Text

Application to Revise Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process. Part 2 of 6
	ML15175A441
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, McGuire
Issue date:	06/24/2015
From:	; Duke Energy Carolinas
To:	; Office of New Reactors
Shared Package
ML15175A438	List: ML15175A439; ML15175A442; ML15175A445; ML15175A447; ML15175A448; RA-15-0006, Application to Revise Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process. Part 2 of 6;
References
	RA-15-0006
	Download: ML15175A441 (50)
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{{#Wiki_filter:RCS Loops - MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.7.1 Verify one RHR loop is in operation. SR 3.4.7.2 Verify SG secondary side water level is ~ 12% narrow range in required SGs. SR 3.4.7.3 Verify correct breaker alignment and indicated power are available to the required RHR pump that is not in operation. SR.. 3. 4.1.4-V e;, {7" ref~'r-t J R.-1-/F-lo.:Jf loc... ~* ~J r:lJ' sus c.~f+.!,(e... ---4... 1~~.s "!CC-uwtul c.+ u;l1./ t:u*c....Su tf--iC.:t fAt"l/ + ,-1/~J w*,+~ Wtt frr. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program .LA II CC Ord.rf"' c..<....___ /41-+L~ .Sv,.. \\r~,~ ""'u-1-r~J "' ~/lc y c..,.,,+r!J' P /'C) J '""/)1, McGuire Units 1 and 2 3.4.7-3 Amendment Nos. ~ 1

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR loops inoperable. 8.1 Suspend operations that Immediately No RHR loop in operation. SURVEILLANCE REQUIREMENTS would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1. B.2 Initiate action to restore one RHR loop to OPERABLE status and operation. SURVEILLANCE SA 3.4.8.1 Verify one RHR loop is in operation. SA 3.4.8.2 Verify correct breaker alignment and indicated power are available to the required RHR pump that is not in operation. Vf r*, 7 R-Htt. lo"f I~ C-Gt --1-wn.s..su.. u~~_r~*'b le ~ J e, J et ~c. *h'w v f 1:4 +, c>,.,_, a rc. S v.f./-1 c., 1 ~,., f / '1 .fdf~d (,V *.fk., w.:.-1-tr. Immediately FREQUENCY In accordance with the Surveillance Frequency Control Pro ram In accordance with the Surveillance Frequency Control Program WIR -/(.._._ S v~"ve~ f( t:t/ICA..-- 1-r~ 1 v ~t? cy G,,trrJI p,_c:)r-RIIJ't/ McGuire Units 1 and 2 3.4.8-2 Amendment Nos. ~41

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.2.1 Verify the following valves are in the listed position with power to the valve operator removed. Number Position Function NI162A Open Sl Cold Leg Injection NI121A Closed Sl Hot Leg Injection NI152B Closed Sl Hot Leg Injection Nl1838 Closed RHR Hot Leg Injection NI173A Open RHR Cold Leg Injection Nl1788 Open RHR Cold Leg Injection NI100B Open Sl Pump RWST Suction FW27A Open RHRIRWST Suction NI147A Open SIPump Mini-Flow / SR 3.5.2.2 ~Verify each ECCS 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. - NOTE - [\\.)of-r-e.J v;,..( J. -J.o k ~+- Hr ~~~~~ \\r('/IT t/ <JW fA +it,s. of-<1-1~ J v /1 J<r-o d !Y1,;, ~.s r A+ 1 "v e.... c....,vrrr-d I

ECCS-Operating 3.5.2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

McGuire Units 1 and 2 3.5.2-2 Amendment Nos.~

Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION A. One containment spray A.1 Restore containment spray train inoperable. train to OPERABLE status. B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. AND 8.2 Be in MODE 5. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.6.1 erify each containment spray manual and power operated valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position. LIFI\\-.-r--, f'J'-' I CJ, - N vi- (1!.../t/lrG-J....fo h..L ~+..ft:. r St.i..f..rh1/ r"V1+ --FlcJw 1~>,+-ir.s. of"'"'~ c:L vii d...er ..,.J.WitV71.S'i-rc*-h~ tA:M+ro I, COMPLETION TIME 72 hours 6 hours 84 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued) McGuire Units 1 and 2 3.6.6-1 Amendment Nos.~

Containment Spray System .$ V,L-Vt'l-LAAlLf Uf:JVI ftEA E,JTJ. l.o 111-l, rr v-eJ SURVEILLANCE SR 3.6.6.2 Verify each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head. SR 3.6.6.3 Not Used SR 3.6.6.4 Not Used SR 3.6.6.5 Verify that each spray pump is de-energized and prevented from starting upon receipt of a terminate signal and is allowed to manually start upon receipt of a start permissive from the Containment Pressure Control System (CPCS). SR 3.6.6.6 Verify that each spray pump discharge valve closes or is prevented from opening upon receipt of a terminate signal and is allowed to manually open upon receipt of a start permissive from the Containment Pressure Control System (CPCS). SR 3.6.6.7 Verify each spray nozzle is unobstructed. S 1?- 3, ~ . ~ -8 V (~,.{.1 ~in r'V\\.df s fre. y I cJc,;f; o_t4..S. ..su.sc~rf~:l-c_ +o J;t;'

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II~ J w.ftv w~~'h-r, 3.6.6 FREQUENCY In accordance with the lnservice Testing Program Not Used Not Used In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Following activities which could result in nozzle blockage I VI A Uor.JaifC..C u,of-"'-' ~ -S vr v.e, /I If 11 (...f..- FI"CJ~c."( ~'1ru ( Pr'(J""',...,_ McGuire Units 1 and 2 3.6.6-2 Amendment Nos.. ~~

