electrolyte level to be temporarily above the specified maximum level during and following equalizing charge (i.e., for up to 3 days following the completion of an equalize charge), provided it is not overflowing. These limits ensure that the plates suffer no physical damage, and that adequate electron transfer capability is maintained in the event of transient conditions. IEEE-450 (Ref. 4) recommends that electrolyte level readings should be made only after the battery has been at float charge for at least 72 hours. (continued) O I Brunswick Unit.2 B 3.8-64 Revision No..
Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE Table 3.8.6-1 (continued) REQUIREMENTS The Category A limit specified for float voltage is a 2.13 Y per cell. This value is based on the manufacturer's recommendations and on the recommendation of IEEE-450 (Ref. 4), which states that prolonged operation of cells below 2.13 V can reduce the life expectancy of cells. The Category A limit specified for specific gravity for each pilot cell is a 1.200 (0.015 below the manufacturer's fully charged nominal specific gravity or a battery charging current that had stabilized at a low value). This value is characteristic of a charged cell with adequate capacity. According to IEEE-450 (Ref. 4), the specific gravity readings are based on a temperature of 77*F (25'C). The specific gravity readings are corrected for actual electrolyte temperature and level. For each 3*F (1.67'C) above 77'F (25'C), 1 point (0.001) is added to the reading; I point is subtracted for each 3*F below 77*F. The specific gravity of the electrolyte in a cell increases with a loss of water due to electrolysis or evaporation. Level correction will be in accordance with manufacturer's recommendations. O Category B defines the normal parameter limits for each connected cell. The term " connected cell" excludes any . battery cell that may be jumpered out. The Category B limits specified for electrolyte level and float voltage are the same as those specified for Category A and have been discussed above. The Category B limit specified for specific gravity for each connected cell is a 1.195 (0.020 below the manufacturer's fully charged, , nominal specific gravity) with the average of all connected cells a 1.205 (0.010 below the manufacturer's fully charged, nominal specific gravity). These values are based on manufacturer's recommendations. The minimum specific gravity value requirod for each cell ensures that a cell with a marginal or unacceptable specific gravity is not masked by averaging cells having higher specific gravities. Category C defines the limits for each connected cell. These values, although reduced, provide assurance that sufficient capacity exists to perform the intended function (continuedl 'O Brunswick Unit 2 B 3.8-65 Revision No.
]
Battery Cell Parameters B 3.8.6 BASES SURVEILLANCE . Table 3.8.6-1 (continued) REQUIREMENTS and maintain a margin of safety. When any battery parameter is outside the Category C limits, the assurance of-sufficient capacity described above no longer exists, and-the battery must be declared inoperable. The Category C limit specified for electrolyte level (above the top of the plates and not overflowing) ensures that the plates suffer no physical damage and maintain adequate electron transfer capability. The Category C limit for voltage is based on IEEE-450, Appendix C (Ref. 4), which states that a cell voltage of 2.07 Y or below, under float conditions and not caused by elevated temperature of the cell, indicates internal cell problems and may require cell replacement. The Category C limit on average specific gravity 2: 1.195, is 1 based on manufacturer's recommendations (0.020 below the manufacturer's recommended fully charged, nominal specific gravity). In addition to that limit, it is required that the specific gravity for each connected cell must be no less than 0.020 below the average of all connected cells. This O limit ensures that a cell with a marginal or unacceptable specific gravity is not masked by averaging with cells having higher specific gravities. The footnotes to Table 3.8.6-1 that apply to specific gravity are applicable to Category A, B, and C specific gravity. Footnote (b) requires the above mentioned correction for electrolyte level and temperature, with the exception that level correction is not required when battery charging current, while on float charge, is < 2 amps. This current provides, in general, an indication of acceptable overall battery condition. Because of specific gravity gradients that are produced during the recharging process, delays of.several days may occur while waiting for.the specific gravity to stabilize. ! A stabilized charging current is an acceptable alternative I to specific gravity measurement for determining the state of charge of the designated pilot cell. This phenomenon is discussed in IEEE-450 (Ref. 4). Footnote (c) allows the float charge current to be used as an alternate to specific (continued) Brunswick Unit 2 B 3.8-66 Revision No. i
L Battsry Cell Parameters B 3.8.6 BASES l SURVEILLANCE Table 3.8.6-1 (continued) REQUIREMENTS ) gravity for up to 7 days following a battery recharge. j Within 7 days, each connected cell's specific gravity must 3 be measured to confirm the state of charge. Following a minor battery recharge (such as equalizing charge that does. ! not follow a deep discharge) specific gravity gradients are i not significant, and confirming measurements may be made in less than 7 days. REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
- 4. IEEE Standard 450, 1987.
O [ U. Erunswick Unit 2 8 3.8-67 Revision No.
j ; Distribution Systems-Operating B 3.8.7 8 3.8 ELECTRICAL POWEfl SYSTEMS B 3.8.7 Distribution Systems-Operating BASES L 1: _
^
BACKGROUND The onsite Class IE AC and DC electrical power distribution system is divided into redundant .nd independent AC and DC i electrical power distribution subsystems. , The Class IE AC electrical distribution system is divided into four load groups. Each load group consists of a primary emergency bus, its downstream secondary emergency bus,120 VAC vital bus, and transformers and interconnecting cables. The buses associated with each of the four load groups are defined as follows: Load group El consists of 4.16 kV bus El, 480 V bus E5, and 120 VAC vital bus IES. Load group E2 censists of 4.16 kV bus E2, 480 V bus E6, and 120 VAC vital bus IE6. , Load group E3 consists of 4.16 kV bus E3, 480 V b pd bus E7, and 120 VAC vital bus 2E7. Load group E4 consists of 4.16 kV bus E4, 400 V bus E8, and 120 VAC vital bus 2E8. I I The El and E2 load groups are supplied from Unit 1 balance of plant (BOP) buses and primarily serve Unit 1 loads. The E3 and E4 load groups are supplied from Unit 2 B0P buses and primarily serve Unit 2 loads. In some instances loads associated with one unit are actually supplied from the opposite unit's load group buses. Each primary emergency bus (4.16 kV emergency bus) has acce!s to two offsite sources of power via a common circuit path from its associated upstream B0P bus (master / slave breakers and interconnecting cables). In addition, each 4.16 kV emergency bus can be provided power from an onsite diesel generator (DG) source. The upstream BOP bus associated with each 4.16 kV emergency bus is normally connected to the main generator output.via the unit auxiliary transformer. During a loss of the normal. po9er source to the 4.16 kV B0P bus, the preferred source supply breaker attempts to close. If all affsite sources are l fesntinued)
'( !
l Brunswick Unit-2 B 3.8-68 Revision No. ! l
Distribution Systems-Operating B 3.8.7 BASES , BACKGROUND (Continued) unavailable, the affected 4.16 kV emergency. bus is isolated
-from its associated upstream 4.16 kV B0P bus and the onsite b
emergency DG will supply power to the 4.16 kV emergency bus. Control power for each 4.16'kV~ emergency bus is supplied. from a Class 1E battery with manual transfer capability to another Class IE battery. Additional descriptions of this system may be found in the Bases for Specification 3.8.1, "AC Sources-Operating," and the Bases for Specification 3.8.4, "DC Sources-Operating". The secondary plant distribution system includes 480 VAC emergency buses ES, E6, E7, and E8 and associated motor control centers (MCCs), transformers, and interconnecting cables. Secondary emergency buses E5, E6, E7, and E8 are b supplied from primary emergency buses El, E2, E3, and E4, respectively. Control power for each 480 VAC emergency bus is supplied from a Class 1E battery with manual transfer capability to another Class IE battery. Additional descriptions of this system may be founo in the Bases for Specification 3.8.4, "DC Sources-Operating". The 120 VAC vital buses IES, IE6, 2E7, and 2E8 are arranged in four load groups and are powered from secondary emergency g O buses E5, E6, E7, and E8, respectively. There are two independent 125/250 VDC electrical power distribution subsystems. The list of required distribution buses is presented in Table B 3.8.7-1. APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC and DC electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant-System, and containment design limits are not exceeded. _These limits are discussed in more detail in the Bases for Section 3.2, " Power Distribution Limits"; Section 3.5, " Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System"; and Section 3.6, " Containment Systems." (continued) O Brunswick Unit 2 'B 3.8-69 Revision No. __.-.._m-___.-__m__- _ _ _ _ _ _.:--,.m___. -
Distribution Systems-Operating B 3.8.7 BASES APPLICABLE The OPERABILITY of the AC and DC electrical power SAFETY ANALYSES distribution subsystems is consistent with the initial (continued) . assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining distribution systems OPERABLE during accident' conditions in the event of:
- a. An assumed loss-of all offsite power; and
- b. A worst case single failure.
The AC and DC electrical power distribution system satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). LCO The required electrical power distribution subsystems listed in Table B 3.8.7-1 ensure the availability of AC and DC electrical power for the systems required to shut down the l reactor and maintain it in a safe condition after an anticipated operational occurrence (A00) or a postulated DBA. The Unit 2 AC and DC electrical power distribution subsystems are required to be OPERABLE. In addition, since some components required by Unit 2 receive power through O. Unit 1 DC electrical power distribution subsystems (e.g., control power for two of the four 4.16 kV emergency buses, two of the four 480 VAC emergency buses, and for two of the DGs, and two of four engineered safeguard system (ESS) panels), the Unit 1 DC electrical power distribution subsystems needed to support the required equipment must also be OPERABLE. As stated in Table B 3.8.7-1, each division of the AC and DC electrical power distribution systems is a subsystem. Maintaining the Division I and II AC and DC electrical power distribution subsystems OPERABLE ensures that the redundancy incorporated into the design of ESF-is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor. The AC electrical power distribution subsystems require the i associated buses and electrical circuits to be energized to their proper voltages. The DC electrical power distribution subsystems require the associated buses to be energized to their proper voltage from either the associated batteries or chargers. (continued)
. f y Brunswick Unit 2. B 3.8-70 Revision No.
1
-_____-__A
c . Distribution Systems-Operating B 3.8.7 BASES LC0 Based on the number of safety significant electrical loads (continued) associated with each bus listed in Table B 3.8.7-1, if one or more of the buses becomes inoperable, entry into the l appropriate ACTIONS of LCO 3.8.7 is required. Other buses, such as MCCs and distribution panels, which help comprise i the AC and DC distribution systems are not listed in Table B 3.8.7-1. The loss of electrical loads associated with these buses may not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., a breaker supplying a single MCC fails open), the individual loads on the bus must be declared inoperabic, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.7-1 (e.g., loss of a 4.16 kV emergency bus, which results in de-energization f all buses powered from the 4.16 kV emergency bus), then although the individual loads are still considered inoperable, the l Conditions and Required Actions of the LCO for the O individual loads are not required to be entered, since LC0 3.0.6 allows this exception (i.e., the loads are inoperable due to the inoperability of a support system governed by a Technical Specification; the 4.16 kV emergency bus). In addition, tie breakers and transfer switches between redundant safety related AC and DC power distribution subsystems, if they exist, must be open. This includes control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, which could cause the failure of a redundant subsystem and a loss of essential safety function (s). If any tie breakers are closed or transfer switches aligned to the alternate sepply, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related, redundant electrical power distribution subsystems. It does not, however, preclude redundant Class IE 4.16 kV emergency buses from being powered from the , same offsite circuit. 1 i (continued) O Brunswick Unit 2 B 3.8-71 Revision No. l - - - - - ---------- _ _ _ _
Distribution Systems-Operating B 3.8.7 BASES (continued) APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES I, 2, and 3 to ensure that:
- a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and l
- b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.
Electrical power distribution subsystem requirements for MODES 4 and 5 and other conditions in which AC and DC electrical power distribution subsystems are required are covered in the Bases for LC0 3.8.8, " Distribution Systems-Shutdown. " ACTIONS A_d With one or more required AC buses or distribution panels in one division inoperable, the remaining AC electrical power distribution subsystems are capable of supporting the b' O minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no i single failure. The overall reliability is reduced, i i however, because a single failure in the remaining AC i l electrical power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, and distribution panels must be restored to OPERABLE status within 8 hours. The Condition A worst scenario is one division without AC I'b power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit and restoring power to the affected division. The 8 hour time limit before requiring a unit shutdown in this Condition is acceptable because of: (continued) O Brunswick Unit 2 B 3.8-72 Revision No.
7 I Distribution Systems-Operating B 3.8.7 BASES ACTIONS M (continued)
- a. The potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit,
- b. The low potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERA 8LE in accordance with Specification 5.5.11, " Safety Function Determination l Program (SFDP).")
The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently returned OPERABLE, this LCO may already have been not met O for up to 7 days. This situation could lead to a total duration of 176 hours, since initial failure to meet the LCO, to restore the AC electrical power distribution system. At this time a DC bus could again become inoperable, and the AC electrical power distribution system could be restored OPERABLE. This could continue indefinitely. This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This results in establishing the " time zero" at the time this LCO was initially not met, instead of at the time A Condition A was entered. The 176 hour Completion Time is an (fG acceptable limitation on this potential to fail to meet the LCO indefinitely. B.1. B.2. B.3 and B.4 With one or mere DC electrical power distribution sut' systems inoperable due to loss of normal DC source, the remaining DC electrical power distribution subsystem (s) are capable of supporting the minimum safety functions necessary to shutdown the reactor and maintain-it in a safe shutdown condition, provided safety function _is not lost and assuming - no single failure. However, the overall reliability is (continued) l Brunswick Unit 2- B 3.8-73 Revision No.
i Distribution Systems-Operating B 3.8.7 l BASES ACTIONS B.1. B.2. B.3 and B.4 (continued) reduced because a single failure in the DC electrical power distribution system could result in a loss of two of four AC electrical load groups and the minimum required ESF functions not being supported. Therefore, action must be immediately initiated to transfer the DC electrical power distribution system to its alternate source and the affected a supported equipment immediately declared inoperable. Upon a completion of the transfer of the affected supported /A_1 j equipment's DC electrical power distribution subsystem to 1 its OPERABLE alternate DC source, the affected supported 1 equipment may be declared OPERABLE again. The ESS logic ' cabinets transfer automatically upon loss of the normal source. For an ESS logic cabinet, verification that the automatic transfer has occurred and alternate power is available to the ESS logic cabinet will satisfy Required i Action B.2. By allowance of the option to declare affected supported equipment inoperable with associated DC electrical power distribution subsystems inoperable due to loss of normal DC source, more conservative restrictions are implemented in accordance with the affected system LCOs' ACTIONS. When any control power transfer switch associated
.hq with the 4.16 kV and 480 V emergency buses or any transfer switch associated with the ESS and DG panels is transferred to the alternate source, a : ingle failure in the DC system could render two of four AC electrical load groups inoperable. Therefore, to prevent indefinite operation in this degraded condition, power from the normal DC source l must be restored in 7 days.
l- 'i he Completion Time of immediately is consistent with the i required times'for actions requiring prompt attention. Required Actions B.1 and B.2 should be completed as quickly as possible. The 7 day Completion Time of Required Action B.4 is considered to be acceptable due to the low )ds potential for an event in conjunction with a single failure of a redundant component and is consistent with the allowed l Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-Operating." The second Completion Time for Required Action B.4 establishes a limit on the maximum time allowed for any h i combination of required electrical power distribution ! subsystems to be inoperable during any single contiguous i occurrence of failing to meet the LCO. If Condition B is I l O- (continued) V Brunswick Unit 2 B 3.8-74 Revision No. 1 i
Distribution Syst=s-Operating B 3.8.7 I
'8ASES ACTIONS 8.1. 8.2. B.3 and B.4 (continued) entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours. This situation could lead to a total duration of 176 hours, since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be restored OPERABLE. This could continue indefinitely.
This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This allowance results in establishing the " time zero" at the time the LCO was initially not met, instead of at the a time Condition B was entered. The 176 hour Completion Time LO is an acceptable limitation on this potential of failing to meet the LCO indefinitely. S.d With one DC electrical power distribution subsystem inoperable for reasons other than Condition B, the remaining DC electrical power distribution subsystem is capable of b supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC electrical pcw r distribution subsystem must be restored to OPERABLE status within 7 days by powering the bus from the associated batteries or chargers. Condition C represents one division without adequate DC b power, potentially with both the battery (s) significantly degraded and the associated charger (s) nonfunctioning. In this situation the plant is significantly more vulnerable to a complete loss of all DC power. It is', therefore, imperative that the operator's attention focus on )
- stabilizing the plant, minimizing the potential for loss.of power to the remaining divisions, and restoring power to the affected division.
(continued) Brunswick Unit 2' 'B 3.8-75 Revision No.;
'{
l
Distribution Systems-Operatir:g B 3.8.7 BASES ACTIONS [ d (continued) The 7 day Completion Time is consistent with the allowed Completion Time for an inoperable DC electrical power subsystem specified in Specification 3.8.4, "DC Sources-Operating". Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 7 days, is acceptable because of:
- a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue;
- b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division;
- c. The low potential for an event in conjunction with a O single failure of a redundant component.
The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required electrical power distribution subsystem.c to be inoperable during any single contiguous occurrencu of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 may already have been not met for up to 8 hours. This situation could lead to a total duration of 176 hours, since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be restored 0,'ERABLE. This could continue indefinitely. This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock."
This allowance results in establishing the " time zero" at the time the LC0 was initially not met, instead of at the time Condition C was entered. The 176 hour Completion Time is an' acceptable limitation on this potential of failing to meet the LCO indefinitely. (continued) Brunswick Unit 2- B 3.8-76 Revision No.
Distribution Systems-Optrating B 3.8.7 . BASES ACTIONS D.] and D.2 (continued) If the inoperable electrical power distribution subsystem (s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to NODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the l required plant conditions from full power conditions in an orderly manner and without challenging plant systems. E.d b Condition E corresponds to a level of degradation in the. electrical power distribution system that causes a required safety function to be lost. When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no-additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a ( controlled shutdown. SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance V:rifies that the AC and DC electrical power distribution systems are functioning properly, with , the correct circuit breaker alignment. This includes verifying that distribution bus tie breakers are open and control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels are aligned to their normal DC sources. The correct breaker alignment ensures the appropriate separation and independence of the electrical L buses are maintained, and power is available to each required bus. The verification of energization of the buses g ensures that the required power is readily available for motive as well. as control functions for critical system loads connected to these buses. . This may be performed by verification of absence of low voltage alarms or by verifying a load powered from the bus is operating. The (continued) o Brunswick Unit 2 B 3.8-77 Revision No.
1 Distribution Systems-Operating B 3.8.7 BASES SURVEILLANCE SR 3.8.7.1 (continued) REQUIREMENTS 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. SR 3.8.7.2 This Surveillance verifies that no combination of more than two power conversion modules (consisting of either two lighting inverters or one lighting inverter and one plant uninterruptible power supply unit) are aligned to a Division II (bus B). Two power conversion modules aligned m to Division II (bus B) was an initial assumption in the DC battery load study. Limiting two power conversion modules to be aligned to Division II ensures the associated batteries will supply DC power to-safety related equipment during a design basis event. The 7 day Frequency takes into account the redundant capability of the DC electrical power distribution subsystems and indications available in the control room to alert the operator of power conversion O, module misalignment. g REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
O Brunswick Unit 2 B 3.8-78 Revision No.
Distribution Systems-Operating l B 3.8.7 Table B 3.8.7-1 (page 1 of 1) AC and DC Electrical Power Distribution Systems TYPE VOLTAGE DIVISION I(a) DIVISION II(a) AC emergency 4160 V Emergency Buses Emergency Buses buses El, E3 E2, E4 480 V Emergency Buses Emergency Buses E5, E7 E6, E8 AC vital buses 120 V Distribution Distribution Panels Panels IES, 2E7 IE6, 2E8 DC' buses 250 V Switchboard 2A Switchboard 2B 125 V ESS logic ESS logic Cabinets Cabinets H58, H60 H59, H61 12S V DG Panels DG Panels O DG-1, DG-3 DG-2, DG-4 DC control 125 V 4.16 kV Switchgear 4.16 kV Switchgear i power buses El, E3 E2, E4 125 V 480 V 480 V
- Switchgear Switchgear ES, E7 E6, E8 (a) Each division of the AC and DC electrical power distribution systems is a subsystem.
l O' Brunswick Unit 2 B 3.8-79 Revision No. l
Distribution Systems-Shutdown B 3.8.8 8 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Distribution Systems-Shutdown BASES BACKGROUND A description of the AC and DC electrical power distribution system is provided in the Bases for LC0 3.8.7, " Distribution Systems-Operating. " APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref.1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC and DC electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. The OPERABILITY of the AC and DC electrical power
^
distribution system is consistent with the initial assumptions of the accident analyses and the requirements I for the supported systems' OPERABILITY. The OPERABILITY of the minimum AC and DC electrical power sources and associated power distribution subsystems during MODES 4 and 5, and during movement of irradiated fuel assemblies in the secondary containment ensures that:
- a. The facility can be maintained in the shutdown or refueling condition for extended periods;
- b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and l
- c. Adequate power is provided to mitigate events postulated during shutdown, such as an inadvertent draindown of the vessel or a fuel handling accident.
The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). (continued) O V l Brunswick Unit 2 B 3.8-80 Revision No.
I i-Distribution Systems-Shutdown B 3.8.8 BASES (continued) LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to. support OPERABILITY of Technical Specifications required systems, equipment, and components-both specifically addressed by their own LCO, and implicitly required by the . definition of OPERABILITY. In addition, DC control power for operation of two of the four 4.16 kV emergency buses and two of the four 480 V emergency buses, as well as control power for two of the four diesel generators, is provided by the Unit 1 DC electrical power subsystems. Therefore, the Unit 1 DC electrical. power distribution subsystems needed to support required components are also required to be OPERABLE. In addition, it is acceptable for required buses to be { cross-tied during shutdown conditions, permitting a single source to supply multiple redundant buses, provided the source is capable of maintaining proper frequency (if required) and voltage.
.O Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,
fuel handling accidents and inadvertent reactor vessel draindown). APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment provide assurance that:
- a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core in case of an inadvertent draindown of the reactor .
vessel; l
- b. Systems needed to mitigate a fuel handling accident are available; (continued) '
i O Brunswick Unit 2 B 3.8-81 Revision No.
Distribution Systems-Shutdown B 3.8.8 BASES APPLICABILITY c. Systems necessary to mitigate the effects of (continued) events that can lead to core damage during shutdown are available; and
- d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
The AC and DC electrical power distribution subsystem requirements for MODES 1, 2, and 3 are covered in LC0 3.8.7. ] ACTIONS LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LC0 3.0.3 is not applicable. If movino 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. Entering LC0 3.0.3, while in MODE 1, 2, or 3, would require the unit to be shutdown, but would not require ( immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3.0.3 is net 9 applicable," ensures that the actions for immediate suspension of irradiated fuel assembly movement are not g postponed due to entry into LC0 3.0.3. A.I. A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 Although redundant required features may require redundant divisions of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem division may ; be capable of supporting sufficient required features to l allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for draining the reactor vessel. By allowing the option te declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LC0's Required Actions. In many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made, (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and any activities that could result in inadvertent draining of the reactor vessel). (continued) Brunswick Unit 2 B 3.8-82 Revision No. I l
I Distribution Systers-Shutdown ( B 3.8.8 BASES ACTIONS A.1. A.2.1. A.2.2. A.2.3. A.2.4. and A.2.5 (continued) Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems. Notwithstanding performance of the above conservative Required Actions, a required residual heat removal-shutdown cooling (RHR-SDC) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LC0 3.0.6, the RHR-SDC ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR-SDC inoperable and not in operation, which results in taking the appropriate RHR-SDC ACTIONS. O The Completion Time of immediately is consistent with the ( required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power. SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution subsystems are functioning properly, with the correct breaker alignment. The correct breaker alignment ensures power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for motive _as well as control functions for critical system leads connected to these buses. This may be performed by verification of the absence of low voltage alarms or by verifying a load powered from the bus is operating. The 7 day Frequency takes into account the redundant capability of the electrical power distribution subsystems, as well as other indications available in the control room that alert the operator to subsystem malfunctions. (continued) m N Brunswick Unit 2 B 3.8-83 Revision No.
Distribution Systems-Shutdorn B 3.8.8 BASES '(continued)
' REFERENCES 1. UFSAR, Chapter 6.
- 2. UFSAR, Chapter 15.
- 3. 10 CFR 50.36(c)(2)(ii).
O l l 1 l Brunswick Unit 2 B 3.8 Revision No.
i a C OA 8*f
'., J , . cf.s.,,. n., , 1_, .
j h .. o. . c. , w . . . . , ;e, :. . . _, .w . . . c , , ., I c h4 LIMITINGCON0ThNSFOROPERATIONANDSURVEILLANREQUIREMENTS V) t _ 3/4.0 APPLICABILITY ,- LIMITING CONDITION FOR OPERATION, 3.0.1 Limiting Conditions for Operation and ACTION requirements shall be g applicable during the OPERATIONAL CONDITIONS or other states specified for each specification. 3.0.2 Adherence to the requirements of the Limiting Condition for Operation D and associated ACTION within the specified time interval shall constitute compliance with the specification. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval. completion of the ACTION statement is not required. 3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification. the unit shall be placed in at least HOT SHUTOOWN within 6 hours and in COLD SHUTDOWN within the following 30 hours unless corrective measures are completed that permit operation under the permissible ACTION statements for the specified time interval as measured from initial discovery or until the reactor. is placed in an OPERATIONAL CONDITION in which the specification is not applicable. Exceptions to these ' requirements shall be stated in the individual specifications. 3.0.4 When a Limiting Condition for Operation is not met, entry into an OPERATIONAL CONDITION or other specified applicability state shall not be made except when the associated actions to be entered permit continued operation in I- licability state for an b) the OPERATIONAL unlimited CONDITION period of time. or other specified This specification s apkall not prevent chang'es in OPERATIONAL CONDITIONS or other specified applicability states that are required to comply with ACTION requirements. Except. ! ions to this specification are stated in the individual specifications. These exceptions allow entry into OPERATIONAL CONDITIONS or other specified applicability states when the associated actions to be entered allow unit operation in the OPERATIONAL CONDITIONS or other specified applicability states only for a limited period of time. LL 3.0.5 When a system. subsystem, train. component or device is determined to be inoperable solely because its emergency power source is inoperable, or
,P 9 @' sole because its normal power source is inoperable. it may be considered OPEgLE for the purpose of satisfying the requirements of its applicable IkM f limiting Condition for Operation. provided: (1) its corresponding normal or emergency power source is OPERABLE: and (2) all of its redundant system (s).
l 3*7'c2j subsystems (s), t ain(s), component (s) and device (s) are OPERABLE or likewis satisfy the renMrmnts of this soeM fi"Hnn .less both con ' ions (1) k d4 DjI a 51ftisfied. the uni .,all be plac in at least HUTDOWN within ours, and in'at st COLD SHUL within the f owing 30 h s. ification is applicable in ditions 4 or 7 lQi L.2-p BRUNSWICK - UNIT 1 3/4 0-1 Amendment No. 1 (j F775G$ fagelo%l6
- n.- -
V.3, . .r J j V . 3S.8ELECTRICALPOWERSYSTEMS 1 M .8.1 iTC, SOURCES h0PERAT!h l tvutetur <nunterna rna nornivenu l fCo ~3.8.l -3.0.1.1 ';c'." -,
- ~-
efollowingd[C.electricalpowersourcesshallbe OPERABLE
- a. Two yhy:!::117 ind:;:nd:x deircuitsp ;:- ni;,'between the offsite l transmissionnetworkandtheonsiteClass1E41styibution/ystem*and ffDhSd
,{ D.I.C- b. Four ::p .4 I r.dep...de..; diesel gene rato s J. . .
$lk 3.f.f,{ N.1 A separate engine-mounted fuel tank containing a minimum of lions of fuel,
^
A separate day fuet tank containing a minimum of 22,650 gattog' g,q
,g' bT :12.
' t of fuel, M
'Ls
-Z15*,78,3
; 3 g 3. y. t.(,
A.3
- 3. A separate fuel tran,sfer pump.
w ..h j ,, j c. A plant fuel storage tank containing a minimum of 74,000 gallons of
- ( fuel. _
APPLICABILITY F OPES %T46thH:-4iGN&lHONS 1, 2, and 3. ACTIOK3) gje.$r-f9A5e^Sobr'
,f I. ,. k With one offsite circuit ef th: 25c e -erir:d . 0. e l e n . . . ! ,~ -4 gn.2,;,
. . .. - . .ce: =_. ..,.u : ef : ,,;,ie n e. a . . . u . . . . . a,. a . .. < - l 6 i s% ! Demonstrate the OPERABILITY of the remaining A'C., , offsite source by perf o rming U * " --- " ,_. . __ n ' .0. ! 1_1 within 2
' lr ,
. g g [, hours and at least once per 12 hours thereaf ter;
' 2 De nstra the OP ILIT f the iesel nera ors gj
' _' ' rfor g Surv ' lance quires ts 4.8 .1.2 .4 4.8. .2.a.5 ithin hours d at 1 st e 72 s I, [ ,
th eafter 3 7,, M#^/ Restore ;t.: 'n:;_.. Lie offnite circuit to OPERABLE status withi
' . M b. 761 72 hours /UT~5e~In at least HOT SHUTDOWN within the next 12 hdurs "
grgod (p . - (and in COLD SHUTDOWN within the--f ol4 wing ,24 hours. m.t. y ,.. , y A g Mi4bA N G -
' ^"E"_,. .g :-2~'^" 4 o r -C nd one C..
- .. " Qi th Uni t 2 *in . . - . :v ir:d Q'A6 4 nit 2 offsite.powes-circultfbr NMr :f .; .e ;'. , ... ; t.- ... u f ped r- "12: ? ?? II:tr'S !^ r---feither restore the~ inoperable Unit _2 Mod I,-'.-fof f site circuit tri ^*(RABLE status within_45 days Er place Unit l
$ 7
'* HOT STUf OWN within the next 12 hours and in COLD' .-
er
- h ~ b t,,}.gastSHUTDOWN wit hin the -fo45owifig-24*nours#--- r.- . . -. - - . - - - - - - - b j 4g;Q A - M . _ : . '- '
- L' F _
r-' ? . : _ ? - ' = ~ :;;!'::5!c. e7, A- BRUNSWICK - UNIT 1 3/4 8-1 Amendment No. 145 -( (g) - s i r g 73e. 2/r 16
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"3,g ELECTRICAL POWER SYSTEMS .
LIMITING CONDITION FOR OPERATION (Continued)
. . . ACTION (Continued)*
' 0" b : ea b l O . . - :--
AA T die generator all be co ered t ino pe ra tros th time of l fa re until i atisfies e requlr nts of S et11ance uirene
.8.1.1.2.a. and 4.8.1 .2.a.5. -f BRUNSWICK - UNIT 1 3/4 8-la Amendment No. 145 l b .
,~
~
< i 5, v -
(fQ,n;f}nf *],f,f A I elegy"' AL PO#ER SYSTEMS LIMITING CONDITION FOR OPERATION (centinued) 1CTION (continued) C'wcmh
- 1. Demonstrate the OPERABILITY of the A.C. offsite soarews'by
~~
g Q4 perfonning h r ' P -- M' -- e ? . i .1. i _ within 2 hours h and at least once per 12 hours thereafter; def9 [,. g {SE y,3.J,I3
- 2. DemonstratetheOPERABILITYofthe! ; diesel generataqtr)by
,' Q g g performing m;;ill .r.;;
".c s. . ._n; i . a .1.1. 2. - ' " . - - g y,g. ),2. or-f -0.0.1.1.0. .5 within 24 hours eM = 1;;;; ::r: r e. ? ggg 4Q
*S* ' 5' E Gm 6:;;;; g gy g bM f M
- 3. [ Restore the 4noposable diesel generator to OPERABLE status with_in L 7 da en COLD rs be in as Aeast HOT SHITTDvure wAuuu uaa nex
, [
~
SHITTDOWN within the following 24 hours. g 12 hours
$CT104 h
.g g c. I With one offsite circuit and one diesel generator c:-{.t d : c; b = W i-M :..:. ;1::tri: 1 ;:r:: r- inoperable: y dh M 80 h 3 j Demonstrate the OPERABILITY of the CPutA t1
- g q A.C., sources by diheN OI EkI 8 . 1. g g g' -
l YL 14'
- c. C.3 2-M performing Surveillance Requirements - -
" :.:.1.1,:...s within a hours and at least once per.ri hours -
Sr - 1 --,,, e b. g ) g w J u b mC.4 4 E) thereafteri 7 z,.; a -o s een Wp .
% C"t104 03.1 of LJ. -
"$( 3.3. l.I C 2. ( Restore at-least one of the inoperable-sources 'to OPERABLE statust ~)
f**Y"' I M I* 2-Tft.'l hour E8 within r be in at least HOT SHU D OWN within the next 12 I'* iY
' gg73g,3 h ,, hours and n COLD SHITTDOWN within die following 24 hours; _
h
-. e- ,,; restored,
.g gg 3. With the inoperable offsite
- ;;;; ~
i j4 demonstrate the OPERADILp of the yrr_r' 8 ; ?.C. :J: . ~ . -
'% as required by ACTION ,bi* restore four diesel generatorsg_a .
,o.
iCA (OPERABLE status within 7.. days (feogr time-ef tettssa-dospor be in) gpg at least HOT snuwwm widaiu cne next 12 nours and in COLD f within the following 24 hourss f G, s
- 4. fwiththeinoperabledieselgeneratorrestored,demonstratethe gP.M l OPERABILITY-of;thp remaining-A.C. power sources a's kequired'by v Ac h 6,lk I,3 ACTION!adestoft M offsite circuj_tg to OPERABLE statum whhf r.
- 72 hours y:Iam,J,ess pr. sna,perA Ayd. lu wt-TWKat HOT SHITTDOWN) j Q gg ithin cne next 12 hours and in COLD SHUTDOWN within the following 24 hours f .
bMk h With two Of " d _ . _ . . -- ' Moffolte d-e circuits inoperable:
/of four diese s 1. stra he OPERABIL .nerators by ]
f perfo g Surveill Requirements .1.1.2.a.4 and t
- i.
4.8. .2.a.5 wi two hours an least once pe hours
- t eafter, un1 the diesel erators are air yoperatip Du g the Brun k Unit 2 Refuell Outage No. 9 a one time sis, Di el
- 6 G .erator 3 or Diesel Gene or Number 4 each be in le for to ;
4 days to rt planned mai nance activi e, provided remaini three , diesel ge ators are OPE . Restore t inoperable D el Gener or / Number r Diesel Genera Number 4 to 'RABLE status thin 14 s or be in j i at le t HOT SHtTTDOWN in the next hours and in LD S within Q1 wing 24 hours. _ J l BRUNSWICK = UNIT 1 3/4 S-2 Amendment No. 155 i .- U - [4 Y "W ______._-________________ w
b &cqYo S.R.{ ELECTRICAL PCWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued) AC*rION (Continued) h10 bnD
. 2. Restore 1st--te1rst6one e' the ir~;rr "'? offsite .;~ wo h#g' p#p" PERABLE status within 24 hours,Jtif'se an ac Aeast ktJA huvaw h.1 (within-cne next A4 nours and in COLD SHUTDOWN within the g g g d following 24 hours; f- a With one offsite source restored, demonstrate the OPERAB,ILITY of ],
d $h5) 3. the remaining I..C. power sources as required by ACTION ); restore / g g,g b,d $ 3 /"" b3 two offsite circuits to OPERABLE status,within *12 hours (L.
- ' ice k 0- 6 hiel luss E be in at least nur suv woWN within the next 12 OD4h 'q hours and in COLD SHDTDOWN within the following 24 hours.
Ce,J;% F hith two of the .a~. . = :;f diesel enerators inoperable
- ' &N OPE 40&L g ,.,) / M. j 1. Demonstrate the OPERABILITY of e a . an.ng A.C. power sources N y~y'
) by performing Surveillance Requirements C -
J. ' C.I, C M ) c.q w.-a- -- 2 - " within 2 hours and at lease rmo: ( per 12 hours thereafter; W o,J a3 ;d b /cnow y C,7.I orc'3-u.;;; diesel- generator ( to OPERABLE status (Restore a+ '! u'.<M Sc[* I* ( 2.Lwithin 2 hoursj;r ce in at Aeast HOT SHOTDOWN within the nEx b I p g g A rs and in COi.D SHDTDOWN within the following 24 hours;
. , _1
- 3. -- With one djesol generator, restored, demonstrate the OPERMILITY c-E,M $b5 f st'ori the remaining st least 4 diesel generators'to OPERABLE status with . 7 A.C. .p(wer sources as-required by AcTI :n 4 in j L*3 '
j g,l 44/ d.).1.
.d M C.Y day f re_-_ tir: :f-i"-4 C Ing,sTor be in at least-HOT SHUTDOWM l
,/ l
_12 nours and)n COLD SHt.MDOWN4ithin the / following 24,.-fiours. MNb (['.,.within the next# # _ . . . - 3[tOfoM , [CT104 .N SURVEILLANCE REOUIREMMrrS 3 4d ' '2- - Each of th; :L ;; required independent circuits between the offsite # h , transmission network and the onsite Class 1E distribution system shall be:
' ~ L.D I
- a. ( Determined OPERABLE at least once per 7 days by verifying correct
, M 3.3./.l[ breaker alignment)( and indicated power availability, and
- b. Demonstrated OPERABLE at least once per indhut[owhby R 3.8. l . F.g manually transferring unit power supply from the @) circuit to the j g alte g a circuit.
ceh aJi g g t s c. u . u .. M p7c. / fo T2. 3.Tr.s.F gg . b t . Se 3.t.1.7 _
*Durin the Sninswic t 2 Refuelja[ Outage No. 9, on a one time ba , Diesel Gene or Number d Diesel etator Number 4 may afh be in able for up ,
t 4 days.to rt plann intenance activ es, provid the remainin roe diesel enerators ar PERABLE. Restor e inoperab iesel Ger.er r number 3 lesel Gener r Number 4 to OPE LE status w 14 days e in et leas
- 10r SWJrDOWN thin the next 12 urs and in SHUTDOWN in the low g 24 hours.
BRUNSWICK - UNIT 1 3/4 8-3 Amendment No. 155
').
gefel6
Spe<;4<dM 3.7. I A.I
; ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
CX.14.2)EachdieselgeneratorshallbedemonstratedOPERABLE:
- a. At least once per 31 days @je 5tK6ERFE TESTM N 54.52.t.4 @ Verifying the fuel level in the engine-mounted fuel tank. g I sg 1.t.t.5) g Gerifying the fuel level in the day fuel tank d /,I
& 3.t.i. (, @, Verifying the fuel transfer pump can be started and transfers fuel from the day tan the engine mountet tank, ed<>
l 4 2 ..J s g. h t.s.2. @ Verifyina the diesel qingss Ean or"eauaMo_ Mecar US.ap
;s and deelerateNo aisleast SDN@))
,, g Verifyi
~
erator is synchronized, luoE 5'u j[hII* $ Ion C839t3 or ua t . and operates for greater than or equal to
@M2M3 m nutes. a Gamw a 4 tm b ., q= I 4* mo WQ An ot o t c b 1 pff'"f g 'y ^ f. At least once per J1 days Dy verifying the fuel level in the plan fuel storage tank. Q d c. At least once per 92 days by verifying that a sample of diesel fuel /G from the fuel storage tank, obtained in accordance with ASTH-D27
() 5 is within the acceptable limits specified in Table 1 of ASTH-D975j-7 ( when checked for viscosity. water and sedimenty l
*f At least once per ** l 1 (@
** ' D . Aubj tne edes to an specti n ac nce wi ,,
/ proc es p ed in c ction h its factu s ggs rec _.-- dati for this ass of andby s__ ice.,
,w u tu %. .< A.In I*dh Verifying
~ ' ' (f2 04'; c r* 'Pr """9 "' eratorcapabilitytorejectaloadequaltoD t" "t tr' 99'"9 - e-Q ut f< eu8 3 U M 4 4m volk
-# gag *t s' t 87*t d "*' nsov 4 sk * "*k I 18 A#*I '
M w W. L R 5.t.t.'1 (# The diesel generator star $10 seconds) from ambient conditions /shall be (d J 4,~, e n.t aa ..J :( t.n 4) ( rformed at least once per 184 days in these surveillance tests. All o r engine starts for the ouroose of this surveillance testing may be A gug),,2
- w. ( )receced by[^ajmanuai -init ted\ engine prelube period erMor oHier warmup)g,,3 OB Ai3 )ootecorA w um- by manuIm.oum jo onot mp.nonn.o votre33 ps par /bn th/ diese enaine s minisfireds p ,, k,
- Surveillance Requirements 4.8.1.1.2.d.2. 4.8.1.1.2.d.3.C4%1/2.ar'6) and
_ g S s .i.q s, g g. .if 4.8.1.1.2.d.7 shall not be performed for diesel generator.1 or Z with Unit 1 in OPERATIONAL CONDITION 1, 2. or 3. k m $ir[3.t.t.i4 BRUNSWICK - UNIT 1 3/4 8-4 Amendment No. l
*T5c 9M 5B67 S&eA*
Tay o l of Ih
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* ~
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. ,n -
- $'00^ E.f,[:
. 6-Is. g.As .5% sa Jeg a mV,J O .
& Hoo6 ELECTRICAL POWER SYSTEMS
- 4. ~;s:., M,.Ne Ca9wy a o.ne g g g g'/
SURVEILLANCE REQUIREMENTS (Continued) N# of offsite power in conjunction with an adel ar-
/ OM
[3. u atin 1 emergency core CoJ1ing system tre64 dignal, andt j)m=14 Q) Unwhb 6 b*i *g aA, Verifying Je-energitation of the emergency buses'j load y,g. g. W shedding from the ese y buses. I M. . Verifying the diese}/ starts from conditichon the auto-start signal l%nergizes _the emergency buses with permanentlyconnectedloadsQnergizesthe_ auto-cor.ntce g g$
@erK oads through the load sequente relays and$operatesg 8^HAWM l greater than or equal to 5 minutes while its generator as y losded with the emergency loads. 47 i ( b"- i(~ GUcre nva h t
.IVerifyingthat on the emergency core cooling system b st signal, gg , all diesel differentia nerator trips except engine overspeed, generator low Lube oil pressure, reverse power, loss of h
N I* E' I D fleid and phase overcurrent with soltage restraint, are GM automatically bypassed.
'l '
3 5 Verifying the diesel generator operates for greater than or Af
$ g 3' g,g,ft equal to 60 m utan while loaded to greater ch=a a n- =a"=1 to 3500 kw ord 6 '3gro KO
~ $ H e h eo4 6 0.T )
t 2 e a M & dk f.8././3
,g 7. [VerifyingthattheautmaticloadsequencerelaysareOPERABLE 3,g g.l3 Lwith each oad equenc within 10% of @ :;; m : ::::q.
l l b Si9 iO Ql?.se)Ac!cs.o. y p.s . _ in x l
' ennemmme j
O .---1 a -m- o . 1-Ne. 7 416
'l.?. l k-{ . .- , ..~...,..a.w. .
u.v. . . s.. ..-.h..dScdion
. & ,,. . .a .
/G 3/4 ~LIMITINGCONDITIONSFOROPERSTINANDSURVEIlldiERE0VIREMENTS () - 2/,,4,,j) APPLICABILITY 5 LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation and ACTION requirements shall be I' 6 applicable during the OPERATIONAL CONDITIONS or other states specified for
.Di,0.0 each specification.
3.0.2 Adherence to ths requirements of the Limiting Condition for Operat' ion and associated ACTIO4within the specified time interval shall constitute compliance with the specification. In the event the' Limiting Condition for Operation is restored prior to expiration of the specified time interval. completion of the ACTION statement is not required. 3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification, the unit shall be placed in at least HOT SHlfT00WN within 6 hours and in COLD SHUTOOWN within the following 30 hours unless corrective measures are completed that permit operation under the { permissible ACTION statements for the specified time interval as measured from initial discovery or until the reactor is placed in an OPERATIONAL CONDITION in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specifications. 3.0.4 When a Limiting Condition for Operation is not met. entry into an OPERATIONAL CONDITION or other specified applicability state shall not be made m / ) except when the associated ACTIONS to be entered permit continued operation in V the OPERATIONAL CONDITION or other specified applicability state for an
. unlimited period of time. This specification shall not prevent changes in OPERATIONAL CONDITIONS or other specified applicability states that are required to comply with ACTION requirements.
Exceptions to this specification are stated in the individual specifications. These exceptions allow entry into OPERATIC 1AL CONDITIONS or other specified applicability states when the associated actions to be entered allow unit operation in the OPERATIONAL CONDITIONS or other specified applicability states only for a limited period of time. L.2- h5 When a system. subsystem, train. component, or device is determined to) ' be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable. it may be considered pT[ AM OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or.. J B.'L,0 7, ) emergency power source is OPERABLE: and (2) all of its redundant system (s). . W D. subsystems (s). train (s), component (s) and device (s) are OPERABLE. or likewise) O M usatisfy the recuireinents of this specification /Unie Dotn onoit 3 i fand42) e sat)sfied the it shall ed in least OT S ! wthin hour . an at st COL N wit n the llowi 30 { ursjl Qis eci f'catio s no pplicab in onditi s 4 or .f 8 1 () . BRUNSWICK - UNIT 2 3/4 0-1 Amendment No. 8773816 1
ec.[&cg;}%. ], f. }
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~M.8ELECTRICALFOWERSYSTEM_S 3h 8.1 A.c. SOURCES -
hERATIN - (flMIUnie towD1TIDIL40R 0PCJlstflOU) h ll be D 3 8* Il dTU m misenrum]Me following
~
,4 A.C. electrical powerl sour Ol'ERABLE! between the offsite Two phy.s44*41, ..- J:p=be onsite Cisss 1E bcircuits w-c!* istributionfystemland a.
transmission network and the h ($ Four eepeenv.
. .,4 ..J =t diesel generators a minim o
#II'#'( .
separate engine-mounted g6o ]g
$ f,'{ . 8 1. - fuel tank containsng~
gallons of fu of 22,650 gall ii - 2. A separate day fuel tank containing a m n mum 8,v)la 3 of f __
.~1 :ctr$: f.y.(
- d k--S A separate fuel transf er pumpj llons of-A plant fuel storage tank containing a minimum of 74,000 ga c.
fuel. IIUU.T;D;M CGa W. m@l, 2, and 3.
- c D
AP PLIC ASILITY: ytg .(- et Mb g e AC%: erg ---*w With one of f site o f n;-1;! circuit - cf
^~~ reewtre -"in_ !! S: ' *8--
UMo= 6 ({ ace so weer-tret- cap.ui. A.C. i' ' ' '- offsite ichin source k Demonstrate the OPERABILITY of the remain ng R 33.1,1 b Q by performing k" --- "' 2 hours thereaf ters hours and at le'ast once per 1
- g'I e dies genera rs by TY of a.4 a e Requ' ements .8.1.1. ce p PERAB
- 2. mons ate th 2 urs perf ming rveill least n 24 h s and
.1.1. .a.! vi 4
t.ere to CPERABLEtstatus u nour withinh
63A [L 7 Restore Aer14a (y -- ,(and in cut.D SHUTDOWN within the follow ng feMacerM - of f site circuit 2 h i 24 hours.