AHA and Coolant Circulation-High Water Level 3.9.5 CONDITION REQUIRED ACTION COMPLETION TIME A. (continued} A.4 Close all containment 4 hours penetrations providing direct access from containment atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SURVEILLANCE SA 3.9.5.1 Verify one AHA loop is in operation and circulating reactor coolant at a flow rate of ;::: 1 000 gpm and RCS temperature is~ 140°F. S ft. 3/L 5*,z... V ~ ~; 17 reJ'.J,,c J P-4-L l oof loc~+ron~ s vs.celf,-~f': ~ J~J ~cc..vM vL~+to.IV ~ f(. St.J 1f-t C. I t>llf-{ f +) ll't'd WI~ /.VA -If('. FREQUENCY In accordance with the Surveillance Frequency Control Program r(l WI~ -ft.._._ 5 ur v-e*, 1/ P/1'--- ~rf!-J t.r<< c '7 Lcm--fr.Jl p n:r-Q ~ McGuire Units 1 and 2 3.9.5-2 Amendment No. ~

RHR and Coolant Circulation-Low Water Level 3.9.6 CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.2 Initiate action to restore Immediately one RHR loop to operation. 8.3 Close all containment 4 hours penetrations providing direct access from containment atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.6.1 Verify one RHR loop is in operation and circulating reactor coolant at a flow rate of ;::::: 1 000 gpm and RCS temperature is ~ 140°F. SR 3.9.6.2 Verify correct breaker alignment and indicated power available to the required RHR pump that is not in operation. ~p_ j. 9. ~-3 V-cr-1,_,.t.J-t~ I oor.lcc..c,-i-I0£1-S S vs G~,-~- 1 bfe. fo J.:r..s ~cc~;vtvl.. +to~ arc. s..;/-f-ic;-1',.,+/7 +; [ { -t J vv, ft._, 141.-. --/-e r, FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program W l f£...__.~ v r"' c ; /1 ~ "' c....e.- .--;-re.7 (,)(VIC f L.o"'+rtJ[ Pr'j/'eri'I'V McGuire Units 1 and 2 3.9.6-2 Amendment No.~

ACTIONS (continued) CONDITION REQUIRED ACTION B. Two required loops 8.1 Suspend all operations inoperable. involving a reduction in RCS boron OR concentration. Required loop not in AND operation. B.2 Initiate action to restore one loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SR 3.4.6.1 SR 3.4.6.2 SURVEILLANCE Verify required DHR or RCS loop is in operation. Verify correct breaker alignment and indicated power available to the required pump that is not in operation. t'-.JcJW - ('J o+ ~-~ 7 v ;',_ e d..J.o b.- p*u*.f..o ~'fV'-l J u,-/-i l i"2-itot.H.S erf..f.Tr -e,+c,~ MD Dt 4-, RCS Loops - MODE 4 3.4.6 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Ve/.',{'1 r--e]t..J*,r~ c! DJ.Ifi. loor Lll t:tcwrd~lft:.<. l 0 c..-~+1 ~VI-{ _.SV.!.C ~ r-1/b f-c ~.J a.s ~,-#,_ ~ Svrv-~*, /ltJI"1t...J.- 4lCV/)II...d,.. +,orv al'c.. SoJfFtt:...trll-1:./7 rre.JU*Mc1 Co~tirol +;Jir:J t-1/1111 we,fer, fr-e> r&lft'L.- --~,.-..--~ OCONEE UNITS 1, 2, &3 3.4.6-2 Amendment Nos.~73

RCS Loops-MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SA 3.4.7.1 SA 3.4.7.2 SR 3.4.7.3 SURVEILLANCE Verify required DHR loop is in operation. Verify required SG secondary side water levels are ;;:: 50%. Verify correct breaker alignment and indicated power available to the required DHR pump that is not in operation. SP.. 3.4.7.4-Ve;:.17 r-eJv'~ J DHA... loof I o4t-f/v"'..S.S ~sc. 'f: p-f.;b {e_ 4v J 4 1 a~vMv lc.+'"IV eti'-L.5 vff,"£..,~-1// {-tl{ l J w,fh t..v~**l-~ r, FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program I// q cc.""' cl~"'" w;fL,.. ~ .S.vrv-e; /l.,llc_.e_ Frr Jl.)<ll c'( ~ft<J) froj r.,I'VV' OCONEE UNITS 1, 2, & 3 3.4.7-3 Amendment Nos.~ I

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS {continued) CONDITION REQUIRED ACTION B. Two DHR loops 8.1 Suspend all operations inoperable. involving reduction in RCS boron OR concentration. Required DHR loop not AND in operation. 8.2 Initiate action to restore one DHR loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SA 3.4.8.1 SA 3.4.8.2 SURVEILLANCE Verify required DHR loop is in operation. Verify correct breaker alignment and indicated power available to the required DHR pump that is not in operation. Ve,.:, I, DHP.... loaf l o e-.,+ r~IU Su.!Je-e.p--1-;~:~ -4 J~tJ etC.CvM~ l.. -/-t~1 etl't-Svf/-iC-1-ft'ltl(.f,*JI'fJ w,f iv W ~t.-1-tr~ COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program ]: "' of c '- CJ" r::lq/7 t.A.- w;fc,. -tt........ .S VI'\\/'<',if o11111~ J-~ 1 v e,"t '( t-c:v,-fr..J J Projr4,h\\/ OCONEE UNITS 1 I 2, & 3 3.4.8-2 Amendment Nos.~ I