~
g +dib3 a,(. , ,... .r MS baJb de ] one of the re Hal W 1_: !E nit 1 in jyl+HMI :- - u - d -_^'_='h. fa
~
1 offsste strcutc hA UnicIS'81* 1 of f site pwer circust A m,;r- j sther e anr at Wleast the inoperable h0T following SHUT h Unit to OPEMI status within 45 days fit 7 Tace unst h _
's. eda M )l wat an t e%:t 12 hours and an=culD SHUTDOWW within t er : .w-n oG 24h p2= r - -swm y j .
( wa 9 ...... 3/46-1 Amendment No. 1Yo b BRUNSWICK - UNIT _2, , f * ~ .. pye toa;-16 L . p L_ - _ _ _ _ _ _ _ _ _ _ _ _
SMc L L 3.s./ n v 3,) ELECTRICAL POWER SYSTEMS LIMITINC CONDITION FOR OPERATION (Continued) ACTION (Continued): IN- A . C . ;I 2 5 ' 8 "' 7 ~T b, With a diesel gengrator of d.. L .. . b bM8 **b w inoperable a O l l p.a o be ino from the of Ad el gene or shall b onsidere rea el11ance k ture un - it satisi s the req ements of~ 4.8.1. .a.4 and 4 .1.2.a.5. - Amendment No. 176l
- 1. [~ BRUNSWICK - UNIT 2 3/4 8-la
!(.. p7e // o+ M i L c :
see n s.a, i g ~ ( )
%/
ELECTRICAL POWER SYSTENS __ LIMITING CONDITION FOR OPERATION (Continued) Cec.l.h by n CTION (Continued) O Demonstrate the OPERABII.ITY 0.0.1.1.!;: of ithin_2 the hours A.C. of f site s ke,p. Me4 [p ly 4 12 f.J.f,
/ perf orming SurvetG...cc *:;;iremeniand oft M L at least once A pe lgenerator$ O Demonstrate the OPERABILITY of the c4ma4e+eg diese"-m"! --w&
M%% Pe g . k h (,.$,2"A by performing tu uillene: j g ,3,i A 4,8AA-rhe,4 within 24 hours.end : 10:n vac.,2 f342. . -CS 44dWAs 0c(d , thereafeet; h a L. w - + A n + w . % n, -..c u ,<d bstatus &*'8 (Restore the 4aeteseble diesel 24 hour generator to til g,3 b hM Sc following Ac h C.4 kn todoyC p .g g g s and in COLD SHUTDOWN within the l generator e+-n : tere nnuar 'cu e inoperables 1. 4 Nl4ta.o 4e3' m+
'i' "4, "
h ..A 4 :1:g te.1 (oMoe. f h(With one offsite circuit and one diese dPGthEs1L. Demonstrate the OPERABILITY of the (es.mn; A.C. source s by 1.be,+) Q G . a .1 fem C.1x performing Surveillance Requirements nee per 12 hours BID W3 C.L 2, ,and_4.8.c A. g.r. l. _ O uhi.". 5- within
, gg n MJDeit_bG,4 C hereafter;g t, perable sources to OPERABLE
() d kb g / g {,2 7 (Restore
~ ' - " ' -e ene's -
but SHUTDOWN within the) 24 g (status _within 12 hou p be in f Cleastin COLD l i SHUTDOWN within next 12 hours and byg hours'
- A
- ::ur** restored,
.eur-e= d' 2 'Y)8 h d b 5C.f C.3.g j With the inoperable offsitdemonstrate the atorsOPERABILITY to e L C.y o r ei 1
(OPERABLE status within 12 hours7 daysJf,xoar and in COLD tyw-o h east HOT suutuown within the next h*4 h SHUTDOWN within the following 24 hou g te the With the inoperable diesel generator restored, demonstra ired by
.g )4 t s_within OPERABILITY of the remaining As 6.lo4 72 hours rWr.af prrets LpevTr be in at12 hours and in COLDbSHU Least nut A.C. power s 63 HUT within the next M*" N the fo11oving 24 hours f 6:>r ~*<t inoperable:
# L.I
/
With two he:,a.c .; qui-ed of f site 4,6 circuits CR four diesel generators by 2 4 and D 1. Demonstrate the OPERABILITY ot 12 hours performing Surveillance Requirements 4.8.1.1. l
- reafter, unless the diesel generators are a rea s Amendment No. 134 3/4 8-2
]
BRUNSWICK - UNIT 2 E. / lob /b
. _ _ _ " - - - ' - - - - - - - ~ _ _ . _ _ _
.I hea%%,3.8.]
h, G . ELECTRICAL POWER SYSTEMS _ LIMITiNC CONDITION FOR OPERATION (Continued) ACTION (Continued) 4 Restore es-4a4*eEone of A in:p::251: offsite bs+= cees to ,, k,p,&w l). 2)e PERABLE status within 24 hourp or oc in ac--icant nut silVTrK)t!N A J witnin the next te g b ollowing 24nourshou and g in COLD SHUTDOWN within the keep,. Q SJ/ 6.37 With one offsite source restored, demonstrate the OPSRABILIn of the remaining A.C. power sources as required by ACTMN a; AJ k restore two offsite circuits to OPERABLE status within 72. hours A' '
' .g te in ac seast uvi 5iiLauvwN witnan ]
12 hours and in COLD SHUTDOWN within the following 24 j g 6 erators inoperable: C, deh hs With two -f a .Le.; .;;:i: Demonstrate the OPERABILITY of the A.C. power sources { .g (,* . lg f by performing Surveillance Requirements (& W g,g,gg M* C. 7.2- O - ----- = :: -- - Ju within 2 hours and at least once per 12 hours thereafter
@wg "I as WA'i4 b.y Aru ca; .c c,g d A Restore et '.;..;.;hreddiesu generatorK to OPERABLE status ggp,l M(Luithin 2 houpbe in ac icast avs inusuv7N within the next 2 O gg' d in COLD SHUTDOWN within the following 24 hours; b y/ ~
With one diesel generator restored, demonstrate the OPERABILITY l
%,Q gg,g)C.3.2. of the remaining A.C. power sources as requtred by ACTION b; j g*9 restore at least 4 diesel generators to OPERABLE status within 7 gy .;;;ytrf De in at teast nut anuiuvwn jcloa Gr sys .;; n . m w u i. s ,
)'
\ t in t e next 12 hours and in COLD SHUTDOWN within the '
- P*feA ktte%.following 24 hours. f SURVEILLANCE REQUIREMENTS
-4i4,4.4A- Each of .... ..~. required independent circuits between the of fsite
/:
, , , transmission network and the onsite Class 1E distribution system shall be: $
- a. (DeterminedOPERABLEatleastonceper7daysbyverifyingcorrect
~
$g.'3 8 1.t d breaker alignmentf and indicated power availability. and
- b. Demonstrated OPERABLE at least once per f p inc#sh9etoarQ by h b manually transferring unit power supply Erom tha noKne+ circuit to" '
+
# df 3'8 hD he alternate circuit.
I [MD . l au a
.. e,& sa. n .s.t.a I h re 3.tSF
$ E b
e.,t a htJ We 33
.fo IE 3.t.s.? d 'f 7[. -
b BRUNSWICK - UNIT 2 3/4 8-3 Arundment No.134 b1 P9e 13 o&/6 4 _m., _ _ . -
3.P.1 k.l hcMc.h l I ; ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 6etTg4/@ Each diesel generator shall be demonstrated OPERABLE:
- a. At least once per 31 days (QVa MAGC#QF04ST JdSi R 5Ai4 $. Verifying the fuel level in the engine-mounted fuel tank.
/\M ge, ,,, g ,g, g @ (erifyingthefuellevelinthedayfueltankg/jfM t .1 st 3,s.g.c $. Verifying the fuel transfer pump can be started and A qu 3 ,, z.f transfers fuel the day tank to the engine mounted tank. (_A.\
A4
#*k g 3 3,,,2, (3) ta.
Verifyino thp/I11 el starts anddiccalerates that 1886$ Slhh tiilek thar( nr poefal tn M secondSP j g ,,mp, M50V .l ! 4 t <l (F)' Verifying 4;ttf r is synchronized.bw ,,, g,deV */ 4eIoacea 8e to g sa. ',.t .i. 3 than or , and operates for greater than _ord U.* da gg, al o gg g t equal to minutes, and\QJeo k*l sa i,.s h r cqui *ssoowg 5 k nM Ntea at N n UN b j AtleastonceNk.r fuel storage t al cays oy verMying the fuel level in the pia j At least once per 92 days by verifying that a sample of diesel F5 ' c. fuel from the fuel storage tank, obtained in accordance with '$ E
/] f ( ASTH-0270-65, is within the acceptable limits specified in Table 1 nf ASTE D975-74 when checked fna vi tensit y water and sediment.
@ @ At least once per y:** I
$< bY?5'"Y *hY$'bf" Q sg 3.e Verifying (BfiIg ator ca
_ A core spray pump withoukabilitfng, tripp to reject a load t Gg p,q g y m u. hl w -a..o - 50tici (@ 10 seconds) from ambient conditions a least once p 184 days in these surveillance tests. All be C Thedieselkeneratorstar performed sa 3s.i.t /other engine starts for the purpose of this surveillance t_esting may . mi \ preceded by raJuanaally inipeteayngine prelube period anutor om mG ed.is acmin orocea _ ded ne: oc incaynnaina 7minig.fso tyn mecn3a+c'J g l cuen aisrwo t r=% A ** Surveillance Requirements 4.8.1.1.2.d.2. 4.8.1.1.2.d.3. GCM Wd4) i e nia and 4.8.1.1.2.d.7 shall not be performed for diesel generator 3 or 4- 6# i su r.i.i( with Unit 2 in OPERATIONAL CONDITION 1. 2. or 3.
"d ,, ,4 a,. 5 v,h 1315e v
..J & ? GLE 6, a d 3
k ,.h 1 6g an,, ovuut , S54AscoA-. *w'd # *e l: 1 Q.vso g3 t st t Ht **A i Uh () t / N BRUNSWICK - UNIT 2 3/4 8-4 Amendment No. l l T5c. 'm38 87 s ptt ,~.t l
'T H vf Ho 1
l . C C.M Cr Mo A '3 7. l [h.1 _ 3'^**^ b J $ $Me e g 379 Q j ) w.,oo v, ' v N. 44 &^ks g
*: Shady sk QY7 8'8 NF ELECTRICAL POWER SYSTEMS
'f SURVEILLANCE REQUIREMENTS (Continued) L.8 L.lb
- 3. g . b to, W-simulating a loss of offsite power in conjunction with an acd I
emergency core cooling system +eee- signal, and: or$WaM p C) 6.WNoD g gg 7 af. Verifying de-energitation ot cne emergency buses'and j oad shedding from the emer ency buses. SE 3.8.I. I'/ M
@c* R Verifying the diesjel starts f rom :-M -9conditionps on the O' auto-start signal *%nergizes, the emerzency buses with ermanently connected loads g' nergizes the auto-connteted 'd/0.r M O' oads through the load sequdE e relays and perates for greater than or equal to $ minutes while es generator is loaded with the emergency loads. 5. y Lg E
b'S w vere m Jq- % ( Verifying tha on the emergency core cooling system est signal, all diesel enerator trips except engine overspeed, generator fR J.3 1, jo ' differential, low lube oil pressure, reverse power, are loss of Ll1 field and phase overcurrent with voltage restraint, MB i automatically bypassed. h Verifying the diesel generator operates for greater than or h M*YE Z equal to 60 minutes while loaded to greater than or equal to ' 3500 kw ( 4 6 3fs0 R a pow bier 6 0 9
% m.,.f t E " E c a = r m 9 2 7 "">"" U MA trifying that the automatic load sequence relays are OPERABLE l
m.3 2.,.,,,2 withe-h g m ithin102of<ts;zej-a;cd aue,.
" @y Q
@ a.k&
p.m A i { r q t ) Amendment No. 134
\/- BRUNSWICK - UNIT 2 3/4 8-/.a l p e 1 7 06 Ko
. w ,
DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING ADMIN!STRATIVI A.1 In the conversion of the Brunswick Nuclear Plant (BNP) current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial l changes, 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 Note ** to CTS 3.8.1.1 Action a only applies to the opposite l unit's offsite circuits. This action allows the opposite unit's l offsite circuit to be taken out of service for maintenance for 45 days when the opposite unit is in Operational Conditions 4 and 5 (ITS MODES 4 and 5). This Action is retained in ITS 3.8.1 (Condition A). The CTS LC0 states "offsite circuits, per i unit ...". To facilitate. entry into ITS 3.8.1 Condition A correctly, the qualified offsite circuits are divided into Unit I and Unit 2 (LC0 3.8.1.a and LC0 3.8.1.c) offsite circuits in the LC0 Statement. Additionally, since ITS 3.8.1 Condition A reflects Note ** to CTS 3.8.1.1 Action a, ITS 3.8.1 Condition B b (CTS 3.8.1.1 Action a) states "One offsite circuit inoperable for reasons other than Condition A." Also, because of the division of [d\ offsite circuits, the result is a total of four offsite circuits. i Hence, ITS 3.8.1 Coadition D and Required Action D.2 refer to the offsite circuits as "two or more" and "all but one". These
/[\
changes clarify existing requirements and do not alter CTS requirements associated with CTS 3.8.1.1 Action a or associated Note **. Therefore, this change is administrative in nature. l A.3 The details in CTS 3.8.1.1.b.3 relating to a separate fuel transfer pump required for ecc.h DG is moved to ITS SR 3.8.1.6. SR 3.8.1.6 will verify OPERV t.ITY of each fuel oil transfer pump periodically to ensure DG * . ABILITY. A.4 Note
- to CTS 3.8.1.1 ? .n b is deleted from ITS because the intent of the Note is cucred by ITS SR 3.0.1. For a DG te be considered OPERABLE, it must meet all Surveillance requirements during performance and between performances of each Surveillance.
This includes ITS SRs 3.8.1.2 and 3.8.1.3 (CTS 4.8.1.1.2.a.4 and l 4.8.1.1.2.a.5). Since ITS SR 3.0.1 bounds the requirement of Note
- to CTS 3.8.1.1 Action b, the deletion of the note is considered administrative in nature.
O ! BNP UNITS 1 & 2 1 Revision 0
i DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-0PERATING ADMINISTRATIVE (continued) A.5 Note
- to Unit 1 CTS 3.8.1.1 Actions c.3 and e.3 is deleted from the ITS. The Note provides interim Actions for DGs 3 and 4 during
!b Brunswick Unit 2 Refueling Outage No. 9. Refueling Outage No. 9 was completed on 1/5/92. Therefore, the information provided in l
Note
- to Unit 1 CTS 3.8.1.1 Actions c.3 and e.3 is no longer applicable. The deletion of the Note is considered administrative g
in nature. A.6 The format of the ITS allows multiple Conditions to be l simultaneously entered. With one or more offsite circuits ; inoperable and two or more DGs inoperable OJ two or more offsite circuits and one DG inoperable, ACTIONS would be taken in i i accordance with ITS Specification 3.8.1, and ITS LC0 3.0.3 entry l conditions would not be met. However, CTS 3.8.1.1 does not l provide Actions for these conditions. Therefore, the plant would default to CTS 3.0.3. To preserve the existing intent for CTS 3.0.3 entry, Condition H is added to ITS Specification 3.8.1 to direct entry into ITS LCO 3.0.3. b A.7 Not used. k A.8 CTS 4.8.1.1.2.a.4 and Note *, 4.8.1.1.2.a.5, 4.8.1.1.2.d.2, 4.8.1.1.2.d.4, and 4.8.1.1.2.d.5 test the DGs and CTS 4.8.1.1.1.b tests the offsite circuits. The DGs and the offsite circuits are g O common to both units an therefore, a NOTE is added to the ITS SRs (SR 3.8.1.2, SR 3.8.1.3, SR 3.8.1.7, SR 3.8.1.8, SR 3.8.1.9, d SR 3.8.1.10, and SR 3.8.1.11) to cle6rly state current plant interpretation of Technical Specifications; i.e., a single test at the specified frequency will satisfy the Surveillance for both units. This is acceptable since the main purpose of the Surveillance can be met performing the test on either unit. If the DG fails one of these Surveillance (other than SR 3.8.1.8 which is not applicable to the DGs), the DG is considered b inoperable on both units, unless the cause of the failure can be directly related to only one unit. SR 3.8.1.8, the offsite circuit is considered inoperable on both If the offsite circuit fails A units. A.9 CTS 4.8.1.1.1.b, 4.8.1.1.2.d.2, 4.8.1.1.2.d.3, 4.8.1.1.2.d.6, and 4.8.1.1.2.d.7 contain MODE restrictions on the performance of ) applicable Surveillance. The ** Note to CTS 4.8.1.1.2.d /A\ clarifics that the 18 month DG Surveillance are performed on DG 1 and DG 2 when BNP Unit 1 is not in MODE 1, 2, or 3 and on DG 3 and DG 4 when BNP L' nit 2 is not in MODE 1, 2, or 3. CTS 4.8.1.1.1.b requires performance of the 18 month offsite circuit Surveillance ' during shutdown. Since each unit has two of the four offsite circuits, it is interpreted that each unit's Technical Specifications govern the performance of the 18 month offsite g , circuit Surveillance on that unit's offsite circuits. Therefore, l the 18 month offsite circuit Surveillance is performed on the I BNP UNITS 1 & 2 2 Revision 0
I i l l DISCUSSION OF CHANGES ITS: 1.8.1 - AC SOURCES-OPERATING ADMINISTRATIVE A.9 (cont'd) Unit 1 offsite circuits when BNP Unit 1 is shutdown and on the Unit 2 offsite circuits when BNP Unit 2 is shutdown. This g information is included separately in a Note to each applicable ITS SR (SR 3.8.1.8, SR 3.8.1.9, SR 3.8.1.13, and SR 3.8.1.14). Additionally, a statement is included to allow credit to be taken for unplanned events that satisfy the SR provided the appropriate data can be obtained. As such, the change is considered to be administrative in nature. A.10 AC sources are considered a support system to the AC Distribution System (ITS LCO 3.8.7). In the event one offsite circuit is inoperable and one DG is inoperable, the associated distribution ! subsystem may be inoperable, ITS LCO 3.0.6 allows taking only the AC Sources ACTIONS; taking exception to complying with the AC Distribution System ACTIONS. Since the current AC Sources Action
-(CTS 3.8.1.1 Action c.2) does not provide this exception, the AC Distribution System ACTIONS must be performed immediately.
Although ITS LCO 3.0.6 allows only performing AC Sources ACTIONS, specific direction to take appropriate ACTIONS for the AC A Distribution System is added (Note to ACTION E) in the event the QE distribution subsystem does become inoperable due to the loss of AC Soulses. This format and construction implements the existing treatment of this condition within the framework of the BNP Improved Technical Specification methods. A.ll The words " equal to" in CTS 4.8.1.1.2.d.2 (ITS SR 3.8.1.9) are replaced with " greater than or equal to." These words are referring to the largest post-accident load during the single load reject test on the DG. The load used in this test may be greater than a core spray pump to verify DG OPERABILITY without impacting the validity of the test. This change is considered to be administrative in nature. TECHNICAL CHANCES - MORE RESTRICTIVE M.1 ITS SR 3.8.1.5 is added to check for and remove any water accumulation in each DG fuel oil engine mounted tank. Removal of water from the engine mounted tanks once every 31 days eliminates the necessary environment for bacterial growth which may result in microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Although the plant currently checks for water in each DG engine mounted tank in accordance with UFSAR commitments, adding this re'quirement in ITS is an ade.ttonal restriction on plant operation. f% BNP. UNITS 1 &.2 3 Revision 0
i DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-OPERATING , I ( TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Notice 84-69, when a DG is operated connected to offsite sources (cont'd) and non-vital loads, disturbances in those areas can adversely affect DG reliability. Further, since the offsite AC sources have been degraded, a demand for DG start is more likely while connected to the grid and non-vital loads for this required surveillance. Therefore, DG availability is potentially lessened ' by a demonstration requiring starting and connecting the DGs to offsite sources when the offsite sources are abnormally degraded. As such, this Action is not required to be in the Technical Specifications to provide adequate protection of the public health and safety and is, therefore, deleted. ! L.2 ITS LC0 3.8.1, Conditions B, C, and D, include requirements to declare required feature (s) supported by the inoperable AC source b inoperable when the redundant required feature (s) are inoperable. This requirement is identical to the requirement imposed by CTS 3.0.5. CTS 3.0.5 provides similar requirements in that it allows required feature (s) supported by an inoperable AC source to be considered OPERABLE provided the redundant required feature (s) are OPERABLE. However, if these requirements are not satisfied, b CTS 3.0.5 requires the unit to be placed in Hot Shutdown within 6 hours and in Cold Shutdown within the following 30 hours whereas ITS 3.8.1 Condition B (one offsite circuit inoperable) allows 24 hours before declaring the equipment supported by the O inoperable AC source inoperable, Condition C (one DG inoperable) allows 4 hours before the affected supported equipment must be l declared inoperable, and Condition D (two or more offsite circuits inoperable) allows 12 hours before the affected supported equipment must be declared inoperable. By declaring the affected supported equipment inoperable, and as a result taking the Technical Specifications actions of the affected supported equipment, unit operation is maintained within the bounds of the Technical Specifications and approved ACTIONS. Since the AC sources support the OPERABILITY of the affected equipment, it is b appropriate that the proper action, in this condition, would be to declare that affected supported equipment inoperable. CTS 3.0.5 is overly restrictive, in that if the associated supported equipment were inoperable for other reasons and the redundant equipment was also inoperable, a restoration time is provided, in some cases, in the CTS system specifications. The 24 hour Completion Time when one offsite circuit is inoperable is acceptable because: the redundant counterpart to the inoperable required feature is still OPERABLE although single failure protection may have been lost; the capacity and capability of the remaining AC sources is still available; a reasonable time for repairs is provided for restoration before the unit is subjected ' to transients associated with shutdown; and, the low probability of a DBA occurring during this period. The 12 hour Completion Time when two or more offsite circuits are inoperable is ( acceptable because Regulatory Guide 1.93 allows a Completion Time ( of 24 hours for two required offsite circuits inoperable. When a concurrent redundant required function is inoperable, a shorter l BNP UNITS 1 & 2 10 Revision 0 l l
t DISCUSSION OF CHANGES ! ITS: 3.8.1 - AC SOURCES-OPERATING
/7 TECHNICAL CHANGES - LESS RESTRICTIVE LJ L.2 Completion Time of 12 hours is appropriate. The 4 hour Completion
- (cont'd) Time with one DG inoperable takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature and is considered to be less of a risk than subjecting the unit to transients associated with shutdown.
Additionally, the 4 hour Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period. l L.3 In the event of multiple concurrent AC Source inoperabilities (i.e., one DG and one offsite circuit), CTS 3.8.1.1 Actions c.3 and c.4 limit restoration time to 7 days and 72 hours, respectively, from the time of initial loss. When a second inoperability occurs just prior to restoration of the initial inoperability and close to the expiration of the initial loss, this limitation can provide little or no time to effect repair. The result would be a forced shutdown of the unit. While these simultaneous inoperabilities are expected to be rare, it is also expected that any AC source inoperability would be repaired in a reasonable time (s 72 hours for offsite circuits and s 7 days for the DGs). Given the minimal risk of an event during the repair of the subsequent inoperability, the likelihood of a satisfactory c return to OPERABLE status, and the risks involved with introducing plant transients associated with a forced shutdown, a separate V) time period is allowed for this subsequent repair. To avoid multiple overlapping inoperabilities, a maximum restoration time limit is imposed. The ITS format presents this as an additional Completion Time of "10 days from discovery of failure to meet LC0 3.8.1.a or b." This additional Completion Time is associated with ITS 3.8.1, Required Action B.3 and Required Action C.4. b In addition, in the event of multiple DG inoperabilities and multiple offsite circuit inoperabilities, the existing ACTIONS d limit restoration time to 7 days and 72 hours, respectively from the time of initial loss (CTS 3.8.1.1 Actions d.3 and e.3). The k consequences and occurrences of the multiple inoperabilities is similar to that described in the first paragraph. Therefore, a separate time period is allowed for the subsequent repair. This time period is described in ITS Section 1.3, " Completion Times," and essentially allows extension of the initial restoration time by 24 hours, not to exceed the actual time if the subsequent inoperability were tracked from its time of loss. ITS Section 1.3 limits the subsequent inoperability extension to one use, i.e., the second inoperability can be extended, but a third or subsequent inoperability cannot be extended. L.4 ITS 2.8.1 Required Actions C.3.1 and C.3.2 provide an allowance to avoid unnecessary testing of the OPERABLE DGs when a DG is d declared inoperable. This change is consistent with tha approved O) (" on the River Bend Station docket (Amendment No. 64, dated 9/29/92) and Generic Letter 93-05. The intant of the Required Actions is BNP UNITS 1 & 2 11 Revision 0
l DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-0PERATING TECHNICAL' CHANGES - LESS RESTRICTIVE L.4 to confirm no common mode failure has rendered more than one DG (cont'd) inoperable. This assurance can be ascertained in many cases by means other than the existing requirement for starting the DGs g (CTS 3.8.1.1 Action b.2). If an assessment can determine no common mode failure exists on the remaining OPERABLE DGs, ITS 3.8.1 allows for not requiring unnecessary DG starts for the remaining OPERABLE DGs. Minimizing DG starts is recommended to g avoid unnecessary diesel wear, thereby enhancing overall DG reliability. Additionally, requiring CTS 4.8.1.1.2.a.5 (DG Icad l test) to be performed on the remaining GPERABLE DG(s) is deleted. The reason for the deletion of this requirement is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network during the period when limited AC sources L are available. A single event could compromise both the offsite l circuit and the remaining DGs. If common mode failure cannot be l ruled out, the requirement to start the DGs remains. The 24 hour l l Completion Time is identified in GL 84-15 as a reasonable time to l confirm that the OPERABLE DG(s) are not affected by the same problem as the inoperable DG. The Completion Time to perform the DG starts is changed from once within 24 hours and every 72 hours thereafter to only once within 24 hours. This Completion Time is h consistent with GL 84-15 and is adequate to verify DG OPERABILITY while minimizing DG starts. At BNP, there are four DGs required by ITS 3.8.1. Therefore, when one DG is ingerable and it can be confirmed that no common mode failure exists, this change will allow avoiding unnecessary starting of the three remaining OPERABLE DGs between one and three times each, depending on when restoration of the inoperable DG occurs. In addition, starting each of the three remaining DGs within 24 hours and once per 72 hours thereafter requires the operators' and plant staff's attention to be focused on ensuring these tests are performed within the required time periods while at the same time ensuring that the testing is scheduled such that d no more than one DG is paralleled to the offsite network during the testing (including the required testing to declare the inoperable DG OPERABLE after it has been repaired). This change also allows operator and plant staff attention to be focused on minimizing the impact of the inoperable DG and performing the actions necessary for restoring the inoperable DG within the required time period. L.5 ITS LCO 3.8.1, Condition F, two or more DGs inoperable, allows 2 hours to " Restore all but one DG" before entry into ITS LCO 3.8.1, b Condition G'(Mode.3 within 12 hours and Mode 4 within 36 hours) is required. CTS 3.8.1.1 Action e addresses two inoperable DGs but h g does not address three or more DGs inoperable, therefore, the plant would default to CTS 3.0.3 (Hot Shutdown within 6 hours and Cold Shutdowr. within 36 hours) whenever three or more DGs are O inoperable. With two or more DGs inoperable, insufficient standby AC sources are available to power the minimum required ESF functions. .Since the offsite Electrical . Power System is the only.
.BNP UNITS 1 & 2 12 Revision 0 l
^
DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-0PERATING TECHNICAL CHANGES - LESS RESTRICTIYi (continued) L.13- ITS LC0 3.8.1, Condition D, two or more offsite circuits inoperable, allows 24 hours to " Restore all but one offsite circuit" before entry into ITS LCO'3.8.1, Condition G (Mode 3 b lg within 12 hours and Mode 4 within 36 hours) is required. CTS 3.8.1.1 Action d addresses two inoperable offsite circuits but does not address three or more offsite circuits inoperable, therefore, the plant would default to CTS 3.0.3 (Hot shutdown within 6 hours and Cold Shutdown within 36 hours) whenever three or more offsite circuits are inoperable. With two or more offsite circuits inoperable, insufficient offsite AC sources are available to effect a safe shutdown and to mitigate the consequences of an accident. However, the onsite AC sources (DGs) have not been degraded in this condition and are available to maintain the units in a safe shutdown condition in the event of a Design Basis Accident (DBA) or transient on one of the units. In fact, a l simultaneous loss of offsite AC sources, a LOCA, and a worst case < single failure are postulated as part of the design basis in the safety analysis. In addition, the configuration of the onsite AC sources (DGs) is such that they are not susceptible to a single i failure which can cause more than one DG to become inoperable. (At BNP only three of the four DGs are required to mitigate the consequences of a DBA or transient and maintain the units in safe shutdown.) Therefore, the 24 hour time period for this condition is considered acceptable since the capability still exists to O mitigate-the consequences of a DBA and maintain the units in safe shutdown. The intent here is to avoid the risk associated with an immediate controlled shutdown (required by CTS 3.0.3) while minimizing the risk associated with this level of degradation. This change is consistent with Regulatory Guide 1.93, Availability of Electrical Power Sources. b L.14 CTS 4.8.1.1.2.a.4 requires verifying, once per 31 days, the each DG starts in f 10 seconds. CTS 4.8.1.1.2.a.4 is modified by an
"*" footnote that states," The diesel generator starts (10 seconds) from ambient conditions shall be performed at least once per 184 days in these surveillance tests. All other engine starts for the purpose of this surveillance testing may be preceded by a manually initiated engine prelube period and/or other warmup procedures recommended by the manufacturer so that mechanical stress and wear in the diesel engine is minimized."
ITS SR 3.8.1.2 requires verifying that the DG will start once per 31 days but-does not include the 10 second start time acceptance criteria. ITS SR 3.8.1.7 requires verifying that the DG will start in 510 seconds once per 184 days. The elimination of the requirement to perform fast starting, once per 31 days, helps reduce stress and wear on the engine and is consistent with the Generic Letter 84-15 recommendations. The intent is to use a modified start in which the starting speed is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated
/~T to~ synchronous speed prior to loading, as reflected in Note 2 to D ITS SR 3.8.1.2. When this modified start is not used, Note 2 to ITS.SR 3.8.1.2 also requires that the 10 second starting time BNP UNITS 1 & 2 15- Revision 0
DISCUSSION OF CHANGES ITS: 3.8.1 - AC SOURCES-0PERATING TECHNICAL CHANGES - LESS' RESTRICTIVE L.14 requirement of ITS SR 3.8.1.7 must met. In addition, other (cont'd) Technical Specification DG starting requirements are adequate to ensure that the DGs are capable of starting within the required time period. As a result, adequate assurance of DG OPERABILITY g will continue to provided by the Technical Specifications, while degradation resulting from fast start testing will be minimized.
-L.15 Not used. A L.16 CTS 4.8.1.1.1.b requires the offsite circuits be demonstrated OPERABLE, at least once per 18 months during shutdown, by manually transferring the unit power supply from the normal circuit to the alternate circuit. ITS SR 3.8.1.8.b will not contain the restriction to perform the Surveillance "during shutdown."
Currently,. this tett is performed by momentarily paralleling the 230 kV offsite AC power sources. Paralleling offsite AC power sources is a controlled evolution and the increased risk associated with the performance of this test while the unit is at power is not significant for the following reasons: 1) the frequency and voltages are verified to be within the required range prior to paralleling the two offsite AC power sources 2) breaker interlocks ensure that the alternate circuit is connected to the load prior to opening the preferred circuit; 3) the test does not result in de-energization of any 4.16 kV emergency bus 6 O and the potential for electrical perturbations on the grid system is the same whether performing the transfer while the unit is at power or while shutdown; and 4) operating history indicates that transferring offsite AC power sources while the units were in MODE 1 or 2 has been performed satisfactorily without electrical distribution system perturbations. In addition, Generic Letter 91-04 states that licensees may omit the Technical Specification qualification _that a refueling interval surveillance is to be performed "during shutdown." Therefore, consistent with the guidance provided in Generic letter 91-04, the requirement to perform this Surveillance "during shutdown" is deleted from CTS 4.8.1.1.1.b and is not included in ITS SR 3.8.1.8.b. RELOCATED SPECIFICATIONS None O BNP UNITS 1 & 2 16 Revision 0
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A'\ ... . 6f ec % L 3.8.7 "J,g ELECTRICAL POWER SYSTEMS H 3.N.7 -N' ^.i err:r erre DISTRIBtTTION SYSTEMS - Op g 6.0. Lisamtsta turs - Urr.antise ei 0::" 0: !^'""'*" (f W errue c<'ur: : = 7;; e;;: = D NwlsMb4e^- fulo sysW-5)
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ffo 2,g.~/ 0.e fpMM A.C. electricalM shall be OPERABLPM :n - %
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- b. 41 volt Emergency Busf El and E3
{,,,,4 'I 4160 volt ergency Bus i E2 a .. 480 volt Emergen y Bus and E7 . 480 volt Emerge Bos E6 and E8 . 120 volt,A.C. Vital Bus # IE. ad 2E7 _ Vital Bus # IE6 and E8 s ig
~~
APPLICABILITY: 40tHWPieNt 1, 2, and 3. __ ACT10h [** MIb h 941 4 i [c% h\ %rb \ Act1oa f'(jWith less than theto' above complement OPERABLE of withJn,J status A.C. buses OPERABLE, hours r be in at leastrestore HOT the
' Linoperable g
~
jg y SHtTTDOWN hours. within the next T2 hns and in COLD SHUIDOWN within the following 24
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SURVEILLANCE REQUIREMENTS h C. M eleckrical Po*< r Oh % b b .sshay W } , f(( 3.g ,"f, / 4,4 ,3rt Yhe @ ci:1 J A.u. -puerAshall be determined OPERABLE at least once per 7 days by verifying correct breaker alignment and indicated power " availability. BRIDISWICK - IJNIT 1 3/4 8-6 (d PITYPED TECH. SPECS. Updated Thru. Amend. 53
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f,7'ELECTRICALPOWERSYSTEMS ,Q j,,J,'7 ove, DISTRIBUTION - OPERATINC
-:.::::;;,. m:;;e in :r-,Aetew D I*I*7 .. 4.5-As a minimum, the following D.C. divls! . sb.11 bt __opraant.rme ti ,
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a DI-tatan r. 6nsisting ott / g,( M.~ i'--9 55 ---%
- 2. Two 125 volt D.U. batteries, la-1 and 1A-2, each with a full capacity charger. ,
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b.. Dp88^a TT- M sisting oft I* I* {g,(. : - Hv/i-- ;: ' * '3 Two 125 volt D.C. batteries,18-1 ar.d 18-2, each with a full 2. capacity charger. APPLICABILITY: ^7; M i- N ^^" b 1, 2, and 3. ACTIONS
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WitbL- or =nem hartaries and/or its associated chartec inoperable. hN y. 6st he aivazionr, restore the division to OPERABLE status within I8Y 7 dayq/pr ne in at least ava snusuvifN within the_next AZ nours andy e O [ACT1oo 0-- r tenr_n suUTDovu ees within the foltowing 24 hours.j --_f gg .
.. '-.... .. .naInc 1e. ...ne19ted charal/ inoperable. TWWI I v l = I a= ^ %e/in at least ava 5HusuvWu within the nexc / GM
,b2hoursandinCOLDSHUTDOWNwithinthefollowing24 hours. g g ,
w e.w na C SURVEILLANCE REQUIREMENTS Aco w,gaE.cT7, e. ' g 3;p,LJ f t." ^.5.^1Each of 'the above required D.C. divisIAns shall be determined' 4,0PERA5 lei-i;; ;u . 2-_.; ;;3st least once per 7 days by verifying s
- a. Correct breaker alignment and indicated power ava11 ability,-ea4-J,$.l .. - ,
b ., Thaii'nb combination of more than two power. conversion modules, g *g , consisting of either two lighting inverties or one lighting inverter g
' -,~and one plant UPS unit, are aligned to division II bus 8.
k BRUNSWICK - UNIT'1 - 3/4 8-8 Amendment No. 109 e n
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~J.yELECTRICAI. POWER SYSTEMS $3w 9 4 h.p.*)@ DISTRIBUTION - OPERATI4hr O!. ' 0; :;;7;; :;;c 4?M!?Iuc r=I?inu rna oprnmnu l -
3.8.2.4 1 The 125 C control pove circuits shal be OPERABI.E from heir norma source for he following e tpment:
- a. Diesel Cen stor #1, 4160 emergency bu El, and 480 V eme ency bus E .
nerator #2, 4 0 V emergency us E2, and 480 V mergency b E6.
. Diesel Cenerator # , 4160 V emerge cy bus E3, and 4 V emergen bus E7.
- c. Dies
- d. D esel Generato f4, 4160 V em gency bus E4, an 480 V emer ency bus af
- e. ESS panel H *
. ESS pane if59*
- g. ESS p .el H60*
- h. Es panel H61*
Mo0E.5 APPLICABILITY: OPERAH e"f.L C0"DITIO"! 1, 2, and 3. g[t.)
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ACTION: .DC ele.e.4cien) p#tr- 3i5db M5ySh bordI b ' D K Wit 25 V control pouer cuit fprthe diesel generd 41603
,nerre bus. or 480 V errency bus /not OPERABLE from its normal source,
;=;..M. Ai60,pemergency busp450 g
f94 4 h d m S il: ( eclare (memeyy the afnoperable fected Masei a;J ci:hcr:- A3, EP'&@ A:.lel ti,.hi, ,rtinu er r,.,nr rne the inanershi, ,ma m ,ne. g
. Q. 1,u g,, ;g J y b Y' 2. ieclare the affected_pquipmen r. o 5,k M 19 trans ferrGift, the'
'I'D N 125 VDC control power circuit for the affectef A ,<e M enerator' t
,n d ale JV dergency buy,- or *ou v emsegency buy to the OPERABLE M*
iedak. % see. alte e so u.* d ,%fgo,s.rbin M , k sebht W W f(byg g b. With the 9 w enarrot oower etrortt tor t.ss panels Af58 fr9m its normal source, either H39. %
' f g g3 dia %__ bihk N not +=
me+b OPERABI.E h$+*' ) y 1. Vee 44y'the61 ternate source feflM(and th(power avalJdti1M
- 6. '2. P" ' N "
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).\
- The ESS pa automatically tra ers to its alt source s the normal urce de-energia:e. er to ACTION b.
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4 BRUNS'.;*;X - t' NIT 1 3/4 5.g: j g y e 5 a'r 8 9
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/ g ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATIs.
ACTION: (Continued) A' R. p.ce &. . When the alternate source is' inoperable, feclaretheaffected M g,f-
- - equipment inoperable @ :: : : 2 ::: r '- " '- - -- :: :;- it
&&h f ik Nu
, g ..f. 8 3 n.Ns y the 125'VDC control power circuit for the affected ESS panel
'..: : r_----e t ::il, ;... ;f::::e to it s OPERABLE alternate source
'ca (IIat pdwer avpflability is indicaydg LA,1 g g c.(Restoret ffect e 25 vnc r w rol nnuar mYcuiD to OPERABLE status i
b D,'9 (.within 7 _daysAr be in at least HOT SHUTDOWN within the next 12 hours an OLD SHUTDOWN within the following 24 hours. i gj gasa SURVEILLANCE REQUIREMENTS
. Celeg4csent we- dhH b.4 dom Obw+<~ _.
-. ...-.... The above specified'/normat 14>101, n_e_ ennef61 oower cincit I
R 33.7. /
- shall de determined OPERisLE at least once per 7 days by verifying correct '
breaker alignment and indicated power availability.
- 4. g8 . .2 Th atterie ad charg associa' with t above no .a t M5 t D.C control er circu' shall ' determij OPERASL8' n er
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{ veilla e Requir ent t. 8.2 , i h6 gu
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. m A;nendment No. 92 ERUNS'4TCK - UNIT 1 3/4 8-13 (v) b O
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ba 3.8 ELECTRICAL POWER SYSTEMS J,f,7 ii. 6.2 vNnt ~~" DISmmION SYS EMS - Qh _
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^a** m rw i I'""'
hvisfe 3' a.J Divisloe h ged5kyh GbA,3% lihail T>e OPERABLE Ch'
/_c0 7.3") $ ".:. = 1:11; d;;"o c. electrical . . ; o..J . ,.57 y 3::: _ , . i; L..
l.A. I M.I
-volt Ese ncy Bus i El and E3 g ,
4160-vo mergency Bus # E2 E4 I 480-volt Emerge Bus 5 and E7 480-volt Emergene us and E8 d 2E7 120-volt A . Vital Bus # 1E5 /. I 8 Q_ t A.C. Vital Bus 8 IE6 and APPLICABILITY _: GeHD 1, 2, and 3. g y Q ,A h %
# IC * %
ACTIO Al gg, han the above complement of A.C. buses PERABLE, restore the g g With nope rable less to OPERABLE status within 8 hours r be in at least HOT 12 hours and in COLD SHUTDOWN within the following 24 SHUTDOWN within the next 8 M N h hours. p 000 knoa E M.2. - SURVEII. LANCE BEOUIREMENTS
/.A . [Ac.4 OC. eJteMad he d4MkNo
.,..;.p sha11 be determined OPERABLE at 1d17s463.-
least once 4 " _ - The Capeeh .w ---. 3S 3 81l per 7 days by verif ying correct breaker alignment and indicated power availability. a l . SRUNSWICK - UNIT 2 3/4 8-6 [ RETYPED TECH. SPECS. \..) Updated Thru. Amend. 78
- 6. 5"o $ 8
,,..~ -
A 'i bfeclGcJ;on x8.7 (. g g FLECT.cCAL PouER SYSTEMS [95 b5 7,7,7 e DISTRIBUTION - OPERATINC
-E!"?!;-w wnui a ivi, m OPC"J.T:0:'
4Co 5.8.7 _h As a minimig. the following D.C. divisions shall be OPEw.T.Efith ti;3 m .... a oc u.. .. a -La= an==: f
</
- a. Division I,AI'o~nsisting of:
^--
25^/M5rh 9 [A,) 2. Two 125 volt D.C. batteries, 2A-1 and 2A-2, each with a full capacity charger. . /$ee, ms.'
- b. Division II,jtonststang ots pg f mf m onie 9
[2. Two 125 volt D.C. batteries, 2B-1 and 28-2, each with a fc1 L capacity charger. A ar$ APPLICABILITY: OPERAHONeb-60NGIT4GNS 1, 2, and 3. ACTION: yg .7-(~ gg% With/M'F-re batteries and/or its associated chargeBinoperable g fk isC(oEe-aivisiodh restore the division to OPERABLE status within 7 . g -$ da's In at least nul 5HUauGWN within the next 12 hours and i y'q i Acrloes p OLD SHUTDOWN within the following 24 hours. (" " JcU $*V'& b. A one_er more batteries and/or its associated chargerlinoperabic ~ ' g 'I be in at least HOT SHUTDOWN within the next lc tioi3 g - ('th divis SHUTDOWN within the following 24 hours. hours and in~ fg ehr SURVEILLANCE REQUIREMENTS Each of the above required D.C. divisions shall be determined M gg, y,g ,g, )0PERABLE {[-4.T,.2.3.L C ;. si. m..;;n q:D at least once per 7 days by verifying:
- a. Correct breaker alignment and indicated power availability, .e+4
- b. That no combination of more than two power conversion modules, SR n7.1 [? e asisting of either two lighting inverters or one lighting inverter and one plant UPS unit, are aligned to divtsion II bus B.
6 n-I (,e) BRUNSWICK - UNIT 2 3/4 8-8 Amendment No. 136 o} & G QS S
/
$f e< % % 3.8 7 p
h , J,3 ELECTRICAL POWER SYSTEMS J.J,~l M . DISTRIBUTION OPERATI$ " $6 Ga 00T' ""!TS-3.IMITIMc enunt m u eno norn_irrog 8.2.4.1 125 VDC e trol power ci uits shall e OPERABLE fr the$r-normal sour e for the 11owing equip tt
- a. Dies Generato #1, 4160 V eme gency bus , and 480 V ergency bu E5.
- b. rgency s E2, and 48 V emergenc us E6.
peselCener*.or#2,416CV c Dieset C erator #3, 4160 emergen bus E3, and 80 V emer ey bus .
- d. Diese Generator #4, 4 0 V emer ency bus E4, nd 480 V e rgency s E8.
- c. ESS panel H58* _
- f. SS panet H59*
g ESS panel H
- e I
( ESS pane H61* M l APPLICABILITY C?El'.T:0 MAL COMD! ut 1, 2, and 3. ! g-I /J,1 V ACTION: p (Qy ggj ;g,,p,y y,pg MA8 % with 25 coner over ci f e diese m nerator m me bus, 20 V em b ot OPERABLE from its normal source, I k hird kh- 8 3 declare the af f ectedfE-i _ g..n.se , u= . =: ;;:::;- t_:. e r "$v
,(1 7:r;:::; La erable ::: :: :- ;.- .
M.Aly [ Take the app sea e ACTIOR statement fortheinoperableequipmenthog
% .$ Aek.a ... S '& ** W
. ,gufg3 2g Declare the af fected equipment OPERABl.f4b)( : i'lf transf ers4ag- the i
^
125 VDC control power circuit for the affectedidi:::1 :::::::: h _ I' "r-- -27a 'd^ " : :r;:::, &_ f o the OPERABLE g ele.Matp.x,-8sb b h son.sys Q g Co 84ie,' With the 25 *.'00 ::n:::1 -m o.m.i f . C Z y.. J . .. ! , ';M , :.i,0 C,3 not OPERABLE from its normal source, either L%441y - [the alternate source khPERABLE):nd th ;
;u : :::!!:M ' !T 4 wkoh te .,
w61 '
- The ESS g el automatical transfers to its ternate source,sh1o'uld tg nor 7 source de-ener Refer to ACTI b.