ACTIONS (continued) F. G. H. CONDITION One LPI-HPI flow path inoperable. Required Action and associated Completion Time of Condition B, C, D, E, or F not met. Two HPI trains inoperable. Two LPI-HPI flow paths inoperable. F.1 G.1 AND G.2 H.1 REQUIRED ACTION Restore LPI-HPI flow path to OPERABLE status. Be in MODE3. Reduce RCS temperature to ~ 350°F. Enter LCO 3.0.3. HPI 3.5.2 COMPLETION TIME 72 hours 12 hours 60 hours Immediately

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SURVEILLANCE REQUIREMENTS ~ SR 3.5.2.1 SR 3.5.2.2 SURVEILLANCE FREQUENCY Verify each HPI manual and non-automatic power operated valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program ( ~..;;::~_v_t __ ch_H_P_I p_u_m_p_c_a_s_in_g_. ____ In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.5.2-4 Amendment Nos.~ I

ACTIONS (continued) CONDITION

c.

Required Action and associated Completion Time of Condition A or B not met. REQUIRED ACTION C.1 Be in MODE 3. AND C.2 Be in MODE4. LPI 3.5.3 COMPLETION TIME 12 hours 60 hours D. One required LPI train D.1 inoperable in MODE 4. Initiate action to restore Immediately required LPI train to OPERABLE status. AND D.2

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

Only required if DHR loop is OPERABLE. Be in MODE 5. 24 hours r--- --.- -- "-' 0 -,-c - - -- -

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.L - SURVEILLANCE SR 3.5.3.1 "" Verify each LPI manual and non-automatic power operated valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. FREQUENCY In accordance with the Surveillance Frequency Control Program ( contrnued) OCONEE UNITS 1, 2, & 3 3.5.3-2 Amendment Nos.~ I

SA 3.5.3.2 SR 3.5.3.3 SR 3.5.3.4 SA 3.5.3.5 SR 3.5.3.6 SURVEILLANCE Verify each LPI pump's developed head at the test flow point is greater than or equal to the required developed head. Verify each LPI automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. Verify each LPI pump starts automatically on an actual or simulated actuation signal. Verify, by visual inspection, each LPI train reactor building sump suction inlet is not restricted by debris and suction inlet strainers show no evidence of structural distress or abnormal corrosion. V e ;,f7 L PI: I oc.."~+(r) ti/.S St..J.Ju1 ..f,il~ FREQUENCY LPI 3.5.3 In accordance with the Surveillance Frequency Control Program In accordance with the I nservice Testing Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program ~.J4i.t 4Cc.v,+rl.;lA..f..t~d!V ~rc...- Sv-!f l;_, ~"' f/7 f,'l/-cJ w1k t;V"'-hr, OCONEE UNITS 1, 2, & 3 3.5.3-3 Amendment Nos. ~

Reactor Building Spray and Cooling Systems 3.6.5 SURVEILLANCE REQUIREMENTS SR 3.6.5.1 SR 3.6.5.2 SR 3.6.5.3 SR 3.6.5.4 SURVEILLANCE -/ Verify each reactor building spray and cooling manual and non-automatic power operated valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position. Operate each required reactor building cooling train fan unit for ~ 15 minutes. Verify each required reactor building spray pump's developed head at the flow test point is greater than or equal to the required developed head. Verify that the containment heat removal capability is sufficient to maintain post accident conditions within design limits. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the lnservice Testing Program In accordance with the Surveillance Frequency Control Program (continued) t..:Jo~- _..,... __ _ t0 o+ f' e i v ;,e J, -f..o 4z..e.. 14-\\.e. ~ -hr rc,,. e..fvr !? v; I ef, ~ Sf,.,. 1 srs+~IYV V~/IT -FLow t~+ll.! Of-lr1 e J_ V /1 cl.cr A.JM t~ ;.s"f-,-, f,,;.'-" l..-t:JI'1frcJ I, OCONEE UNITS 1, 2, & 3 3.6.5-4

SR 3.6.5.5 SR 3.6.5.6 SR 3.6.5.7 SR 3.6.5.8 Reactor Building Spray and Cooling Systems 3.6.5 Verify each automatic reactor building spray and cooling valve in each required flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. Verify each required reactor building spray pump starts automatically on an actual or simulated actuation signal. Verify each required reactor building cooling train starts automatically on an actual or simulated actuation signal. Verify each spray nozzle is unobstructed. v-e;,{.7 rC<<c...f.or ~ui/J,~ !lf/"#41 lo""f,"rMs. St.J.Sc..'l'"'-'bfe... io J"..S t~tCC.VMV J1ftfJ/V fllr-c...S v /{:,~1 ~1'1+/'( -f:, /{ c J. w ;-n, W#l t~r. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program I;, "'<.ccVc14,.., ~ 441 ~ fL ~ .5vr-v~i /l,n'-4.- FI'"eJv~"' cr c_o,.,1ro f fll'"oJ r.. wv OCONEE UNITS 1, 2, & 3 3.6.5-5 Amendment Nos.~ I

DHR and Coolant Circulation-High Water Level 3.9.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued} A.4 Close all containment 4 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE penetrations providing direct access from containment atmosphere to outside atmosphere. SA 3.9.4.1 Verify one DHR loop is in operation. .s~ 3~9-4.2.. Vef'fr "eJ~u-e.J J)Ji,t_ loop Jo~-ho"-.5 ~\\JJ'-~/+,'b/e- ~ -J"'J "'-c.t-UhT u le-+1 C}/V arc S v.fl/c..i rl'l-(;/f f/J/<:J Wt.ff-WA-1-c.r, FREQUENCY In accordance with the Surveillance Frequency Control Program r..-, " C 0.,. J Pfl'l t.e 1..111 +1._ ~ s vrvet*ll~/1~ F/' e J Vf'/1C( G 11-lru { p,"j I'~~ OCONEE UNITS 1, 2, & 3 3.9.4-2 Amendment Nos. -~ I

ACTIONS DHR and Coolant Circulation-Low Water Level 3.9.5 CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.3 Close all containment 4 hours penetrations providing direct access from containment atmosphere to outside atmosphere. SURVEILLANCE REQUIREMENTS SR 3.9.5.1 SR 3.9.5.2 SURVEILLANCE Verify one DHR loop is in operation. Verify correct breaker alignment and indicated power available to the required DHR pump that is not in operation. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program v~~~-~~~~~~~ SR.. 3/J..S_ 3 Ve;,..£'( vi1-!L loof low.-h.o./1-s .L/1 01 cc.or-d&t"7U/ .Sv..sc.~f-Ftble... o J4..S ~cLu;ll(vlc,+t,M.. l#*tk. it-t...5urv;1/la/?c.e-are-.Sv+f.l'c:..;VI-f{l -(:..;1/~J.. {::,rc.lv-erJc( Cv/r+ro { £.{),fh W a-k r-, p roJrcY ~ OCONEE UNITS 1, 2, & 3 3.9.5-2 Amendment Nos.~ I RA-15-0006 Proposed Technical Specification Bases Changes (Mark-up) (For Information Only)

BASES LCO (continued) APPLICABILITY RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. ote 1 permits bot requ1re RHR shutdown cooling subsystems and recirculation pumps to be removed from operation for a cumulative period of 2 hours in an 8 hour period. Note 2 allows one required RHR shutdown cooling subsystem to be inoperable for up to 2 hours for the performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation may be low enough and the heatup rate slow enough to allow changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy. In MODE 3 with reactor steam dome pressure below the RHR shutdown cooling isolation pressure (i.e., the actual pressure at which the isolation trip resets) the RHR System must be OPERABLE and shall be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature. Otherwise, a recirculation pump is required to be in operation. In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR shutdown cooling isolation pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the RHR System suction piping. Decay heat removal at reactor pressures greater than or equal to the RHR shutdown cooling isolation pressure is typically accomplished by (continued) 111~ V'~e M.Utf-c.L jt~S vo tcL.s iS 1~ por+c,/1+ -/.v S4vt-JowV\\. ~o /,~ S I s-1-tM-- oPt=!<.ABtL.i 1Y, Brunswick Unit 1 B 3.4.7-2 Revision No. 31 I

BASES (continued) RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 SURVEILLANCE SR 3.4.7.1 REQUIREMENTS REFERENCES Brunswick Unit 1 This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room. This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after the pressure setpoint that isolates the shutdown cooling mode of the RHR System is reset, or for placing a recirculation pump in operation. The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability. 1. 10 CFR 50.36(c)(2)(ii). .BaJJJ SJ._.3. 4~7 ~ ?. ( ~*ffa. cL d ) B 3.4.7-5 Revision No. 41

Brunswick Unit 1 INSERT Bases SR 3.4.7.2 SR 3.4.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. Gas accumulation in the RHR shutdown cooling (SOC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SOC in service. Since the non-safety shutdown cooling mode of RHR is manually initiated at a low reactor pressure, sufficient time is available to ensure fill and warm-up of the flow path have been performed prior to starting an RHR pump, thereby avoiding any unacceptable pressure transients on the system. RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. This SR is modified by a Note that states the SR is not required to be performed until 12 hours after reactor steam dome pressure is less than the RHR shutdown cooling isolation pressure. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

BASES LCO (continued) APPLICABILITY RHR Shutdown Cooling System-Cold Shutdown B 3.4.8 exchanger and common discharge piping. Thus, to meet the LCO, both pumps in one loop or one pump in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. In MODE 4, the RHR cross tie valve may be opened to allow pumps in one RHR loop to discharge through the opposite RHR and recirculation loops to make a complete subsystem. Additionally, each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. Note 1 permits both required RHR shutdown cooling subsystems and recirculation pumps to be removed from operation for a cumulative period of 2 hours in an 8 hour period. Note 2 allows one required RHR shutdown cooling subsystem to be inoperable for up to 2 hours for the performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation may be low enough and the heatup rate slow enough to allow changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy. In MODE 4, the RHR Shutdown Cooling System may be operated in the shutdown cooling mode to remove decay heat to maintain coolant temperature below 212°F. Otherwise, a recirculation pump is required to be in operation. In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR shutdown cooling isolation pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the RHR System suction piping. Decay heat removal at reactor pressures greater than or equal to the RHR shutdown cooling isolation pressure is typically accomplished by (continued) \\1' 0 ; d.5 I J. I /J/1 f 0 r+A /1 +..f.o P-1-1 fl._ OPE".A-It!../ LIT'-/. Brunswick Unit 1 B 3.4.8-2 Revision No. 31 I

BASES (continued) RHR Shutdown Cooling System-Cold Shutdown B 3.4.8 SURVEILLANCE SR 3.4.8.1 REQUIREMENTS REFERENCES Brunswick Unit 1 This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

1.