Q.I f% i)v BRUNS'.'ICK - UNIT 2 3/6 8-12 Amendment No. 117 p)e 7 e4i
C 4bc e ' J,g, h* n v ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION g ACTIOWt (Continued)
- h. f When the alternate source -e,.. a c is
. . ... inoperable,4.eclare
. . .. :: n---- f r- - b-the a h(p".y A.4A l.e4ui eentP 8 ;l'
. 5 :r- ---
. e P fc .QC a j'y w,Tw4 A #h.s r the affected ESS panel w.d K,
c!r I vuc con 6rn yv <n her- cur aciccity tr:--!- r:F to its OPLA /2, u.c a. BLE alternate, source )O. Qf d g3 4 ,3 kit /bowe r Availmhili rv is uGlica(e Y' QC.t.%.hrutPoee desk W s.,h PPRARLF ststus b a+f RestJtT theLattectph-125 VDc rp acrot k w esecutO to 8mjde 4 bs . b l,within 7SHUTCOWN p or be in at least WOT SHUTDOWN within the next 12 hours an within the following 24 hours. g SURVEILLANCE REQUIREMENTS Lele4t vical Pewn_c_ d.W~bA rnet--t fa.bsreed ;e--- 44;;;;:N i . S . 2 *rtit- The above specifiedC.:T=1 125 r!r IE- 3 8 l,I -- "> 'shall be determined OPERABLE at least once per 7 days by verif ying correct breaker alignment and indicated power availability. ~ LAl. ; above n mal h.2.4g. The batt itfi and chargers socist with t OPERAB per power circui shall be etermin
, 125 v rt D.C. cont .2.
eiliance Re trement 4.8. Q hI g.i *~ 8fM4 Qd secaApWAhek g l l (D 3/4 3-1) M endr-ar.t N:...'? N- SP.35,'!CK - UNIT 2 DtES8
DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING A34INISTRATTVE A.1 In the conversion of the Brunswick Nuclear Plant (BNP) current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted which do not result in technical changes (either actual nr interpretational). Editorial changes, 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 ITS 3.8.7 includes requirements of CTS 3.8.2.4.1. CTS 3.8.2.4.1 requires the opposite unit's DC electrical power distribution subsystems to be OPERABLE to support control power to equipment required by the subject unit (i.e., DGs and emergency buses). Since CTS 3.8.2.3 and 3.8.2.4.1 are combined in one Specification, ITS 3.8.7 Conditions C and E include "or more" to correctly address conditions where more than one subsystem may be inoperable b without a loss of a safety function. This change preserves the intent of CTS 3.8.2.3 and 3.8.2.4.1 ACTIONS. A.3 The details in CTS 3.8.2.4.1 Action a.1 that require applicable actions to be taken for equipment declared inoperable is not necessary since ITS LCO 3.0.6 requires applicable Conditions entered and Required Actions performed on equipment declared inoperable in a support system Specification. This is a ! presentation preference in ITS Specification 3.8.7 ACTIONS and l maintains current requirements. No technical changes are made; therefore, this change is considered administrative in nature. A.4 To preserve the existing intent of CTS 3.8.2.4.1 ACTIONS, the word l
"immediately" is added to ITS 3.8.7 Required Action B.I. No technical changes are made; therefore, this change is considered h
administrative in nature. l A.5 CTS 4.8.2.4.1.2 is being deleted since its provisions only reference requirements in CTS 4.8.2.3.2. ITS LC0 3.8.4, "DC Sources-0perating," and ITS LCO 3.8.6, Battery Cell Parameters," contain these current provisions of CTS 4.8.2.3.2 and thus no reference is necessary. A.6 CTS 3.8.2.3 Action b describes a shutdown required due to loss of DC Division I and DC Division II for the subject unit. combination of inoperabilities results in a loss of function This h (e.g., the HPCI System, the RCIC System, and both ADS Trip Systems would be inoperable which constitutes a loss of function). g ITS 3.8.7 Required Action E.1 requires immediate entry into LC0 3.0.3 for this condition. This preserves the intent for ITS g LC0 3.0.3 entry. CTS 3.0.3 shutdown Completion Times are the same as CTS 3.8.2.3 Action b shutdown Completion Times. Therefore, this change is considered administrative in nature. ITS LCO 3.0.3 O extends the Completion Times for shutdown by 1 hour. extension is justified in Discussion of Change L.1 in ITS Section 3.0. This BNP UNITS 1 & 2 1 Revision 0
DISCUSSION OF CHANGES ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING ADMINISTRATIVE (continued) A.7' CTS 3.8.2.3_ requires two DC electrical power distribution divisions (subsystems) associated with one unit to be OPERABLE. In the event one of these divisions is inoperable, CTS 3.8.2.3 ACTION a requires restoration of the division within 7 days. In the event two of these divisions are inoperable, CTS 3.8.2.3 ACTION b requires the plant to be shutdown. ITS 3.8.7 requires the DC electrical power distribution divisions (subsystems) associated with both units to be OPERABLE (as addressed in comment - A.2). Therefore, ITS 3.8.7 Condition C addresses one-or more DC dc electrical power distribution subsystems inoperable and associated i
/_L\
Required Action C.1 allows 7 days to restore the inoperable A distribution subsystems. ITS 3.8.7 Condition E addresses two or LO more electrical power distribution subsystems inoperable that i result in a loss of function and associated Required Action E.1 l requires immediate entry into LCO 3.0.3 (see comment A.6). In the event two DC electrical power distribution divisions associated l with one unit are inoperable, entry into ITS 3.8.7 Condition C l would be required and since a loss of function will have occurred l (as stated in comment A.6) entry into ITS 3.8.7 Condition E and l subsequent entry into LCO 3.0.3 (and subsequent shutdown) would be i required per Required Action E.1. Since the CTS 3.8.2.3 ACTIONS are equivalent to the applicable ACTIONS of ITS 3.8.7, the change is considered to be an administrative presentation preference. & TECHNICAL CHANGES - MORE RESTRICTIVE M.1 The Completion Times of ITS 3.8.7 ACTIONS have a limitation in addition to the 8 hour or 7 day limit. This additional limit establishes a maximum time allowed for any combination of distribution subsystems listed in ITS 3.8.7 to be inoperable J l during any single contiguous occurrence of failing to meet the l LCO. If a Division I AC distribution subsystem becomes inoperable l while, for instance, a Division II 125 V DC bus is inoperable and ) subsequently returned OPERABLE, the LCO may already have been not l met for up to 7 days. This situation could lead to a total duration of 176 hours since initial failure of the LC0 to restore the Division II 125 V DC distribution system. Then, a Division I AC subsystem could again become inoperable, and the DC distribution restored OPERABLE. This could continue indefinitely. Therefore, to preclude this situation and place an appropriate restriction on any such unusual situation, the additional Completion Time of "176 hours from discovery of failure to meet LC0" is added. M.2 CTS 3.8.2.1 ACTION allows 8 hours to restore any AC bus regardless of how many buses are concurrently inoperable. Certain combinations of inoperable AC buses will result in a loss of safety function. ITS.3.8.7 adds Condition E which requires entry b O BNP UNITS 1 & 2 2 Revision 0
DISCUSSION OF CHANGES ITSi 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TECHNICAL CHANGES - MORE' RESTRICTIVE M.2~ ' into ITS LCO 3.0.3 if the loss of two or more electrical- power (cont'd) distribution subsystems (emergency buses) results in a loss of a safety function. ITS 3.8.7 Required Action E.1 preserves the intent of ITS LC0 3.0.3 and reflects an additional restriction on h plant operation. M.3 If a loss of normal control power to equipment occurs, CTS Actions (CTS 3.8.2.4.1 Actions a and b) require affected equipment to be a declared inoperable and appropriate supported equipment actions a taken until power from the alternate power source is provided. These actions are revised in the ITS. ITS 3.8.7 provides a Required Action (ITS LCO 3.8.7, Required Action B.2) to immediately commence and continue attempts to transfer the g, affected DC electrical power distribution subsystem to its , alternate source. This change ensures that actions are taken to restore the DC control power to the affected equipment in a timely manner. The change ensures actions are immediately initiated to restore power to the equipment from its alternate source rather than allowing the equipment to remain de-energized for the length of the associated Completion Time in the supported equipment's d Specification. Therefore, the change is considered an. additional restriction on plant operation necessary to help ensure the time control power is unavailable to the affected equipment is minimized. TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic" LA.1 CTS 3.8.2.1 ar.d 4.8.2.1 specify the 4160 V buses, 480 V buses, and 120 V AC vital buses that constitute the AC electrical power distribution subsystems. CTS 3.8.2.1 and 4.8.2.1 also specify requirements for the tie breakers to be open between redundant buses. CTS 3.8.2.3, 3.8.2.4.1, and 4.8.2.4.1.1 specify the 250/125-V.DC buses and 125 V DC control power circuits to the DGs and Engineered Safeguard System panels that constitute the DC electrical power distribution subsystems. CTS 3.8.2.3 and 4.8.2.3.1 also specify requirements for tie breakers tt, be open g
between divisions. These requirements are details of system. design and OPERABILITY and are to be relocated to the ITS Bases. ITS 3.8.7,:" Distribution Systems-Operating," requires that the Division I and II of the AC and DC electrical power distribution subsystems be OPERABLE. O
'BNP UNITS 11 2- 3- Revision 0
DISCUSSION OF CHANGES
- ITS: 3.8.7 - DISTRIBUTION SYSTEMS-OPERATING TECHNICAL CHANGES - LESS RESTRICTIVE LA.2' C.3 only allows this required equipment to be declared OPERABLE (cont'd). upon completion of transfer of the required equipment's DC electrical power distribution subsystem to its OPERABLE alternate DC source. . For the DC electrical power distribution subsystem to be considered OPERABLE, it must be. energized (i.e., power r available). - Therefore, to ensure compliance with the requirements of ITS 3.8.7 Required Action C.3 prior to declaring the affected required equipment OPERABLE, it will be necessary to ensure that the transfer has occurred to the OPERABLE alternate source by verifying the affected DC electrical power distribution subsystem is energized (i.e., power available) from the alternate source.
8 Therefore, the requirements of ITS 3.8.7 and the definition of OPERABLE-0PERABILITY are adequate to ensure that power is available to the affected supported equipment's DC electrical power distribution subsystem from its alternate source. As a result, the details of the method of performing actions (i.e., verification of power availability) are not necessary to be included in the Technical Specifications to provide adequate protection. of the public health and safety. Changes to the Bases will be controlled by the provisions of the ITS Bases Control Program described in Chapter 5 of the ITS.
" Specific" L.I Not used.
L.2 Not used. g RELOCATED SPECIFICATIONS None l [ BNP UNITS I & 2 5 Revision 0
.i, . . \ . /~
AC Sources-Operating 3.8.1
- CTS /Decs 3.8 ELECTRICAL POWER SYSTEMS 4
,. 3.8.1 AC Sources-Operating [l*N2- 6 M 1-M I#! LC0 3.8.1 The 11 i electrical power sources shall be OPERABLE:
g,. vs s A.2, t.A.'l 4 s.+ 1 - a, wo qua edcirc{uits~betweentheoffsitetransatssion M 2 network and theonsite' Class IE AC Electrical Power Distribution Systes;,p .' y .. .
)
bs ib.;1-dieselgenerators(DGs)k,and3; -l (ect s.e.(-I) W *""****'"M mm . t @, -T*Jo Unf pl;%el circJ+s behseede APPL.!CABILITY: MODES 1, 2, and 3. oWsNe fruMmisdoA APbM'NO M2-L*L k %ss Id' AC. Elet%l pow Dis + Mon Sy s%.)
.- J j,f ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l
C. .OneM;;;i,e., - site Perform SR 3.8.1.1 J C V) 7I'I 1 circuit inoperable for OPERABLE 4;;;;i:;LYoffsite M L2
/' circuit (s).
Acba l/ [- 0%^5 ab ' l Once per thereafter hours On Oor8 kn A c /\ s M . , . b
' g.2 Declare required 24 hours from 415 N 3.0.f4.E. ,
feature (s) with no discovery of no f g 9eg7 offsite power offsite power to available inoperable one d hici-- - A but - when the redundant concurrent with required feature (s) inoperability of f are inoperable, redundant required feature (s) m (continued)
-8WR/44TS- ,,
3.8-1 ": 1, 94/07/95 Bruns.Jck. Un'd Ann)wd do, (~} v .
~ .
r
Insert 3.8.1-1A Not used. a O O
AC Sources-Operating O 3.8.] CT5//bc5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 1.3.I.I Restore & :;:fr:Q' 72 hours n =.5 (continued) 43 offsitt circuit to
.[6 b OPERABLE status. 8tgl. gocbp 3
/ d.3/t. 3 A t .*/ 5 days from h discovery of-g f failure to meet
~
LC0 ef C J One 6 .y.i.Wi~DG 1 Perform SR 3.8.1.1 Ae Ihou@
^
3
- 3. F. l.l inoperable, for OPERABLE Jr:;:'r:d; of(site 83 b.. ^5 ki,C #, circult(s).
Once per hours t'.3, e.lj i e,3/ g g thereafter h as Declare required 4 hours from f .o..r// a q)'.2 O O feature (s), sup orted by the inoperab e DG, inoperable when the discovery Condition concurrent w h redundant required inoperability of feature (s) are redundant inoperable. required feature (s) (continued) BWR/4 STS 3.8-2 Rev I, 04/07/95 O I
- .w.
AC Sources-Operating
- 3.8.1 C1'5/Coc.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
. (continued) #.3.1 Determine OPERABLE 124 ' hours IJ II C DG(s) are not A inoperable due to (f_\
AfLb.f C common cause failure. 2 t,9 6' [ DH
- 7. f./. I [f.3.2 Perform SR 3.8.1.2 124.K hours
- g. b2 -
for OPERABLE DG(s). 3 C.I,C.1,C. tr O'Y M -
.4, Restore.l= ;;. d } DG 72 .'.;,.-
. r J.F. I. I (* OPERABLE status.
A shn M po
" f ~
hf eC'I] ays from I8'3/ . iscovery of t.'3 failure to meet
\ LCOC V.l.a-or Q O . w-Two 4r:aui ,r d) offsite g.1 Declare required 12 hours from (p
circuits inoperable. feature (s) inoperable discovery f p when the redundant Condition D required feature (s) concurrent with 3 L .'0' I
/ are, inoperable, inoperability of redundant h
g required 7 4 feature (s) g9 all Lt g, y, f,l f.2 Restore one 24 hours
-[mtr+re&} offsite e
Ahr J.L/ circuit to OPERABLE status. (continued) BWR/4 STS 3.8-3 Rev 1. 04/07/95 O
l ['i}
' g'd
~
AC Sources-Operating 3.8.1 CTSMS ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME h 4
. One-{-e pir:d] offsite ----------NOT E- ----
A.e circuit inoperable. Enter applicab onditions and Require ctions of AND LC0 3.8. , Distribution Systems-Operating," when One [r;;; ired] DG Condition s entered with I inoperable! no AC powe ource to any g 4fs?'#1 f y.g./t g;g a 6-
]M >
.1 Restore-{r;;d offsite circuit to OPERABLE status.
12 hours
= 0 LTII p.2 Restore-{ . yd. uj DG 12 hours AdW to OPERABLE status.
(~. h Two fr h ]- A.1 Restore 2 hours [r;;;ir;d]DGs 4r;;;ir;d] DG to 7.8./ ' unoperable. k% e.7/L.C; f. OPERABLE status. A (continued) 4 BWR/4 STS 3.8-4 Rev 1, 04/07/95 (~~;
'%.)
I *.
. ;s i
l l t O AC Sources-Operating 3.8.1 C.T5/D<>C5 N A,TIONS C (continued) ._,. CONDITION REQUIRED ACTION COMPLETION Trite F. One equired] -- 4tEVIEWEP.'S NOT - [ omatic loa ondition may deleted quencer) perable. the unit desi is such
/ hat any segue r failure mode will on affect the
,/ ability of e associated DG e to power s respective safety oads following a ss of o site power indepe ent i of r coincident wit a l / sign Basis Event.
F.1 Resto [ required] ] hours f [aut atic load
! / se neer] to / I RABLE status. /
3.8 I l Requirsd Action and G.1 Be in MODE 3. 12 hours b l %/ Ac.45/'G. Associated Completion Time of Ccndition A, 6NJ B, C, u, .fert E ,7 or F ot met. ~ G.2 Be in MODE 4. 36 hours a l _
//),(, H. IThre r H.1 Enter LCO 3.0.3. Imediately
-{ uir AC rces E
j One oc ng. o%sda. CWexsh a4 bo or mne [6s 'gemble., OR.
^% or nec. o4 5Ha c'wcEh a) b0'eDG'emmble[ #
A BWR/4 STS 3.8-5 Rev 1, 04/07/95 O
.., . : r .m . .
AC Sources-Operating 3.8.1 CE/ar_.s SURVE!LLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY m, - 93e. , b SR, 3.8.1.9
"# "b t.,
NOTES
//.3.M.2.d,2/ 1. This Surveillance shall not be - 4- "3 se* L performed in MODE I r However, A8, A3, A.lf/ /4.5~p,l Med )',-
credit say be taken or unplanned events that satisfy h i R. K 3's* l'-7) 2. If performed with th
* * *' b
- synchronized $
with offsite power, it shall be , performed at a power factor s (0.9). f0 _ _ [cere g Verify each DG rejects a load greater than i months): pu,ep or equal to its associated ; b ,h hriest [ toiWd. ge:t- =:y;~;.t 1x4 andt p g b* -j a. 110w1ng lo frequency rejecti , the 5 [65.5 ;.
)
I
- b. Withi }seco followi oad l4 rej on, t oltage is [3740] V -
. s [4 ; and ,~
g/ ,
- c. Within seconds lowing loa l rejec on, the f ency is [
24 .87Hzand $61.2tHz 3.8.1.10 NOTE- '
/'
T Surveillance sh not be performed n MODE 1 or 2. ver, credit may I taken for unp events that s fy this SR. IS
' rify each DG operat at a power factor ,, months) s [0.9? does not and voltage is ,/ /
ma<nta'ned s 4 . Y during and foll
'.a load reject n of 2 [1710] kW and s[2000)ky.
(continued) BWR/4 STS 3.8-9 Rev 1, 04/07/95 .r
~
[D
.d .
AC Sources-Operating 3.8.1 CW/lbcS_ SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY [A'f SR,3.8.1.1) - FIhis urvell
--NOTE '
ce sna 1 not i>e formed b O unp$ D Zayd ^ i 3.r.I-F - l].9.l.l.2d.f y, f *nt w ,'C', f j f f 'f h ,i Verify each DG's automatic trips are months) 4,g/ g,) cu ifan actual or simulated ECCS initiations'gnal$.except:
- a. Engine overspeed; g (,
- b. Gener,ator differential urrent{;
- c. Low lobe oil pressure; 4 uy - '~e ;x;na; xd Z A
O "te -t nih : =hy]. (continued) ck. Eevesse. par ; e,. loss oF Me Oj c4 S, PM3e. oveccurced (wlkje, res4miM, L . BWR/4 STS 3.8-12 Rev 1, 04/07/95
.. . , . . v.
.C35 M INSERT 3.8.1-8 Al A single test at.the specified Frequency will satisfy this Surveillance for b both units.
O O
)
/ AC Sources-Operating V 3.8.1 UVws SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY I Sg 3.8.1.1K NOTES
/l/7 Ig
- 1. Momentary transients outside the load, and power factor ranges do '
not g invalidate this 4est. 3.2.l-9 81 r2. is Su e111ance hall not gk p0 I erfo d in 1 or 2, owevey, cr may akent fors SR. nplanyn s ev nts that satisfy Z, 0 iIlZd f[ , Verify each DG operating at a power factor 5 (O 97 operates for 2 i 'monthst; p
/M.fj M,p f ggg 55fu kw .
%F 2
[34 ] kW; hours ded 2 00] kW- -
. F the int urs of test onded {2850) and 50] kW.
3.8.1.3 - 7 NOTES 9 s 1. This urvalliance shall performed - w in 5 minutes of s ting down the { after the DG ha perated 2 2] hours loa 2 [1710] kW and
' jg .
5 ;2000] kW. Momenta tr'ansients outside load range not invalidate t test.
- 2. DG starts may receded by an engine prelabe p od.
7
~
Verify each s and achieves, [18 months s :12] sec9nds, voltage 2 [3740 M and 5 :4584 W and frequency 2 [5 ] Hz and s;61.2lHz. J (continued) BWR/4 STS 3.8-13 Rev 1, 04/07/95
GTs / Doc 5 INSERT 3.8.1-9 AN A single test at the specified frequency will satisfy this Surveillance for both units. d O O l
AC Sources-Oper cr>/pd SURVE!LLANCE REQUIREMENTS (continued) g
$ SURVEILLANCE FREQUENCY m i.,2 , .
,t.o u.~.l a-m . ..a w 1Ai f N *'3*" "
t/.T.I.l.ed.7/ SR3.8.1.1$ -NOTE'- This Surveillance shall not be nerfa* - SS,A4.10
/3 g 3 2 ein MODE 1, 2
'be taken for,or M nowever, credit anyunplanned events that satisfy g h
Q @ lb's this SR. z4
, Verify. interval'between each sequenced 4 nthsh load block is within i $ of design interval 11foreachloadsquence z reh .
SS 3.8.1.I'(4 - 1. NOTES All DG starts may be preceded by an
@ f,'
//,10 engine prelube period. , M i ^*d M A
, tw 3 . 4 bc, 3 j,,,' 2.
- 2. This surveillance shall not be y -
j/,g A 7 performed in M00E 1,*2 or 3r However, credit may be,taken for 2 h g unplanned events that satisfy this SR. JA O t/.F.1.1. 2d.3/4.g verify, on an actual' or simulated loss of offsite power signal in conjunction with an monthsy actual:or simulated ECCS initiation signal:
- a. De-energization of emergency buses;
/ b. Load shedding from emergency buses; and g" '"*# "
ll.8. I.I.2.6. 3. bl
- M' 1. energizes nently connected loads in s nds,
- 2. energizes auto-connected emergency loads through fload 7 sequenc , j 7 (continued) l .
l l BWR/4STS 3.8-15 Rev 1, 04/07/95 l i'% i-l
Distribution Systems-0per ng 3.8 ELECTRICAL POWER SYSTEMS N 3.8 Distribution Systems-operating LC0 3.8 pivision3f.andJDivision~ 'ACy DCh = :n:: ::-t 38.2l. electrical power distribution subsystems shall be OPEtA8LE:
. u.z.s/ .
a.1 APPLICABILITY: MODES 1, 2, and 3. d
- t. g, ?; *
.g ,
ACTI0ltS Cole! TION REQUIRED ACTION COMPLETION TINE A.1 Restore AC electrical 8 hours W/ A. One or more AC electrical power distribution pou r distribution subsystems to AMI D M b y igl subsystems inoperable. OPERABLE status.
- ~ hours from discovery of e- '
failure to meet
.tw5tm" q 1.1."I~ I ] %
LC0 One or ' vital- B.1 Restore AC vital 2 hdurs I buse perable. distribution subsystems to M OPERABLE s us.
- 16 urs from covery of
/ 11ure to meet u _
/ l
~
' Eg,g3 C.' One or re C.1 Restore DC electrical dGh.C DC electrical power distribution
/kkna/ . power d'stribution subsystems to M A, 3_ubsystems inoperabl . OPERABLE status.
,g- ours from 4 %, ,4e discovery of
.A AA- 6 failure to meet LC0 (continued)
BWR/4 STS 3.8-38 Rev 1, 04/07/95 0
,6 g % % g ,p[$ 4
,pe9 g, p g* j ,g
, ,e 1
Insert 3.8.7-A Not used. 1 1s i I O I O
0,T5/DoO 31 INSERT 3.8.7-1 B. Dne or more DC electrical power B.1 Declare required feature (s), Immediately b distribution supported by the subsystems ino, arable DC inoperable due to electrical power loss of normal DC distribution source. subsystem, inoperable. 3.u.o i AND b AM / B.2 Initiate action to transfer DC Immediately b Wi A,g 4,9' e > electrical power A L A .1, A l s"O distribution 6h subsystem to its alternate DC source. AND h
~N B.3 Declare required Upon completion of b (d feature (s) supported by the transfer of the required feature's DC electrical inoperable DC power distribution electrical power distribution subsystem to its OPERABLE alternate DC subsystem source OPERABLE.