10 CFR 50.36(c)(2)(ii). B 3.4.8-5 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SR 3.4.8.2 SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. Gas accumulation in the RHR shutdown cooling (SOC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SOC in service. Since the non-safety shutdown cooling mode of RHR is manually initiated at a low reactor pressure, sufficient time is available to ensure fill and warm-up of the flow path have been performed prior to starting an RHR pump, thereby avoiding any unacceptable pressure transients on the system. RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

BASES LCO APPLICABILITY ECCS-Operating B 3.5.1 Each ECCS injection/spray subsystem and six of seven ADS valves are required to be OPERABLE. The ECCS injection/spray subsystems are defined as the two CS subsystems, the two LPCI subsystems, and one HPCI System. The low pressure ECCS injection/spray subsystems are defined as the two CS subsystems and the two LPCI subsystems. With less than the required number of ECCS subsystems OPERABLE, the potential exists that during a limiting design basis LOCA concurrent with the worst case single failure, the limits specified in Reference 9 could be exceeded. All ECCS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 9. LPCI subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the actual RHR shutdown cooling isolation pressure in MODE 3, if they are 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 realigned to or from the RHR shutdown cooling mode. At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary. All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is s; 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS-Shutdown." (continued) .M., /'1 :J e M -fA+ a-T-J 4 s v o *, d.s. 1-.1 1 :,_, f o r+c. VI f- -/v t:-C(;..$ ,/Jjec+~ot'L-/.sfrCff.sJ1.s1 ..s--~-tNV DPt!-.ABILI TY~ Brunswick Unit 1 B 3.5.1-5 Revision No. 58 I

BASES ECCS-Operating B 3.5.1 ACTIONS .4..1 (continued) When multiple ECCS subsystems are inoperable, as stated in Condition J, the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE ~S~R~3~.5~.1~.1~~~~~~~~~~~~~~~~~~~~ REQUIREMENTS r _ The flow path piping of each ECCS has the potential to develop voids and-pockets of entrained air. Maintaining the pump discharge lines gfjf:l~ HPCI System, CS subsystems, and LPCI subsystems fu Wafer __....,r::~ ensures that the ECCS will perform properly, in* 1ts full capacity into Brunswick Unit 1 the RCS upon demand. This SR also s water hammer in the piping following an ECCS initia

gnal. One acceptable method of ensuring that the lines I is to vent at the high points. The 31 day Frequency is on the gradual nature of void buildup in the ECCS pipin procedural controls governing system operation, and operating erience.

SR 3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these are verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition to the accident position in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification 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. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position. (continued) B 3.5.1-10 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SR 3.5.1.1 The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The 92 day Frequency is based on the gradual nature of void buildup in the ECCS injection/spray subsystem piping, the procedural controls governing system operation, and operating experience.

BASES ECCS-Operating B 3.5.1 SURVEILLANCE SR 3.5.1.2 (continued) REQUIREMENTS Brunswick Unit 1 The 31 day Frequency of this SR was derived from the lnservice Testing Program requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position typically only affects a single subsystem. This Frequency has been shown to be acceptable through operating experience. In MODE 3 with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure, 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 LPCI subsystems to be considered OPERABLE during alignment and operation for decay heat removal, if 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 realigned to or from the RHR shutdown cooling mode. At low reactor pressure and with a low decay heat load associated with operation in MODE 3 with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure, a reduced complement of low pressure ECCS subsystems should provide the required core cooling in the unlikely event of a LOCA, thereby, allowing operation of the shutdown cooling mode of the RHR System, when necessary. SR 3.5.1.3 Verification every 31 days that ADS pneumatic supply header pressure is ~ 95 psig ensures adequate pneumatic pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least three valve actuations can occur with the drywell at 70% of design pressure. The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of~ 95 psig is provided by the non-interruptible Reactor (continued) B 3.5.1-11 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SR 3.5.1.2 The Surveillance is modified by a second Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

ECCS-Shutdown B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 ECCS-Shutdown BASES BACKGROUND A description of the Core Spray (CS) System and the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System is provided in the Bases for LCO 3.5.1, "ECCS-Operating." APPLICABLE The ECCS performance is evaluated for the entire spectrum of break SAFETY ANALYSES sizes for a postulated loss of coolant accident (LOCA). The long term cooling analysis following a design basis LOCA (Ref. 1) demonstrates that only one low pressure ECCS injection/spray subsystem is required, post LOCA, to maintain adequate reactor vessel water level in the event of an inadvertent vessel draindown. It is reasonable to assume, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level. To provide redundancy, a minimum of two low pressure ECCS injection/spray subsystems are required to be OPERABLE in MODES 4 and 5. LCO The low pressure ECCS subsystems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 2). Two low pressure ECCS injection/spray subsystems are required to be OPERABLE. A low pressure ECCS injection/spray subsystem consists of a CS subsystem or a LPCI subsystem. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the reactor pressure vessel (RPV). Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. The necessary portions of the Service Water System are required to provide appropriate cooling to the required low pressure ECCS injection/spray subsystems. Only a single LPCI pump is required per LPCI subsystem because of the larger injection capacity in relation to a CS subsystem. In MODES 4 and 5, the RHR System cross tie valve is not required to be close~ (continued) ~----~--~--~------------------------------------~ /lll.:t ""'] ~ M.V\\+ a..J jlf.s vo 1 d-s 1-J '~for-f.-~/1 f -fo E. CL.S J"Aj ~c ftM-/.sf~'#' 7.sJ!,s ys-k~ 0 pr; )-A!J ; L 11"1, Brunswick Unit 1 B 3.5.2-1 Revision No. 31 I

BASES ECCS-Shutdown B 3.5.2 SURVEILLANCE SR 3.5.2.4 (continued) REQUIREMENTS REFERENCES Brunswick Unit 1 to be in a nonaccident position provided the valve will automatically reposition to the accident position in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification 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 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 system is being 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 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 occur.