AND B.4 Restore DC electrical power 7 days b distribution AND subsystem to OPERABLE status. 176 hours from discovery of failure to meet the LC0 v
Distribution Systems-Oper ACTIONS (continued) 3' #' 'I
- CONDITION REQUIRED ACTION COMPLETION TIME
$^ C >
3.fE.I ' D. Required Action and D.1 Be in MODE 3. 12 hours associated Completion Wd Time of Condition A, 6tgl , 8 J.F 7.'3 B, sor C not met. 4444 ,' O.2 Be in MODE 4. 36 hours One more DG E.1 Declare ociated Mdiately a ctrical p DG(s noperable, istributi subsyst inoperab1[ - 3
- 3. 8.2.s -
gg 7 7. Two cr-more electrical / g. g power distribution j Enter LCO 3.0.3. Immediately
/,(,/A '2, subsystems inopecable ( b- A (50 1 that result in 2 loss 9 of functior..
p , SURVEILLANCE REQUIREMENTS
) SURVEILLANCE FREQUENCY ll.8.t.1. l.a ,
f,g // SR 3.8.R.1 Verify correct bre er#al neents and 7 days ve hage to frequir )ACx -[nd ".C citd yi s bootelectr'calpowerdistribution 3 subsystems.
/A4 90 i Aalic.JJ pawn awa\bi\'h AI p,g utm se u.n vo:
w n. ca:. % s - % c - :., moaun c<~:A)
, &p h
4e .e % lit )hww.fus. - onc E i d a.2 - po.d w;n W hA i iijkE) r-u 5g ue + ) =<<. alijn.4 f. bivim u_ 63 B. BWR/4 STS 3.8-39 Rev 1, 04/07/95 n A
>....a~.+.,, .
__________m
JUSTIFICATION FOR DEVIATIONS FROM NUREG-1433, REVISION 1 SECTION 3.8 - ELECTRICAL POWER SYSTEMS 3 ' (V 17. (continued) Starting an RHR pump and a CS pump simultaneously, which bounds the condition of a dual unit LOCA, also bounds the concurrent starting of the 480 V MCC loads and an NSW pump (i.e., 1689 kW versus 1424 kW). Although the DGs are not routinely subjected to this slightly harsher test which simultaneously starts a NSW pump and 480 V MCC loads, it is considered reasonable that any DG degradation that would prevent the DG from accepting this load (1424 kW) will be detected during the LOCA with LOOP test required by ITS SR 3.8.1.14 (NUREG-1433 SR 3.8.1.19) and the load block sequence test required by ITS SR 3.8.1.7 'NUREG-1433 SR 3.8.1.18). Since any DG degradation that would prevent the DG from accepting the A proper load during a LOOP without a LOCA signal will be detected during the LOCA with LOOP test required by ITS SR 3.8.1.14 (NUREG-1433 SR 3.8.1.19) and the load block sequence test required by ITS SR 3.8.1.13 (NUREG-1433 SR 3.8.1.18), NUREG-1433 SR 3.8.1.11 is not required to ensure DG OPERABILITY. Not including NUREG-1433 SRs 3.8.1.11 and 3.8.1.12 in the BNP ITS is also consistent with the BNP current licensing basis. The subsequent Surveillance are renumbered, where applicable, to reflect this deletion. (b 18. MODE 3 to the Note which restricts performance of SRs when in MODE 1, 2, or 3 in NUREG-1433 SRs 3.8.4.7 and 3.8.4.8 is not included in the associated BNP ITS SRs (SRs 3.8.4.6 and 3.8.4.7). The deletion is consistent with BNP current licensing basis which restricts performance b of the associated Surveillance to "during shutdown". The BNP current Technical Specifications define shutdown as MODES 3, 4, and 5 (CTS Table 1.2) . In addition, the MODE restrictions on the performance of NUREG-1433 SRs 3.8.1.13 and 3.8.1.14 are deleted in BNP ITS SRs 3.8.1.0 and 3.8.1.11 based on the current licensing basis. g
- 19. The loading on the DGs (assuming one DG failed) during a DBA is less than their continuous design rating. Therefore, it is unnecessary to subject the DGs to loads greater than their 2000 hour rating. As such, NUREG-1433 SR 3.8.1.14.a and b. are deleted in the BNP ITS.
Additionally, the 24 hour load run time is changea to a 60 minute load run time in BNP SR 3.8.1.11 to be consistent with BNP current licensing basis. An upper DG load limit (2000 hour rating) is provided in this Surveillance to prevent routine overloading of the DGs. U BNP UNITS 1 & 2 6 Revision 0
JUSTIFICATION FOR DEVIATIONS FROM NUREG-1433, REVISION 1 SECTION 3.8 - ELECTRICAL POWER SYSTEMS O 42. To be consistent with the ITS format, the requirement to maintain battery cell average electrolyte temperature within the required limit is added to the LCO statement of BNP ITS 3.8.6 (NUREG-1433 Specification 3.8.6) since average electrolyte temperature of the battery cells supports OPERABILITY of the DC electrical power subsystems. The additional requirement to the LCO statement is'made since the LCO for NUREG-1433 Specification 3.8.6 states that battery cell parameters shall. be within the limits of Table 3.8.6-1. However, average electrolyte temperature is not included in this Table.
- 43. Various Surveillance Requirements in NUREG-1433 Section 3.8 are modified by Notes which state the surveillance shall not be performed in MODE 1, 2, or 3. These Note'; also state that credit may be taken for unplanned events that satisfy the associated surveillance. TSTF-8 adds a clarification to the Bases of SR 3.0.1 which allows credit to be taken for unplanned events that satisfy surveillance. However, TSTF-8 also deletes the portion of the NUREG-1433 Section 3.8 Notes that allow credit to be taken for unplanned events. As a result of this change, credit can no longer be taken for unplanned events in MODE 1, 2, or 3 for surveillance modified by these Notes since the Technical Specifications no longer allow exceptions to the MODE restriction requirements in these Surveillance Notes. The basis of this position is b
that the. Technical Specification Bases or interpretations can not be used to change Technical Specification requirements, as documented in the Part 9900 of the NRC Inspection Manual, Technical Guidance - ' O Licensee Technical Specifications Interpretations, and the ITS Bases Control Program. In addition, the description and justification for TSTF-8 only addresses adding the clarification to the SR 3.0.1 Bases and did not address the changes to the NUREG-1433 Section 3.8. Therefore, ) the changes of TSTF-8 with respect to NUREG-1433 Section 3.8 are not i incorporated into BNP ITS Section 3.8.
- 44. Not used.
b O BNP UNITS 1 & 2 12 Revision 0
JUSTIFICATION FOR DEVIATIONS FROM NUREG-1433, REVISION 1 SECTION 3.8 - ELECTRICAL POWER SYSTENS
- 45. The Notes in BNP ITS SR 3.8.1.8, SR 3.8.1.9, 3.8.1.13, 3.8.1.14, 3.8.4.6, and 3.8.4.7 which areclude satisfying these Surveillance in f MODE 1, 2, or 3 (as applica)1e) are revised to be consistent with the BNP current licensing basis and interpretation. The CTS 3/4.8 Bases clarify that the 18 month DG Surveillance are performed on DG 1 and DG 2 when BNP Unit 1 is shutdown and on DG 3 and DG 4 when BNP Unit 2 is shutdown. This Bases clarification was approved by the NRC in a Safety Evaluation dated May 10, 1990. BNP ITS SR 3.8.1.8 (CTS 4.8.1.1.1.b) requires performance of the 18 month offsite circuit Surveillance.
Since each BNP unit has two of the four offsite circuits, it is interpreted that each unit's Technical Specifications govern the performance of the 18 month offsite circuit Surveillance on that unit's offsite circuits. Therefore, BNP ITS SR 3.8.1.8 is performed on the Unit 1 offsite circuits when Unit 1 is shutdown and on the Unit 2 A offsite circuits when Unit 2 is shutdown. BNP ITS SR 3.8.4.6 and UD SR 3.8.4.7 (CTS 4.8.2.3.2.d and 4.8.2.3.2.e) require performance of battery service tests and performance discharge tests. Since each unit has two of the four required DC electrical power subsystems, it is interpreted that each unit's Technical Specifications govern the performance of these Surveillance on that unit's DC electrical power subsystems. Therefore, BNP ITS SR 3.8.4.7 and SR 3.8.4.8 are performed on the Unit 1 DC electrical power subsystems when Unit 1 is shutdown and on the Unit 2 DC electrical power subsystems when Unit 2 is shutdown.
- 46. Not used.
O b l 47. A new Surveillance (SR 3.8.7.2) is added in BNP ITS 3.8.7. SR 3.8.7.2 requires verification, once per 7 days, that no combination of more than two power conversion modules are aligned to DC Electrical Power l Distribution System Division II bus B. This Surveillance ensures that initial assumptions in the BNP Units 1 and 2 battery load study are g maintained. The addition of this requirement is consistent with the current licensing basis reflected in CTS 4.8.2.3.1.b. l BNP UNITS 1 & 2 13 - Revision 0
l-4 O AC Sources-0perating B 3.8.1 LBASES.(continued)
/"
( . .
~APPLICA8ILITY ' The AC sources @ :;;;.:e..] are required to be OPERA 8LE
.in MODES 1, 2 4 a so ensure that:
- a. J Acceptable fuel design lialts and reactor coolant
- pressure boundary limits are not exceeded as a result of A00s or abnomal transients; and
- b. Adequate core cooling is provided and containment OPERA 8ILITY and other vital functions are maintained in the event of a postulated DBA.
t 'I ! The AC power requirements for MODES 4 and 5 are coverd 4-LC0 3.8.2, "AC Sources-Sh*:tdown." 41 ofw c.Ab,*s is m Ac so-c.s . p <epu.J ACTIONS b To en:,ure a highly reliable power s rce remains with one Mj offsite circuit inoperablef it _is essary to verify the availability of the remainingsmanuwainoffsite circui p J.P.l ~g- more frequent basis.~-Since the Required Action.only @ on a
-specifies "perfom," a failure of SR 3.8.1.1 acceptance O ,
criteria does not result in a Reauired artiaa_aat mat. However, if a second Ncircuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Conditt ~ for.
. ffsite circuits ~ inoperable, is entered.- ~
- g, j k g M o,e4%T d "
3 l RequIlredAction cannot be powe
.2, which only applies if .he L ;.ie.
free an offsite source, is intended to @ provide assurance that an event with a coincident single (6 3.)
,//.Mhg*
failure of the associated DG does not result in a complete Ioss of safety function of critical system Thesefeatures[ 6fy/g7 M "d'"d'"* **t' "1*tg Qjt ":a e M 'y b A, ot**i h{,J" ***!!"*8?ith iW M ired feature & failures consist of inoperable features & d&ICQ associated with4gges**=*'=-redundant to the d!v!!i:qthat > has no offsite power. f (4 gry The Completion Time for Required Acti is' intended to y allow time for the operator to evaluate and repair any 1 (continued) 8WR/4 STS 8 3.8-5 Rev 1, 04/07/95 0
* *
- ggr* 9 , '%[ tP;) 4 ,
INSERT B 3.8.1-5 Ad The offsite circuits for two of the four 4.16 kV emergency buses utilize the opposite unit's SAT and UAT. Therefore, this Required Action provides a 45 day time period to perform maintenance on one of the opposite unit's transformers. This is acceptable because performing maintenance on the transformer will increase the reliability of the offsite circuit. However, if a second Unit 1 or 2 offsite circuit becomes inoperable, Condition B and D are entered. b The 45 day Completion Time takes into account the capacity and capability of the remaining AC sources and a reasonable time for performance of maintenance. The Note to Condition A only allows the 45 day Co etion Time to be used when the opposite unit is in MODE 4 or 5. When a Unit 2 offsite circuit becomes A inoperable while Uni is in MODE 1, 2, or 3, ondition B of Unit 1 'E \ 4 Specification 3.8.l a s be entered and the sociated Required Act ons i performed. 4.. u t I f 4 '* 1 7 } 4 p 2. 1o ,O
w,- -- INSERT B 3.8.1-5A Not used. b O 9 O
i INSERT B 3.8.1-5A (continued) Not used. b O O
INSERT B 3.8.1-5A (continued) Not used. b O O u
4 O AC Sources-Operating 8 3.8.1 BASES . ACTIONS g, M .(continued) . discovered inoperabilities. This Completion Time also " allows an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action the Camoletion Time only ins on discovery that both:
@ 44 d eMar k .
a. vaec=
"dg,A.&D :Sas no offsite power Mobsu e*<qend p1vina its loads;h '
- b. A tequired feature aon y _er c'- m e is inoperable, gg If, at any time during the ext once of this Condition (one offsite circuit inoperable) a equired feature subsequently becomes inoperable, this Completion Time would begin to be tracked. (jI[ky e ey&
Discovering no offsite power to one f; - = hs of the onsite Class IE Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with any other bus that has offsite power, results in starting the O Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown. The remaining OPERABLE offsite circa nd DGs are adequate to supply electrical power to the onsTle Class IE Distribution System. Thus, on a component basis, single failure protection any have been lost for the required feature's function; however, function is not lost. The 24 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. I b According to Regulato uide1.93(Re.h,operationmay continue in Condition for a period th -sfiould not exceed 72 hours. With one o site circuit inoperable, the (continued) BWR/4 STS B 3.8-6 Rev 1, 04/07/95 O
.u . m a v., . ,
_...-__-_-...--_____-___-_a
AC Sources-Operating 8 3.8.1 BASES ACTIONS (continued) - reliability of the offsite system is degraded, and the-
- b'
{ potential for a loss of offsite power is increased, with attendant potential for a challange to the plant safety systems. In this condition, however, the remaining OPERABLE nd DGs are adequate to supply electrical g offsitepowercircui @ite to the ons Class IE Distribution System. The 72 hour Completion Time takes into accoun he capacity and capability of the remaining AC sources, asonable time for repairs, and the low probability of a DBA occurring during this period. The second Completion Time for Required Action A.3 f establishes a limit on the maximum time allowed for any rg b combination of required AC power sources to be inoperable 3 8' g ,a. o during any single conti uous occurrence of failing to meet es CO. If Conditio s entered while, for instance, a h t DG is subsequently returned s inoperable, and i OPERABLE, the LC0 may already have been not met for up to j $
. This situation could lead to a total of
" in s , since initial failure to meet the LCO, to restore O 8 ojag yhs the offsite circuit. At this time, a DG cocid again become inoperable, the circuit restored OPERABLE. and an additional 7 % 3 (for a total of & days) allowed prior to complete D
restoration of.the LCO. Thei. day Completion T< a limit on the time allowed in' a spectf ad cond' an tionerovides after ([r k discovery of failure to meet & LC0."his limit is O l.0 'o@ con.sidered reasonable for situations in which Conditions ~ A T C. - ante are entered concurrently. The '831' connector between the 72 hours anQ) day Completion Times means that both Q b Completion nues' apply simultaneously, and the more restrictive Completion i must be met. As in Required Actio , e Completion Time allows for an exception to the normal ' time zero" for beginning the rg b allowed outage time " clock." This excepti results in A 'y*lA y h establishing the ' time zero" at the time hotC0%as initially not met, instead of at the time that Condition was entered. (continued) BWR/4 STS B 3.8-7 Rev 1, 04/07/95 g U s
t O AC Sources-0perating 8 3.8.1 BASES
' ACTIONS g A
(continued) 6 To ensureighly a reliable power source remains with one DG QE ino rable it is necessary to verify the availability of - 6 the offsite circuits on a more frequent basis. Since the trod Action only specifies "perfom," a failure.OSR 3.8.1.1 acceptance criteria does not result in
- a Required Action being not met. However, if a circuit falls to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered.
6 b ^ 6 f b Required Acti 5 is intended to provide assurance that a
- loss of offsite r, during the period that a DG is inoperable, does not result in a complete loss of safety
- g be. y d
. ft.nction of critical systems. These features are designed bOM ' '
~
-41 s on systees ar not ciu Red at red f, relado) ! eats failures consist of inoperable features associated
' with redundant to the d' W i^. that has an Q
i 4.lfokV y ,inoper 1. DG. ,eme,q g bh .- The Caspletion T se is intended to allow the operator time 8- to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the nomal
" time zero" for beginning the allowed outage time " clock."
In this Required Action the Completion Time only begins on discovery that both:
- a. An inoperable DG exists; and ; 9,.c 3
N* J b. A* required feature on the ther di c t = pi i '... I M M is inoperable. 4
, y If, at any time during the existence of this Condition (one DG inoperable), a requi eature subsequently becomes inoperable, this Comp 1 n Time begins to be tracked.
Discovering one DG inoperable coincident with one or more inoperab ed support or supported features, orboth,thatareassociatedwiththeOPERA8LEDGfsKresults in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing (continued) BidR/4 STS 8 3.8r8 Rev 1, 04/07/95 O 1
-h" 3
( i
O AC Sources-Operating 8 3.8.1
+
BASES ACTIONS C (continued) . b 3 concurrently is acceptable because it minimizes risk while: allowing time for restoration before subjecting the unit to - transients associated with shutdown. The remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection for the required feature's functica may have been lost; however, function has not been lost. The 4 hour Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour Completion Time takes into account the capacity and capability of the remaining AC sources reasonable time for repairs, andylow probability of a DBA curring during this period. h b 3>
.3.1 and .3.2 b Required Action 1.3.1 provides an allowance to avoid unnecessary testing of OPERA 8LE DGs. If it can be g
iO p deterrinedthatthecahu exist on the OPERABLE of the inoperable DG does not su 3.s.l.z coes not nave to be wrformed. If the cause of inoperability exists on other G b T 1G(s' . they are & ared iaa-rable upon discovery, and
;ond tioqJEof LCO L.8.1 is enteredjP Once the failure is l g e,r B repairec, and the common cause' failure no longer exists, Required Action J .5.1 is satisfied. If the cause of the g E Initial inoperapie DG cannot be confirmed not to exist on '
the remaining DG(s), performance of SR 3.8.1.2 suffices to
;,rovide assurance of continued OPERABILIT those DGs.
In the event the inoperable DG is stor ;o OPE ,, status prior to c leting either .3.1 or L3. the j - i efbrrective Ation ramL will continue to evaluate the n cause possib111ty. This continued evaluation. however, is no longerander the 24 hour constraint imposed
/
/
while in cond on Mr9 6 to g According to n ic Letter 84-15 (Ref. ), $247 hours is a reasonable time to confirm that the OPERABLE DGs are not affected by the same problem as the inoperable DG. (continued) BWR/4 STS 8 3.8-9 Rev 1, 04/07/95 res4,<<A % I L ) % k M ic. u% a In been
<m as s w w n+ w aLJ .(
cwss k k L Qds4us c-.. AtoW % 4., er( oaam %w.) y .q u ass:hy{
AC Sources-Operating 8 3.8.1 BASES h ACTIONS h NWY 7A * " b te "bMt: ; C:M: ! .^2 Z. peration eey M h @eaa:tinue in condition A ror a pertoa that should not exceed
?? N:r:. In conanton7, the remaining OPERA 8LE DGs and lg 5 offsite the onsite circuits class IEare adequate Distribution to supply System. The d . .-- electr'gr to g[7 Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and Jew probability of a DBA curring during this period. g 3 g i
The second Completion Time for Required Action 3.4 W establishes a limit on the maximum time allowed for any g) combination of required AC power sources to be inoperable during any single cont vous occurrence of failing to meet L F,lA er LC If Condit is entered while, for instance, an of s e circuit perable and that circuit is [h subsequently restored OPERA 8LE, the LCO may already have been not met for up to 72 hours. This situation could lead b Jodgt to a total or u- -- , since initial failure of the LCO, to restore the OG. At this time, an offsite circuit could 6 anain become inoperable, the DG restored OPERA 8LE, and an O g 83 additional 72 hours (for a total erg days) allowed nrior to complete restoration of the LC0. The w way completion Time provides a limit on the time allowed in a specified (TJ,l.a. o<- condition after discovery of failure to meet the LC0f This limit is c_onsidered reasonable for situations in which a*d conomonswenqMe are entered concurrently. ' The "AND" connector between the 72 i;_. - nay Laupseuon Times h T means that both Completion Times appl simultaneously, and the more restrict 1 t be met. g g As in Required Act , the Completion Time allows for an B exception to the norma " time zero" for beginning the- 8 I'l*a orp allowed outage time " clock." This exception results i - establishing the " time zero" at the time that 4he LC as initially not met, instead of the time that Condition 1 was ente C 7 T.1 and .2 @ kequired Action K.1 addresses actions to be taken in the event of inoperability of redundant required features 4 (continued) BWR/4 STS B 3.8-10 Rev 1, 04/07/95 ~(1
O AC Sources-Operating B 3.8.1 SASES ACTIONS- .2 (continued) . concurrent witit inoperability of two%ffsite circuits. Q ,%
- D area Act6 n.1 reduces the vulnerability to a loss of function. The Completion Tisq for taking these actions is t#I h reduced to 12 hours from that allowed with one d4s4s4ee W without offsite power (Required Acti 2). The rationale 6
for the reduction ta 1H hoursns snat ulatory Guide 1.93 Luera allows a Comp' etion Ties of 24 hours for two h r n;; .4 offsite circuits inoperable, based upon the NT' q
- assumption that two complete safety divisions are OPERABLE.d t ---1g3 r.lg, Ifhon a concurrent redundant required feature failure exists,
'2 '. this assumption is not the case, and a shorter Completion- ag
..- Ties of 12 hours is appropriate. These features are O'**7t*C4 b
- designed with redundant safety related dist;;;;.;'TI.e.,
t single division systems are not included in the list . / h , Redundant features that arerequired features inoperable because > failures any inoperability is on consist of any o on eqeccy , = circuits. dirt;tr. redundant to g d4vesien with inoperabl offsite
% g ency g g The Completion Time for Required Action .1 is intended to allow the operator time to evaluate and repair any O discovered inoperabilities. This Completion Time also allows for an exception to the nomal " time zero" for
. beginning the' allowed outage time " clock." In this Required
-Action,'the Caspletion Time only begins on discovery that y.ao er- mom , _
g a. . m = t' W offsite circuits are inoperable; and reda M b. Afoquired feature is inoperable. g M" an If, at any time during xistence of this Condition g g,4 g ,,4 : pg.offsite circuits inoperable quired feature subsequently becomes inoper le, this Completion Time begins to be tracked. D1 C g According to Regulatory Guide 1.93 (Ref. 5), operation may continue in Condition for a period that should not exceed 24 hours. This level of, degradation means that the offsite p electrical power systeem not have the capability to ( effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds (continued) SidR/4 STS B 3.8-11 Rev 1, 04/07/95 O
,--)
+
, ,...t-.s- . . .Qs.3 . . ,
AC Sources-Operating 8 3.8.1 BASES
,@ 3 ACTIONS I.1 and .2 (continued)
I to a total loss of the immediately accessible offsite power
- sources.
Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable. However, two factors tend to decrease tha severity of this degradation level:
- a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure; and
- b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite g c a . qWith of the ergliEii8 offsite circuits inoperable, sufficient onsite AC sources are available to maintain the O unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety yQ analysis. Thus, the 24 hour Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC tiectrical power system capable of meeting its design criteria. g According to Regulatory Guide 1.93 (Ref. 3), with the a available offsite AC sources two less than re utred LCO, operation may continue for 24 hours. If e sources are restored within 24 hours, unrestricted operation may continue. If only ne offsite source is restored within 24 hours, power operat on continues in accordance with Condition A
,, or 8,a5 e p i be. A g Pursuant to LCD 3.0.6, the Distribution System TIONS would not be entered even if all AC sources to it were inoperable, (continced)
WR/4 STS B 3.8-12 Rev 1, 04/07/95 l
L O AC Sources-Operating 8 3.8.1 BASES (g]
.2 7 ACTIONS (coatinued) .
- resulting in de-energization. Therefore, the Required Actions of Conditiot$ are modifie y a Note to indicate A that when Condition"W is enter " w th no AC source to any LE._\
bus, ACTIONS for LC0 3.8.) . Distribution Systems-Operating," must be immediately entered. This [M'g ' y4 c allows ConditioM to provide requirements for the loss of orrsite circuit and one DG without regard to whether gej de-energized. LCO 3.8 provides the d4efsfon QE ap restrict s fo a e-ener i eme+ egg b [ n According to Reg a ie .93 (Re . , operation may M
.U/
continue in Condition 12 hours. In Condition r a period that should not exceed individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the oower systems in this Condition may - Igher than that in concitierrn (loss of he *lbD ""- offsite circuits). This difference in reliability h is o set by the susceptibility of this power system configuration to a single bus or switching failure. The O 12 hour Completion Time takes into account the capacity and capability of the remaining AC sources, repairs, and the low probability of a asonable time for occurring during this period. , (or me*)e. With two s inopera>Te c a N rn.,. ;-'.x.;_c j 7
)
t9iiNWi==WiiE plWan assumed loss of of# site electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, whtch could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk (continued) OWR /4 STS B 3.8-13 Rev 1, 04/07/95 O
". t
_ - . - _ . - _ - - __-_-___-Q
l AC Sources-Operating B 3.8.1 BASES' ACTIONS (continued) b associated with an insiedi- % controlled shJtdown and to minimize the risk associnas with th 1 of degradation. (7 (.Tt69Y According to Regulatory Guide 1.93 ( . 8 '**T$
, with-4en DGs
$ y f,/-7
~
i - inoperable, operation may continue for a period that should L l D % notexceed2 hours 7 u sequence s) is an sential sup rt system to both the offsite ci u t and t DG associ d with a give ESF bus.) [Furthe re, the s uencer(s) n the primar success
/ path p
most sa AC electri from t associated ly powred s ty systems /
- E5 bus's s encer:Iaffec every major bus.) There re, loss of an System in he .
/
' division). The[121hou completion Ti provides a riod/
/of importan time t correct the p oblem commensu te with the of maintaining sequencer 0 ILITY. T stime/
/ period Iso ensures th'at the probab ty of an a , dent requi ngsequencerAPERABILITYoc rring durin period O who the sequencer is inoperable s minimal.
is Conditionjfs preceded by Note that ows the Condition to be deleted if e unit desig is such at any / sequencerfailuremodeon affects the 111ty of he associated'DG to power 1)$ respective fety load under any f
/ condition's. Implicit un this note is he concep that the Condition must be reta ned if any se encer fai ure mode d
results in the inab}l'ity to start or part f the saf y lo. ads when required regardless of ower svail bility, results in overloading the offst power ci uit to a afety jbus during an event thereby cau ing its fa ure. A o
/ implicit in the Note is that t6e Conditio is not plicable to any divjsion that does nof have a se encer.
( , C'.1 and G.2 If the inoperabl'e AC electrical power sources cannot be restored to OPERABLE status within the associated Completion b Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to MODE 4 (continued) BWR/4 STS B 3.8-14 Rev 1, 04/07/95 O,rm A______.___.___.____--.__
TF. I cw.sh b .F T g O AC Sources-Operating B 3.8.1 8ASES-
~
g ACTIONS .G.1 and C.2 (continued) within 36 hours. 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. 11,.1 b Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been l lost. At this severely degraded level, any further losses
~% '
n tin AC electrical power systemJ4M cause a loss of
# Func Lion. Therefore, no aeditional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.
SURVEILLANCE The AC sources are designed to permit inspection and testing of all important areas and features, especially I. REQUIREMENTS those that have a standby function, in accordance with g t'"""'" ^^^ '" (Ref.,4). Periodic component tests are O U/$A72o<3 7 3 I supplemented by exteW5fve functional tests during refueling outages (under simulated accident conditions). The SRs for r- _ [3q f ~
@ 3-demonstrating the OPERA 81LITJ of the DGs are wnn tne recommendations orgegulatory Guide 1.9 (Ref. ,
D '. k h
$fel%'Je1 i ."4 to-' 0:21.100 (".d. ^h and Regulatory Guide .137 t% m(Ref. p;, as addressed in the '
gg GeV.5) Uhere the $Rs discussed herein spectfy voltage and frequency The h tolerances, inimum steadythe following state sussiary outout voltage is applicab g _41RKmF of ;;700;..cis s or o d ' C a ) i to the terminals of 4000 V motors whose minimum o ratin I a- 4.u s A voltage is rpecified as@DE ob3600 V. LJt also abows fo / 4k[mi"-*^ O voltage drops to motors and other equipment down through the 1 34c.)y sf.k1 oJpt go V level where minimum operating voltage is also usually g ,.,;p,:. ,<,s.u specified as 90% of name plate rating. The specified 'jp ,,,;b, 4 st. AV maximumsteadystate.outputvoltageof).{
==4 earating so naan suma r mo r-r p- ug L., p,,k.,9,acs
;n 1
A c., w89 t <4 Awdlt <3
\,
ensures that for a lightly loaded distribution system, g,,,pt t w Mhhw
-the voltage at the terminals of 4000 V motors is no more w SL13 than the maximum rated operating voltag . The specified ---
9 (continued) BWR/4 STS _ B 3.8-15 Rev 1, 04/07/95 _ I j e %,, b. u . .;,- .g,<.-% ulbp g % ggq ,,4u,1 4so y
-% ~ r.~ rJ<.i 4<. sLk O
- I SMus h v.N
%. y.ma s .%
so nos .h , ceikei. 4, % 9to, y M<...Nbi c u kes. Aq ski,_ e y v.th y m et,& <A.4 u, id.
- c.*Mder kn ~ A vel b.p eJ r- bebt i 46a % a.el A 44.10 kV a .dierewj
.w>m ut u n voll . p w+ a N 4to v s4 Lw.4 + ~n.
- is taa s.' =m sf<aJ) sMe,. yegg nth ih y -[_
I \ t I n INSERT B 3.8.1-14A Due to the shared configuration of certain systems.(required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be /,\ DPERABLE to supply power to these systems when either one or both units are in E MODE 1, 2, or 3. In order to reduce the consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, while at the same time avoiding the need to shutdown both units to perform this Surveillance , Note only prec1 es satisfying this Surveillance Requirement for DG and DG 2 hen Unit is in MODE 1, 2, or 3. During the performance of this Surveillance with Unit ot in MODE 1, 2, Lor 3 and with Unit / Din MODE 1, 2, or 3; the p icable T ONS of t e Unit I and Unit 2 ochnical Specification must be ntered if DG or DG s rendered inoperab e by the performance f this urve111ance. I (3 y f d
- E T v vm v_m O
' AC Sources-0perating B 3.8.1
, BASES
~
SURVEILLANCE ~ SR2.8.1.12/ (continu
/
REQUIRDIGITS / .
/
/ rerf e of th urvcillan could poten ly cause pe tions he electri distributi systems that '
, d challe continued eady state ration and, ,
s a resu , plant safe systems. Cr it may be t n for / g unplan events that atisfy thi k4g& &W SR 3.8.1.1
' - htaby CQe.l/l
' his Surveillance demonstrates that DG non-critical rotective g ,{l )' p ro y q-L.
. functions (e.g.highjacketwatertemperature)aregypassed T
. ' C.L -
en an ECCS initiation test signal and critical protective 7 e functions (engine overspeed, generator differential turrent, (*# Ic t j -end low lubricating oil pressurW trip the DG to avert g0g & Dely1 substantial canage to tne us unit. The non-critical trips are bypassed during 08As and provide an alam on an abnomal engine condition. This alars provides the operator with d) f ,#U, sufficient time to react appropriately. The DG availability ON" ' to mitigate the DBA is more critical than protecting the g % c #b = M engine against minor problems that are not immediately J detrimental to emergency operation of the DG. U The month)Frequencyisbasedonengineeringjudgment, '
'4 k4 takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with
- xpected fuel cycle lengths. .0perating experience hasfb h
h o-*b sna11nese componentsMoveHy pass the SR when perfomed at thez;tDoont frequenc .4 Therefore the Frequency was 3 . conc uded to accept le from a re lability stpndpoint The SR is modif ad by a NoteJhe reaso for the se is ih ^ $ xfb se e t = 4*= Y -- *+ b 3.8.I' d _ altsfy this SS A ~ Re r's Note- e above MOD strictions us deleted _) ) g> it can nstrated t e staff, on a nt specific r basis, t perfoming R with the re r in any of the
/ restr ed MODES can isfy the foll criteria, as cable: i p
/ a. Perfo nce of the SR wi not render any s y system or nont inoper (continued)
BWR/4 STS .B 3.8-26 Rev 1, 04/07/95 [ l s
INSERT B 3.8.1-15A O. Not used.
)
b O , l 1 l lO
Tf IN5ERT 5 3.8.1-15 O To minimize testing of the DGs, the Note allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is d allowed since the main purpose of the Surveillance can be met by performing the test on either unit'. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. O I l O
AC Sources-Operating B 3.8.1 st 3.a.1.1 7 SURVEILLANCE tinued) REQUIRDIDITS /A C This Surveillance has been modified by two Notes. Note 1 states that momentary transients due to changing bus loads 4 do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. fThe rea a for Rote is snat -.iing .n..iion w un . Y reac critical rforman of this 111anc uld cau e l A g rbations t el cal dis tion ens J
/E at would alle tinued s y sta perati ,a a resul plant s y sys.t . Credit be ta" for g lan events hat satts is_S!Lre- t
%t. 5 5.t.1- 14, st 3.s.1.15 This Surv lance demonstr es that the esel engi can restart a hot condt' on, such as bsequent shutdown from real Surveill s, and acht the requ voltage requency withi 12] seconds. The [12] ond time is tved frw the urements of he accude analysis to respond to a de n basis la break L The [18 mont Frequency is s stent wi roc ations of R atory Guide 1.108 f. 9), par aph2.a.( ,
This 5 s modified b wo Notes. to 1 ensures at the tast performed w< the dies sufficiently . The rament that i diesel h operated for least 2 hours E full load c tions pri to performanc of this rveillance i based on ufacturer roc ations for achieving ho condition The load ba s provided to avo routine ov oading of he DG. Routi overloads may res t in more nt to inspecti in accordance wi vendor occamendat s in order t maintain DG OPE ITY. ry transt ts due to ch ing bus loads do inv idate thi test. Nete 2 ows all DG sta to be p edad by engine prelu period to minimi wear and tear the die during test g. , SR 3. 1.16 As quired by ulatory Guide 1 (Ref. 9), ragraph2.a.J6),thisSurvati ce ensures that t manual l ynchronizat on and automatic oad transfer from DG to the offsite e can be made that the DG can returned (continued) OWR /4 STS B 3.8-28 Rev 1, 04/07/95 0 6 -* d+ 4 O
INSERT 5 3.8.1-16A Not used. a O O 1
INSERT B 3.8.1-16 To minimize testing of the DGs, Note 2 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is b allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillance, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit. O i
)
l
- O
- ___m___-_ ..-.-_____..______.m _
1 l l INSERT 5 3.8.1-17A Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs, and associated load sequence relays, are required to be OPERABLE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce potential consequences associated with removing a required offsite circuit g from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the need to shutdown both units to perform this Surveillance, the Note on'y precludes satisfying this S veillan Requi nt for the load sequence relays associated with DGl1 nd DG hen is i MODE 1, 2, or 3. During the perform ce of this Surveil anc with Unitf1 ot in MODE 1, 2, or 3 and with Unit MODE 1, 2 or 3; the 8 applicabl CTIONS of the Unit I and Unit Techn ca pecifica o must be i entered if a required offsite circuit, DG or DG is rendered noperable by I the performance of this Surveillance. 2 4 3 (4 g e v e. ewo no
*n ws i twa L w4L wtL O
O
l [
~ INSERT 5 3.8.1-19 L
Due to the shared configuration of certain systems (required to mitigate DBAs and transients) between BNP Units 1 and 2, all four DGs are required to be OPERA 8LE to supply power to these systems when either one or both units are in MODE 1, 2, or 3. In order to reduce the potential consequences associated with removing a required offsite circuit from service during the performance of this Surveillance, reduce consequences of a potential perturbation to the d electrical distribution systems during the performance of this Surveillance, and reduce challenges to safety systems, while at the same time avoiding the l need to shutdown both units to perform this Surveillance, t e Note 2 only preci es satisfying this Surveillance Requirement for DG J d DG(Owhen Unit is MODE 1, 2, or 3. During the performance of t is urveT11ance /,\ 1th it at in MODE 1, 2, or 3 and with Unit n MODE 1, 2 or 3; the C applicabl CTIONS of the Unit I and Unit Tech ca ecifica on must be entered if a required offsite circuit, DG DG or other supporte Technical Specification equipment is rendere in pera 1 by! the e ormance of this Surveillance. C M 2- 4 /A\ INSEAT B 3.8.1-20 [2 y / 3 Not used. { d2. $x 2_ v i O V
INSERT B SR 3.8.3-1 For the purposes of this SR, the verification of the main fuel oil storage tank fuel oil volume is performed on a per DG basis. . This per DG volume is obtained using the following equation:
+ U, b
; where M. - measured fuel oil volume of the main fuel oil storage tank, U, - unusable fuel oil volume of the main fuel oil storage b
tank, and N,, - number of DGs required to be OPERABLE. The results from this equation must be 2: 20,850 gallons in order to satisfy the acceptance criteria of SR 3.8.3.1.b. O l 4 1 i
)
o ,
O Olstribution Systems-Operating B 3.8. BASES' LC0 bat _ter r charge ERAB ltal bus lectri i powe (continued) (dis)'iputi upsy ens r the ociate uses ipvfrg u o th prop voltage on the sociat I inv er via verte DC volta , inver" using te (AC voltagV.ransfo r). gp j h L ource s const W h5fF In additio le breakers *between redundant safety related N AC/DCDE@E =: == power distribution subsystems, if B 3.Fa-3 J they exist, ust be noens This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, which could cause Tohrr the failure of a redundant subsystem and,a loss of essential safety function (s). If any tie breakers are closedP the gMyld or g40,3 a 7 6 3 8..I-% affected redundant electrical power distribution subsystems O
- are considered inoperable. This applies to the onsite, bh" I safety related, redundant electrical power distribution subsystems. It does not, however, preclude redundant
(-M'f "s Class IE 4.16 kV @ buses from being powered from the same i offsite circuit. q APPLICABILITY The electrical power distribution subsystems are required to i be OPERABLE in MODES 1, 2, and 3 to ensure that: C
- a. Acceptable fuel design limits and reactor coolant y pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and o.)o&re.,U b.
Adequate coreand cooling p a g .4 Ot. OPERABILITY otherisvit!rovided, andare 1 functions containment maintained in the event of a postulated DBA. AWd p J M ' M ar i M *5 Electricalhower distribution subsystem requirem?nts for
%d _ MODES 4 and Pare covered in the Bases for LCO 3.8.14,
" Distribution Systems-Shutdown."
ACTIONS L1 W one or more required AC busesg O iente n . - dis M i h LJ ol r*t inoperable,the $ or distribution remaining panels in AC electrical one distribution power civision subsystems are capable of supporting the minimum safety functions necessary to shut down the reacter and maintain it b (continued) BWR/4 STS B 3.8-81 Rev 1, 04/07/95 O V te
- - - - - - - - - - - - _m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'""~"^
O Not used. l O I O
INSERT B 3.8.7-ACT A (continued) Not used. b O 1
Distribution Systems-Operating d B 3.8. . 7 8 BASES ACTIONS A J (contipued) OC in a safe shutdown condition, ass ing no single failure. - The overall reliability is reduc d, however, because a single failure in the remaining ower distribution subsystems could result in the minimum required ESF functbns not being supported. Therefore. the required AC and distribution h busespanels must be restored to OPERABLE statufwithin 8 hours. The Condition A worst scenario is one division without AC power (i.e., no offsite power to the divir, ion and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit r and en restoring-power to the affected division. The 8 houftime limit before requiring a unit shutdown in this Condition is acceptab us ,
- a. The. .. _ potential for decreased safety if the unit operators' attention is diverted from the evaluations 7 and actions necessary to restore power to the affected 3 division to the actions associated with taking the los unit to shutdown within this time limit.
- b. Th) potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5 " Safety Function Determination Program (SFDP).') g 7 The second Completion Time for Required Action A.I establishes a limit on the maximum time allowed for any g
combination of required distribution subsystems to be ino erable during any single contiguous occurrence of fat ing to meet the LCO. If Condition A is entered while, * #+
.for instance, a DC bus is inoperable and subsequently returned OPERABLE, this LCO may already have been not met p). 3 for up to*2 L ws. This situation could lead to a tot g duration of S hours, since initial failure e L 0, to restore the A distribution system. At this me a DC D h it could again become inopera n A distribution lecMca l h.e b (continued) dWR/4 STS B 3.8-82 Rev1,04/07/95 a
4
F
.i 9
O Distribution Systems-Operating B 3.8.
. BASES ^)
i ACTIONS
>z..
Ad (continued) , [ i f ould be restored OPERABLE. This could continue h indefinitely. *
- This Completion Time allows for an exception to the nonnal
" time.zero" for beginning the allowed outage time " clock."
This results.in establishing the " time zero" at the time i 7 6 this LC0 was initially not met, nstead of at the time ondRTin was entered. The our completion iine is an acceptable @ limitation on this potential to fail to meet the h LCO indefinitely. With one A ital bus ino rable, e remainin PERABLE AC
/
p4Rr \ -=/ - vital bu s are capabi f suppo ing the mi functi s necessary shut d the unit safety maintain in g 3,r.7-3b l the fe shut ondition. verall re bility is j r ced howev , since an ditional ngle failur could fesultInt Therefore, minimum re red ESF f ctions not ing e require C vital b must be /
/
/ supported restore o OPERABLE atus wit 2 hours b owering the O $ 1 I bus f the assoc ed[inve r via inv ed DC invert usi internal source, o lass'1E c tantvoltage t nsformer).
Conditio represen one AC vi bus withou ower; potent ly both t DC source d the asso ed AC sourc f
/ are afunctioni si ificantly interru
. In this re vulner ble power.
tuation th lant is e to a com M4 e loss of a t is, thereiore, imperat that k he oper, r's atten n focus on s (bilizing th lant, minimi (ng the pot tal for loss f power to e remaining
/ vita uses, an estoring p bu ds.
to the affe ed AC vital /
/This 2 h limit is no conservative an Completion mes allow 3 the ma,jorit of components at are withou o
ade s.e vital AC ppeer. Taking exp tion to LCO .0.2 for e onents withouyadequate vital C power, tha ould have quired Action ompletion Time shorter than hours if declared inope ble, is accep ble because : (continued)
-BWR/4 STS B 3.5-83 Rev 1, 04/07/95 eh Y ,
,w. W "'. + y < . ,u e ,
S INSERT B 3.8.7-3b B.I. B.2. B.3 and B.4' b
.With one or_ nore DC electrical power distribution subsystems inoperable due to loss of normal DC source,'the remaining DC electrical power distribution g
! subsystem (s) are capable of supporting the minimum safety functions necessary to shutdown the reactor and maintain it in a safe shutdown condition, provided safety function is not lost and assuming no single failure. However,_the overall reliability is reduced because a single failure in the DC electrical power. distribution system could result in a loss of two of_ four AC electrical load groups and the minimum receired ESF functions not being supported.
Therefore, action must be immecintely initiated to transfer the DC electrical power distribution system to its alternate source and the affected supported equipment-immediately declared inoperable. Upon completion of the transfer of the affected supported equipment's DC electrical power distribution subsystem to its OPERABLE alternate DC source, the affected supported equipment may be 8 declared OPERABLE again. The ESS logic cabinets transfer automatically upon loss of the normal source. For an ESS logic cabinet, verification that the automatic transfer has occurred and alternate power is available to the ESS logic cabinet will satisfy Required Action B.2. By allowance of the option to declare affected supported equipment inoperable with associated DC electrical b power distribution subsystems. inoperable due to loss of normal DC source, more conservative restrictions are implemented in accordance with the affected system LCOs' ACTIONS. When any control power transfer switch associated with the 4.16 kV and 480 V emergency buses or any transfer switch associated with the ESS and DG panels is transferred to the alternate source, a single failure O in the DC system could render two of four AC electrical load groups inoperable. Therefore, to prevent indefinite operation in this degraded condition, power from the normal DC source must be restored in 7 days. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. Required Actions B.1 and B.2 should be completed as quickly as possible. The 7 day Completion Time of Required b Action B.4 is considered to be acceptable due to the low potential for an event in c.onjunction with a single failure of a redundant component and is g consistent with the allowed Completion Time for an inoperable DC electrical power subaystem specified in Specification 3.8.4, "DC Sources-Operating." O
T
-INSERTB3.8.7-3b(continued)
-The second Completion Time for Required Action B.4 establishes a limit on the maximum time allowed for any combination of required electrical power b
distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LC0 8 may already have been not met for up to 8 hours. This situation could lead to a total duration of 176 hours, since initial failure to meet the LCO, to restore the DC electrical power distribution system. At this time, an AC bus could again become inoperable, and DC electrical power distribution system could be restored OPERABLE. This could continue indefinitely. This Completion Time allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." This allowance results in establishing the " time zero" at the time the LCO was initially not met, instead of at the time Condition 8 was entered. The 176 hour Completion Time E is an acceptable limitation on this potential of failing to meet the LC0 indefinitely. O i Q. __.__.-___--.____._____-_-___-_____.__-_.-_..___-.___a
1 l 1 l Distribution Systems-Operating B3.8.J 8ASES w_ ejedrical r.Mc)isMbJ.A. m6sys k ACTIMS U 9' (continued) With one 66eH en-*=rr & DC noperableDthe remaining DC T __ electrical power distribution subsystem is capable of Ie [ supporting the minimum safety functions necessary to shut ob7^ down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in d*4M O b the remaining DC electrical power distribution subsystes could result in the sinimum required ESF functions not being __ - supported. Therefore, the required DC buses %ust De ggg restored to OPERABLE status within . by powering the p,, dMa bus from the associated batter charge . y g g g j Condition C represents one division without adequate DC power, potentially with both the battery 41gntricantly h degraded and the anociated chargegnonfunctioning. In this untion the plant is significantly more vulnerable to a [5) complete loss of all DC power. It is, therefore, imperative
- that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the Of remaining divisions, and restoring power to the affected di/ision. @'
hou a re rvat an C g ep p g j aking except'on to Lco 3.0.2 for components without a equate DC power, which would have Required Action Completion Times shorter than " Y , is acceptable because of:
- a. The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown)whilenotallowingstableoperationsto continue;
- b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required .
Actions for components without DC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring 3 l o .) power to the affected division;
- c. The otential for an event in conjunction with a sing a failure of a redundant component.