1.

2.

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. 10 CFR 50.36(c)(2)(ii). B 3.5.2-6 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SA 3.5.2.4 The Surveillance is modified by a second Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

BASES BACKGROUND (continued) RCIC System B 3.5.3 The RCIC pump is provided with a minimum flow bypass line, which discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is maintained full of water using a "keep fill" system. APPLICABLE The function of the RCIC System is to respond to transient events by SAFETY ANALYSES providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the system satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 3) and is therefore included in the Technical Specifications. LCO APPLICABILITY ACTIONS Brunswick Unit 1 The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for i tainin RPV- ~nventory during an isolation event ~'lo:A '" "'j~~-r, j "'..1 vc' -' 14 lhf ur+~V\\ ~ fl. CIC. s,.s-1-,~ OI'G"J.../rBIL t T Y~ The RCI System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure $150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV. A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is verified immediately to be OPERABLE, the RCIC System must be restored to (continued) B 3.5.3-2 Revision No. 41

BASES (continued) RCIC System B 3.5.3 SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The flow path piping has the potential to develop voids and po of entrained air. Maintaining the pump discharge line of IC System full of water ensures that the system will perfo operly, injecting its full

"171 capacity into the reactor vessel upon nd. This SR will also prevent Brunswick Unit 1 water hammer in the piping ~

mg an initiation signal. One acceptable method of ensuring t

e is full is to vent at the high points. The 31 day Frequency is ea on the gradual nature of void buildup in the RCIC Syst ping, the procedural controls governing system operation, and er tin experience.

SR 3.5.3.2 Verifying the correct alignment for manual, power operated, and automatic valves in the RCIC flow path provides assurance that the proper flow path exists for RCIC System 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 receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition to the accident position in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification 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. This SR also includes the steam flow path for the turbine and the flow controller position. The 31 day Frequency of this SR was derived from the lnservice Testing Program requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position typically affects only the RCIC System. This Frequency has been shown to be acceptable through operating experience. B 3.5.3-4 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SR 3.5.3.1 The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RCIC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RCIC System locations susceptible to gas accumulation is based on a self-assessment of the piping configuration to identify where gases may accumulate and remain even after the system is filled and vented, and to identify vulnerable potential degassing flow paths. The review is supplemented by verification that installed high-point vents are actually at the system high points, including field verification to ensure pipe shapes and construction tolerances have not inadvertently created additional high points. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The RCIC System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RCIC Systems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The 92 day Frequency is based on the gradual nature of void buildup in the RCIC piping, the procedural controls governing system operation, and operating experience.

Brunswick Unit 1 INSERT Bases SR 3.5.3.2 The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

BASES (continued) RHR Suppression Pool Cooling B 3.6.2.3 APPLICABLE References 1 and 2 contain the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break LOCAs. The intent of the analyses is to demonstrate that the heat removal capacity of the RHR Suppression Pool Cooling System is adequate to maintain the primary containment conditions within design limits. The suppression pool temperature is calculated to remain below the design limit. LCO APPLICABILITY ACTIONS Brunswick Unit 1 The RHR Suppression Pool Cooling System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii) (Ref. 3). During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Refs. 1 and 2). To ensure that these requirements are met, two independent RHR suppression pool cooling subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool cooling subsystem is OPERABLE when two pumps, the heat exchanger, and associated i in

_.m ntation, and controls are OPERABLE.M~t"'"J"'..,.,~-t Ja.i VolJ-' /l. IM(JO~ :.{b f..

Sulfrt.5, v~ col l.coi!.J SJ4+tM Ofc!U!>ILIT'I' In MODES 1, 2, and 3, a DBA could cause both a release of radioactive material to the primary containment and a heatup and pressurization of primary containment. 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, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE4 or5. A.1 With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period. (continued) B 3.6.2.3-2 Revision No. 41

BASES SURVEILLANCE REQUIREMENTS (continued) REFERENCES I N.St/CI Brunswick Unit 1 SR 3.6.2.3.2 RHR Suppression Pool Cooling B 3.6.2.3 Verifying that each RHR pump develops a flow rate;:: 7700 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment pressure and temperature can be maintained below the design limits during a DBA (Ref. 2). The normal test of centrifugal pump performance required by ASME OM Code (Ref. 4) is covered by the requirements of LCO 3.5.1, "EGGS-Operating." This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such tests confirm component OPERABILITY, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is 92 days.

1.

UFSAR, Section 6.2.1.1.3.2.

2.

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

3.

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

4.

ASME Code for Operation and Maintenance of Nuclear Power Plants. B 3.6.2.3-4 Revision No. 59

Brunswick Unit 1 INSERT Bases SR 3.6.2.3.3 SR 3.6.2.3.3 RHR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool cooling subsystems and may also prevent water hammer and pump cavitation. Selection of RHR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. RHR Suppression Pool Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The 92 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Suppression Pool Cooling System piping and the procedural controls governing system operation.