(continued) l BWR/4STS B 3.8-85 Rev 1, 04/07/95 0 9 11 . 4 . 9g
( ? Distribution Systems-Operating 8 3.8.7 BASES ACTIONS Cil (continued) . IT h let buse consist [1 , i The secord C letion Time for Required Action C.1 l establishes a imit on the _ maximum time allowed for any /etyq7y 'I combination of requiredadrstr1Duu on suosystems to be ,, inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C 'is entered while. 3 for instance, an AC bus is inoperable and subsequently t restored OPERABLE, the LC0 may already have been not met for 3 f g up to 8 hours. This situation could lead to a to duration ofdthours, since initial failure e LCO, to as restore the'DC# distribution system. At this ime, an AC l 5ould vm= becould again become inoperable, and DC*tnstributioq _leds, I
,--- restored OPERABLE. This could cent nue e 1
elecju 1 I
,g iaderiaitair-This Coopletion Time allows for an exception to the normal a-
, ' time zero" for beginning the allowed outage time " clock."
This allawance result; in establishing the ' time zero' at the time the LCO was initially not met, instead of at the A) i V time Condition'C was entered. The hour Completion Time is an accerptable limitation on this otential of failing to meet the LC0 indefinitely.
.c, g 17 6 5 b
,D.1 'and D.2 6 )ec4 d e,1 Q @ l Iftheinoperabledistributionsubsystemcannotberestored '
- to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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.
L1 -- Wi one or DG DC buses erable, the ass ted (s) may incapable of oming their in ed j i functio . In this situ on the DG(s) mu tamedia ely )
% 2
. (continued)
BWR/4 STS B 3.8-86 Rev I, 04/07/95 A l
Distribution Systems- r g BASES w ACTIONS bid continu clared operable. T action al requires en into applic e Conditions nd Requir etions of L . 8.1, *
- Sour s-Operating."
Conditio f rresponds to a level of degradation in the , y electrica stribution system that causes a required safety ' function to be lost. When more than one AC or DC electrical power distribution subsystem is lost, and this results in 3 the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LC0 3.0.3 must be entered isusediately to commence a controlled shutdown. 3.8. / SURVEILLANCE SR B 3 g/7 'I" REQUIREMENTS This Surveillance veriffes that the AC and DC electrical
/
.powerdistributionsystemsarefunctioninanro[perly,wi_th
-O If the correct circuit breaker alignment. G e correct Dreaker-alignment ensures the appropriate separation and independence of the electrical buses are maintained, and Gu>
c ite ff ^ is available to each required bus.v ';The A ve~ icaSion co - 21 ---
- - the buses LA._T s "s reaciiy available for 6g ensures that the required e s 7 motive as well as control func< Tons for critical system .
f' loads connected to these buses.# The 7 day Frequen takes into account Ine recunaant capaTility of the ACx AC g enM*M Dg 008" C electrical power distribution subsystems, and indications available in the control room that alert I h v b.4 w l4=ft a W W o the o erator to subsystem malfunctions. 4 g[.7 4g g b b 7ve @
- M P' M J
- 4.,,4&. to.a h oPeregj u i ,.
M FERENCES- 1. FSAR, Chapter . bCFR .sb.3C (CMd5
- 2. FSAR, Chapter (15}.
- 3. ' ;'1' " a y e"i d- ! es n.r..k.r ia m J
BWR/4 STS B 3.8-87 Rev 1, 04/07/95 O I$- ,,4 N
NO SIGNIFICANT HAZARDS EVALUATION' ITS: 3.8.1 - AC SOURCES-OPERATING Ll33H8NGE In accordance with the criteria set forth in 10 CFR 50.92, Carolina Power and Light Company has evaluated this proposed Technical Specifications change and detemined 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 b consequences of an accident previously evaluated?
The proposed change establishes Required Actions for more than two offsite circuits inoperable which will allow 24 hours to attempt to restore three offsite circuits to OPERABLE status before entering Condition G which requires that the reactor be in MODE 3 within 12 hours and MODE 4 within 36 hours. Existing specifications require immediate 8 entry into CTS 3.0.3 whenever more than two offsite circuits are inoperable. While the loss of all offsite AC sources is identified as an initiator of an analyzed event in the UFSAR, the probability of an accident is not increased since the change only provides a time period for restoration after the event has occurred. With two or more offsite circuits inoperable, insufficient offsite AC sources are available to effect a safe shutdown and to mitigate the effects of an accident. However, the onsite AC sources (DGs) have not been degraded in this condition and are available to maintain the units in a safe shutdown condition in the event of a Design Basis Accident (DBA) or transient on O one of the units. In fact, a simultaneous, loss of offsite AC sources, a LOCA, and a worst case single failure are postulated as part of the design basis in the safety analysis. In addition, the configuration of the onsite AC sources (DGs) is such that they are not susceptible to a single failure which can cause more than one DG to become inoperable. l (At BNP only three of the four DGs are required to mitigate the consequences of a DBA or transient and maintain the units in safe b l shutdown.) Therefore, the 24 hour time period for this condition is L considered acceptable since the capability still exists to mitigate the effects of a DBA and maintain the units in safe shutdown and the > consequences of a previously evaluated accident are not impacted. Therefore, this change will not involve a significant increase in the probability or consequences of'an accident previously evaluated. .
- 2. Does the change create the possibility of a new or different kind of ; q accident from any accident previously evaluated? l j This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or the manner in which these SSC are, operated, maintained, modified, tested, or inspected.
Therefore, this change will not create the possibility of a new or different kind of accident from'any accident previously evaluated, i O BNP UNITS 1 &'2 16 Revision'0 r
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.8.1 - AC SOURCES-0PERATING O, L.13 CHANGE (continued)
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change establishes Required Actions for more than two b offsite circuits inoperable which will allow 24 hours to attempt to restore three offsite circuits to OPERABLE status before entering Condition G which requires that the reactor be in MODE 3 within 12 hours and MODE 4 within 36 hours. Existing specifications require immediate e entry into CTS 3.0.3 whenever more than two offsite circuits are inoperable. The proposed change does not involve a significant reduction in a margin of safety because the onsite AC sources (DGs) have not been degraded in this condition and are available to maintain the units in a safe shutdown condition in the event of a Design Basis Accident (DBA) or transient on one of the units. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure are postulated as part of the design basis in the safety analysis. In addition, the configuration of the onsite AC sources (DGs) /A is such that they are not susceptible to a single failure which can E cause more than one DG to become inoperable. (At BNP only three of the four DGs are required to mitigate the consequences of a DBA or transient > and maintain the units in safe shutdown.) Therefore, the 24 hour time period for this condition is considered acceptable since the capability still exists to mitigate the effects of a DBA and maintain the units in safe shutdown. The proposed Completion Time avoids the risk associated dp with an immediate shutdown but minimizes the risk associated with this level of degradation i I I o i b i BNP UNITS 1 & 2 17 Revision 0
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.8.1 - AC SOURCES-0PERATING L.15 CHANGE Not used. O a I l
)
i O
'BNP UNITS 1 L 2- 19 Revision 0
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.8.1 - AC SOURCES-OPERATING L.15 CHANGE (continued). Not used. O A I I l l i O BNP UNITS 1.& 2 20 Revision 0 i I
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING O L.2 CHANGE Not used. . b O LO
-BNP_ UNITS 1 & 2 2 Revision 0 )
NO SIGNIFICANT HAZARDS EVALUATION ITS: 3.8.7 - DISTRIBUTION SYSTEMS-0PERATING O L.2 CHANGE (continued) Not used.
^
O O BNP UNITS 1 & 2 3 Revision 0
Prograns and Manuals 5.5 5.5 - Programs and Manuals 5.5.7 Ventilation Filter Testina Proaram (VFTP) (continued)
- c. 2) Demonstrate for the CREV System that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 1, A
Position C.6.b. and tested in accordance with ASTM D3803-1989, at a temperature of 30'C and a relative humidity of 95% within the' temperature and humidity tolerances provided in Table 1 of g ASTM D3803-1989, meets the acceptance criteria of
< 5.0% penetration of methyl iodide, g
- d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilter (SGT only), and the charcoal adsorbers is less than or equal to the value specified below when tested at the system flowrate
! specified as follows: ESF Ventilation System Delta P (inches wg) Flowrate (cfm) SGT System 8.5 2700 to 3300 CREV System 5.25 1800 to 2200
- e. Demonstrate that the heaters for each of the SGT subsystems dissipate;t 16.67 kW under a degraded voltage condition when tested in accordance with ANSI N510-1975.
u 5.5.8 Explosive Gas and Storace Tank Radioactivity Monitorino Proaram This program provides controls for potentially explosive gas mixtures contained in the Main Condenser Offgas Treatment System and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The program shall include:
- a. The limits for concentrations of hydrogen in the Main Condenser Offgas Treatment System and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and (continued)
Brunswick Unit 1 5.0-12 Amendment No.
4
. Programs and Manuals 5.5
.5.5 Programs and Manuals 5.5.8 Exolosive Gas and Storaae Tank Radioactivity Monitorina Proaram (continued)
- b. A surveillance program to ensure that the quantity of radioactivity contained in each outdoor liquid radwaste tank that is not surrounded by liners, dikes, or walls, capable of holding the tank's contents'and that does not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is s 10 Curies,~ excluding b
tritium and dissolved or entrained gases. The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program Surveillance Frequencies. 5.5.9 Diesel Fuel Oil Testina Proaram A diesel fuel oil testing program shall establish required testing of both new fuel oil and stored fuel oil. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following: O- a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has not become contaminated with other products during transit, thus altering the quality of the fuel oil;
- b. Kinematic viscosity is within limits for ASTM 2-D fuel oil when tested every 92 days; and M
- c. Total particulate concentration of the fuel oil is s 10 mg/l when tested every 31 days in accordance with the applicable ASTM Standard.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program test Frequencies. 5.5.10. Technical Specifications (TS) Bases Control Procram This program provides a means for processing changes to the Bases of these Technical Specifications. (continued) O Brunswick Unit 1 5.0-13 Amendment No. L, ,
1 1 Prograns and Manuals 5.5 l [) V 5.5 Programs and Manuals 5.5.12 Primary Containment Leakaae Rate Testina Proaram (continued)
- b. Following air lock door seal replacement, performance of door seal leakage rate testing with the gap between the door seals pressurized to 10 psig instead of air lock testing at P as specified in Nuclear Energy Institute Guideline 94-01, Revision 0;
- c. Reduced duration Type A tests may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-1, Revision 1.
d
- d. Performance of Type C leak rate testing of the hydrogen and oxygen monitor isolation valves is not required; and
- e. Performance of Type C leak rate testing of the main steam isolation valves at a pressure less than P instead of leak rate testing at P, as specified in ANSI /AN$ 56.8-1994.
The peak calculated primary containment internal pressure for the design basis loss of coolant accident, P,, is 49 psig, The maximum allowable primary containment leakage rate, L,, shall (o) be 0.5% of primary containment air weight per day at P,. Leakage rate acceptance criteria are:
- a. Primary containment leakage rate acceptance criterion is ,
s 1.0 L,. During the first unit startup following testing in j accordance with this program, the leakage rate acceptance l criteria are < 0.60 L, for Type B and C tests and s 0.75 L, i for Type A tests.
- b. Air lock testing acceptance criteria are:
)
- 1) Overall air lock leakage rate is s 0.05 L, when tested at 2 P,. %
- 2) For each air lock door, leakage rate is s 5 scfh when the gap between the door seals is pressurized to 2 10 psig.
dl g The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program frequencies.
/m l
G 1 1 Brunswick Unit 1 5.0-16 Amendment No. l
Reporting Requir:ments 5.6 f) 5.6 Reporting Requirements (continued) tg 5.6.5 CORE OPERATIhG LIMITS REPORT (COLR)
- a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
- 1. The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) for Specification 3.2.1;
- 2. The MINIMUM CRITICAL POWER RATIO (MCPR) for Specification 3.2.2;
- 3. The Allowable Value for Function 2.b, APRM Flow Biased Simulated Thermal Power-High, for Specification 3.3.1.1; and
- 4. The Allowable Values and power range setpoints for Rod Block Monitor Upscale Functions for Specification 3.3.2.1.
- b. The analytical methods used to determine the core operating
,o limits shall be those previously reviewed and approved by i
) the NRC, specifically those described in the follcwing documents:
- 1. NEDE-240ll-P-A, " General Electric Standard Application for Reactor Fuel" (latest approved version).
- 2. NED0-32339-A, " Reactor Stability Long Term Solution:
Enhanced Option I-A," July 1995.
- 3. NEDC-32339-P Supplement 1, " Reactor Stability Long Term Solution: Enhanced Option I-A ODYSY Computer Code,"
March 1994 (Approved in NRC Safety Evaluation dated January 4, 1996).
- 4. NED0-32339 Supplement 3, " Reactor Stability Long Term Solution: Enhanced Option I-A Flow Mapping Methodology," August 1995 (Approved in NRC Safety Evaluation dated May 28,1996).
- 5. NRC Safety Evaluation for Brunswick Unit 1 Amendment No. 194. 8 (continued)
_) l Brunswick Unit 1 5.0-19 Amendment No. A
Progra s and Manuals 5.5 5,5 . Programs and Manuals
'5.5.7 Ventilation Filter Testina Proaram (VFTP) (continued)
- c. 2) Demonstrate for the CREV System that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 1, Position C.6.b, and tested in accordance with ASTM D3803-1989, at a temperature of 30*C and a relative humidity of 95% within the temperature and humidity tolerances provided in Table 1 of ASTM D3803-1989, meets the acceptance criteria of
< 5.05 penetration of methyl iodide. g
- d. Demonstrate for each of the ESF systems that the pressure drop across the combined HE.aA filters, the prefilter (SGT only), and the charcoal adsorbers is less than or equal to l
the value specified below when tested at the system flowrate ~ specified as follows: ESF Ventilation System Delta P (inches wg) Flowrate (cfm) SGT System 8.5 2700 to 3300 CREV System 5.25 1800 to 2200
- e. Demonstrate that the heaters for each of the SGT subsystems dissipate a 16.67 kW under a degraded voltage condition when tested in accordance with ANSI N510-1975.
5.5.8 Explosive Gas and Storace Tank Radioactivity Monitorino Proaram This program provides controls for potentially explosive gas mixtures contained in the Main Condenser Offgas Treatment System and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The program shall include:
- a. The limits for concentrations of hydrogen in the. Main Condenser Offgas Treatment System and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion); and (continued)
O Brunswick Unit 2 5.0-12 Amendment No.
- _ _ _ = . _ - _ _ - _ _ . _ . - -
Progra:s and Manuals 5.5 5.5 Programs and Manuals 5.5.8 Exolosive Gas and Storaae Tank Radioactivity Monitorina Procram (continued)
- b. A surveillance program to ensure that the quantity cf radioactivity contained in each outdoor liquid radwaste tank that is not surroundsd by liners, dikes, or walls, capalile l of holding the tank's c.ontents and that does not have tank b^.
overflows and surrounding area drains connected to the Liquid Radwaste Treatment SM tem is s 10 Curies, excluding tritium and dissolved or entrained gases. The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program Surveillance Frequencies. 5.5.9 Diesel Fuel Oil Testina Procram A diesel fuel oil testing program shall establish required testing of both new fuel oil and stored fuel oil. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following: j
- a. Acceptability of raw fuel oil for use prior to addition to storage tanks by determining that the fuel oil has not becomo contaminated with other products during transit, thus altering the quality of the fuel oil;
- b. Kinematic viscosity is within limits for ASTM 2-D fuel oil when tested every 92 days; and b
- c. Total particulate concentration of the fuel oil is s 10 mg/l when tested every 31 days in accordance with the applicable ASTM Standard.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program test Frequencies. 5.5.10 Technical Specifications (TS) Bases Control Procram This program provides a means for processing changes to the Bases of these Technical Specifications. I (continued) Brunswick Unit 2 5.0-13 Amendment No. l
Prograns and Manuals I 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakaae Rate Testina Proaram (continued)
- b. Following air lock door seal replacement, performance of door seal leakage rate testing with the gap between the door seals pressurized to 10 psig instead of air lock testing at P as specified in Nuclear Energy Institute Guideline 94-01, R,
e vision 0;
- c. Reduced duration Type A tests may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-1, Revision 1.
b
- d. Performance of Type C leak rate testing of the hydrogen and oxygen monitor isolation valves is not required; and
- e. Performance of Type C leak rate testing of the main steam isolation valves at a pressure less than o instead of leak rate testing at P, as specified in ANSI /AN$ 56.8-1994.
The peak calculated primary containment internal pressure for the design basis loss of coolant accident, P,, is 49 psig.
# The maximum allowable primary containment leakage rate, L,, shall
( be 0.5% of primary containment air weight per day at P,. Leakage rate acceptance criteria are:
- a. Primary containment leakage rate acceptance criterion is s 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 L, for Type B and C tests and s 0.75 L, for Type A tests. d
- b. Air lock testing acceptance criteria are:
- 1) Overall air lock leakage rate is s 0.05 L, when tested l at 2 P,. p
- 2) For each air lock door, leakage rate is s 5 scfh when the gap between the door seals is pressurized to d
h 10 psig, d, The provisions of SR 3.0.3 are applicable to the Primary , Containment Leakage Rate Testing Program frequencies. ! i v Brunswick Unit 2 5.0-16 Amendment No. '
cibedim $$
~
[ PLANT SYSTEMS 3/4 C0KT ROOM NCY VfdllATIONYSTEM b mvrtil nrnill MTS ( nued) Verifying fitMh 31Afys M6r rem 6v9 aboratory
$6.7.c. 2) @ analysis ofEa representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1. July 1976, and tested in accordance with the raethodology provided by ASTM D38031989, at a temperature of 30*C and a relative humidity of 95%* meets the acceptance criteria of < 5.0% penetration of methyl iodide.
g g' 7'f @ Verifying a system flow rate of 2000 cfm i 10% during system operation when tested in accordance with ANSI N510-1975. g* g*7 After every 720 hours of charcoal adsorber operation by verifying g 7tyn apys atwr remetaDthat a laboratory analysis of a r xmmauve carbon sample obtained in accordance with ulatory Position C.6.b of Regulatory Guide 1.52. Revision 1. 6.5.7.c.2) Ju y 1976, and tested in accordance with the, methodology provided ASTMD3803-1989. at a temperature of 30*C and a relative I idity of 951. meets the acceptance criteria of < 5.01 penetration off methyl iodide.
@ At least once per s -
@ Verifying that re e dr across the combined HEPA filters and charcoa adsorber nks is 5 5.25 inches Water 567d Gauge while operating the filter train at a flow rate of -
2000 cfm i 10%.
- 2. Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system.
- 3. Verifyi that on a chlorine detector test signal, the See \ control 11 ding ventilation system automatically isolates
- and the control room emergency filtration system cannot be
- started by a smoke detector or control room ventilation M*W/ system high radiation test signal.
- 4. Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system operation.
- Laboratory testi within the t rature and humidity tolerances nrovided in Table of ASTN 03803- 989 constitutes compliance with
- 66. 7.c. Z) S~urveillanceRequirements4.7.2.b.2and4.7.2.c.
l b D BRUNSWICK'- UNIT 1 3/4 7-4 Amendment No,
'd .gc, 9775603 py N .4 3r L:
I i A.I S p e s % fic, S.5
. J / PbWTSYSTEMS 3/4.7 CONTROL EMERGENC ILATI TEM j l 5 ILLANCE IREM tinaed) l
( - . A d2 Vert fying ditimi Wnavs a6er rMfovaCt. aboratory 6.5 7 C' analysis of a representative carbon sample obtained in
'accordance with Regulatory Position C.6.b of Regulatory j Guide 1.52. Revision 1. July 1976 and tested in accordance -
with the methodology provided by ASTH D3803-1989, a,t a temperature of 30*C and a relative humidity of 95% . meets the acceptance criteria of < 5.0% penetration of methyl iodide. gg'gj h Verifying a system flow rate of 2000 cfm i 10% daring system operation when tested in accordance with ANSI N510-1975. g g'g (O After every 720 hours of charcoal adsorber operation by verifying i .ipaayserter perliov@ that a laboratory analysis of a re resentative carbon sample obtained in accordance with R ulatory Position C.6.b of Regulatory Guide 1.52. Revision 1. Ju y 1976 and tested in accordance with the methodology provided 6.6.7.c.2-) byASTHD38031989, at a temperature of 30*C' and a relative humidity nf 95% . meets the acceptance criteria of < 5.0% penetration of methyl iodide. i p (d At least once per - V $9 Verifying that e drop across the ceabined HEPA filters and charcoa adsorber banks is s 5.!5 inches Water b NJ^ Gauge while operating the filter train at t. flow rate of 2000 cfm i 10%.
- 2. Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically Giverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system.
3 that on a chlorine detector test signal, the
%W I" \ /
Verifyinbuilding ventilation system automatically isolates control and the control room emergency filtration system cannot be
/ started by a smoke detector or control room ventilation l system high radiation test signal.
- 4. Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system operation.
- Laboratory testing within the temperature and humidity tolerances rovided in Table 1 of ASTM 03803-1989 constitutes compliance with 6* 6.7.C. 2.) ' [ surveillance Requirements 4.7.2.b.2 and 4.7.2.c.
b [] q) BRUNSWICK - UNIT 2 3/4 7-4 Amendment No. F$c TH5803 T.y. 33 d 3r
i i cN t a.M cru b. b ra. Ati at<. wim. 4, Laio 2.s Amn [Cb.5.4. t J..a t;as L 5. .t A1 8,. n i f. . - Af ' .r., y3 , g o ADMINISTRATIVE COU R0LS M #' " '" * ' I'"# Tsc % 603 g6 5 CORE OPERATING LIMITS REPORT (Continued)
/ noci t E t. . s. . . z @.
The MINIMUM CRITICAL POWER RATIO (MCPR) for Specifications 3.2.2$ (30W3%2 D J.m (c,.6.4.4 @ The/bdflockfonitor/pscal se poirp)nd,dlowableMlug for Specification Q wu mg
- 9. 6.a and shall~be documented in the CORE OPERATING LIMITS REPORT.
The analytical methods used to determine the core operating limits gg,g,g s la be those previously reviewed and approved by the NRC. specifically those describN n the following documents. sitDE-24011-P-A. " General Electric Standard Application for Reactor SL 5 b*i @ Fuel" (latest approved version).
. ' The Ha 18. 1984 and ober 22. 1984 NRC Safety Evaluation Repo s for the Brun ick Reload Het logies described in:
/A4J r'
\; M M 801 Topical R Steady-S rt NF-1583.01.
e Analysis Me Description and alidation of s for 80111ng W er Reactors." , Februar 1983.
/ ALP
( f 4 2.- Top al Report NF-1 .02. "Hethods o ECORD." February k .1, L .3,
..J b.9 3. Topical Report F-1583.03. "Heth s of PREST 0-B."
February 198
- 4. Topical R rt NF-1583.04 ccification of L Reference BWR The -Hydraulic Methods Using the FI Code." May 1983. -
f(,.6.ta .6 g The NRC Safety Evaluation for Brunswick Unit 1 Amendment No.
,,,._.3 b
6(,.6.c Qp_._EJ The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal-mechanical limits. core thermal-hydraulic limits. ECCS limits, nuclear limits such as shutdown margin, transient analysis limits. and accident analysis limits) of the safety analysis are met.
>3 g,j 6orThe CORE OPERATING LIMITS REPORT. including any midhycle revisions supplements shall be orovided. uoon issuance for each reload cycle. to the NR 'ument C esifent Insp&oritrol tor f Opsk with, copies todhe Regidnal Administrator 3.
b b BRUNSWICK - UNIT 1 6-23 Amendment No. 'T.5C 'l775810 L pp le.- t h c ~7 f Ib
F
.. ,- ,.w<., .g.
.. ., s m, .. _. .m.;s,. s o. -
4.r, , 6>.. d y., y ,. g ,2}}