BASES LCO (continued) APPLICABILITY ACTIONS Brunswick Unit 1 RHR-High Water Level B 3.9.7 with respect to the corresponding specified water level above the RPV flange. Only one subsystem is required because the volume of water above the RPV flange provides backup decay heat removal capability. An OPERABLE RHR shutdown cooling subsystem consists of an RHR pump, a heat exchanger, one RHR Service Water Pump capable of providing cooling to the heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. In MODE 5, the RHR cross tie valve is not required to be closed; thus, the valve may be opened to allow pumps in one RHR loop to discharge through the opposite RHR and recirculation loops to make a complete subsystem. Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. A Note is provided to allow a 2 hour exception to shutdown the operating subsystem every 8 hours. One RHR shutdown cooling subsystem must be OPERABLE and in operation in MODE 5, with irradiated fuel in the reactor pressure vessel and with the water level ~ 21 feet 10 inches above the top of the RPV flange, to provide decay heat removal. RHR shutdown cooling subsystem requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS). RHR shutdown cooling subsystem requirements in MODE 5 with irradiated fuel in the RPV and with the water level < 21 feet 10 inches above the RPV flange are given in LCO 3.9.8, "Residual Heat Removal (RHR)-Low Water Level." A.1 With no RHR shutdown cooling subsystem OPERABLE, an alternate method of decay heat removal must be established within 1 hour. In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core. However, the overall reliability is reduced because loss of water level could result in

j *~jor~v-f --4 OPE t-k.D IL I -,-y' (continued)

M.f.ll:J'f/YW\\+ J J '{,S VC) I d~ s~~~+.Jo<>>vv Coo 1,-,j Srs"-r,., ~~~~~---------------------- B 3.9.7-2 Revision No. 31 I

BASES ACTIONS B.1. B.2. B.3. and B.4 (continued) RHR-High Water Level B 3.9.7 examining logs or other information to determine whether the components are out of service for maintenance or other reasons. It is not necessary to perform the Surveillances 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, a Surveillance may need to be performed to restore the component to OPERABLE status. Actions must continue until all required components are OPERABLE. C.1 and C.2 If no RHR shutdown cooling subsystem is in operation, an alternate method of coolant circulation is required to be established within 1 hour. The Completion Time is modified such that the 1 hour is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of reactor coolant circulation must be reconfirmed every 12 hours thereafter. This will ensure reactor coolant circulation is maintained. During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem), the reactor coolant temperature must be periodically monitored to ensure proper functioning of the alternate method. The once per hour Completion Time is deemed appropriate. SURVEILLANCE SR 3.9.7.1 REQUIREMENTS REFERENCES Brunswick Unit 1 This Surveillance demonstrates that the required RHR shutdown cooling subsystem is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR shutdown cooling subsystem in the control room.

1.

10 CFR 50.36(c)(2)(ii). B 3.9.7-4 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SR 3.9.7.2 SR 3.9.7.2 AHA Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required AHA shutdown cooling subsystem(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of AHA Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The AHA Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the AHA Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. Gas accumulation in the RHR shutdown cooling (SOC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SDC in service. Since the non-safety shutdown cooling mode of RHR is manually initiated at a low reactor pressure, sufficient time is available to ensure fill and warm-up of the flow path have been performed prior to starting an RHR pump, thereby avoiding any unacceptable pressure transients on the system. RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the AHA Shutdown Cooling System piping and the procedural controls governing system operation.

BASES LCO (continued) APPLICABILITY ACTIONS RHR-Low Water Level B 3.9.8 pumps in one loop or one RHR pump in each of the two loops must be OPERABLE. If the LCO is met using two RHR pumps in one loop, then two RHR Service Water pumps must be capable of providing cooling to the associated heat exchanger. In MODE 5, the RHR cross tie valve is not required to be closed; thus, the valve may be opened to allow pumps in one RHR loop to discharge through the opposite RHR and recirculation loops to make a complete subsystem. Additionally, each RH s ut own cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. A Note is provided to allow a 2 hour exception to shutdown the operating subsystem every 8 hours. Two RHR shutdown cooling subsystems are required to be OPERABLE, and one must be in operation in MODE 5, with irradiated fuel in the RPV and with the water level < 21 feet 10 inches above the top of the RPV flange, to provide decay heat removal. RHR shutdown cooling subsystem requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS). RHR shutdown cooling subsystem requirements in MODE 5 with irradiated fuel in the RPV and with the water level~ 21 feet 10 inches above the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR)-High Water Level." A.1 With one of the two required RHR shutdown cooling subsystems inoperable, the remaining subsystem is capable of providing the required decay heat removal. However, the overall reliability is reduced. Therefore, an alternate method of decay heat removal must be provided. With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, (continued) fV1;"0-t~-f- ~J Jer.I V~* Js iJ ,:V,/o~'"+l:f/1--f -f-D.LHJ-. S4v+dvwl'\\ Cvoi'~J.S T ~~ OPtP--AIJ ILl i V, Brunswick Unit 1 B 3.9.8-2 Revision No. 31 I

BASES ACTIONS B.1 I B.21 and B.3 (continued) RHR-Low Water Level B 3.9.8 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 until all required components are OPERABLE. Cl1 and C.2 If no RHR shutdown cooling subsystem is in operation, an alternate method of coolant circulation is required to be established within 1 hour. The Completion Time is modified such that the 1 hour is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of reactor coolant circulation must be reconfirmed every 12 hours thereafter. This will ensure reactor coolant circulation is maintained. During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem), the reactor coolant temperature must be periodically monitored to ensure proper functioning of the alternate method. The once per hour Completion Time is deemed appropriate. SURVEILLANCE SR 319.811 REQUIREMENTS REFERENCES Brunswick Unit 1 This Surveillance demonstrates that one RHR shutdown cooling subsystem is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR shutdown cooling subsystems in the control room. 1 I 10 CFR 50.36(c)(2)(ii). B 3.9.8-4 Revision No. 31 I

Brunswick Unit 1 INSERT Bases SA 3.9.8.2 SA 3.9.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. Gas accumulation in the RHR shutdown cooling (SOC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SOC in service. Since the non-safety shutdown cooling mode of RHR is manually initiated at a low reactor pressure, sufficient time is available to ensure fill and warm-up of the flow path have been performed prior to starting an RHR pump, thereby avoiding any unacceptable pressure transients on the system. RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

BASES LCO (continued) APPLICABILITY RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. Note 1 permits both required RHR shutdown cooling subsystems and recirculation pumps to be removed from operation for a cumulative period of 2 hours in an 8 hour period. Note 2 allows one required RHR shutdown cooling subsystem to be inoperable for up to 2 hours for the performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation may be low enough and the heatup rate slow enough to allow changes to the RHR subsystems or other operations requiring RHR flow interruption and loss ofredundancy. In MODE 3 with reactor steam dome pressure below the RHR shutdown cooling isolation pressure (i.e., the actual pressure at which the isolation trip resets) the RHR System must be OPERABLE and shall be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature. Otherwise, a recirculation pump is required to be in operation. In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR shutdown cooling isolation pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the RHR System suction piping. Decay heat removal at reactor pressures greater than or equal to the RHR shutdown cooling isolation pressure is typically accomplished by (continued) jiA d/1 'J eN~Pt+.-J-J <<4 vc>. Lr "' ,;,/~"+""'+ 1v ~t-Ift-s~J+r::!.uwrv C,?ol,r~j.s*1sh~ o!Ei-4-JtltT'(, Brunswick Unit 2 B 3.4.7-2 Revision No. 30 I

BASES (continued) RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 SURVEILLANCE SR 3.4.7.1 REQUIREMENTS REFERENCES Brunswick Unit 2 This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room. This Surveillance is modified by a Note allowing sufficient time to align the RHR System for shutdown cooling operation after the pressure setpoint that isolates the shutdown cooling mode of the RHR System is reset, or for placing a recirculation pump in operation. The Note takes exception to the requirements of the Surveillance being met (i.e., forced coolant circulation is not required for this initial 2 hour period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

1.

10 CFR 50.36(c)(2)(ii). B 3.4.7-5 Revision No. 39

Brunswick Unit 2 INSERT Bases SA 3.4.7.2 SA 3.4.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel. Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions. The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If the accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process. Gas accumulation in the RHR shutdown cooling (SDC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SDC in service. Since the non-safety shutdown cooling mode of RHR is manually initiated at a low reactor pressure, sufficient time is available to ensure fill and warm-up of the flow path have been performed prior to starting an RHR pump, thereby avoiding any unacceptable pressure transients on the system. RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. This SR is modified by a Note that states the SR is not required to be performed until 12 hours after reactor steam dome pressure is less than the RHR shutdown cooling isolation pressure. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System piping and the procedural controls governing system operation.

BASES LCO (continued) APPLICABILITY RHR Shutdown Cooling System-Cold Shutdown B 3.4.8 exchanger and common discharge piping. Thus, to meet the LCO, both pumps in one loop or one pump in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. In MODE 4, the RHR cross tie valve may be opened to allow pumps in one RHR loop to discharge through the opposite RHR and recirculation loops to make a complete subsystem. Additionally, each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required. To ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required. Note 1 permits both required RHR shutdown cooling subsystems and recirculation pumps to be removed from operation for a cumulative period of 2 hours in an 8 hour period. Note 2 allows one required RHR shutdown cooling subsystem to be inoperable for up to 2 hours for the performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation may be low enough and the heatup rate slow enough to allow changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy. In MODE 4, the RHR Shutdown Cooling System may be operated in the shutdown cooling mode to remove decay heat to maintain coolant temperature below 212°F. Otherwise, a recirculation pump is required to be in operation. In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR shutdown cooling isolation pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the RHR System suction piping. Decay heat removal at reactor pressures greater than or equal to the RHR shutdown cooling isolation pressure is typically accomplished by (continued) ,/U tf/l~tJ c~f-of-J Q._f Vdr'. d...r I~,;:,_,f'c! ~~~"'+ ~ F-J.fll s Ltuf-~vv Ce> ol, "j £ rs.~'YL Brunswick Unit 2 B 3.4.8-2 Revision No. 30

BASES (continued) RHR Shutdown Cooling System-Cold Shutdown B 3.4.8 SURVEILLANCE SR 3.4.8.1 REQUIREMENTS

t'?"

REFERENCES Brunswick Unit 2 This Surveillance verifies that one required RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

1.

10 CFR 50.36(c)(2)(ii). B 3.4.8-5 Revision No. 30 I}}

RA-15-0006, Application to Revise Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process. Part 2 of 6

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