RA-20-0165, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements

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Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements
ML20272A091
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 09/24/2020
From: Krakuszeski J
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0165
Download: ML20272A091 (83)
v • d • e


Text

el_-, DUKE

~ ENERGY John A. Krakuszeski Vice President Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 September 24, 2020 Serial: RA-20-0165 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324

Subject:

Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements" Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC (Duke Energy), is submitting a request for an amendment to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

Duke Energy requests adoption of TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." provides a description and assessment of the proposed changes. Enclosures 2 and 3 provide the existing TS pages marked-up to show the proposed changes for Units 1 and 2, respectively. Enclosures 4 and 5 provide revised (typed) TS pages for Units 1 and 2, respectively. Enclosure 6 provides Unit No. 1 TS Bases pages marked-up to show the proposed changes for information only.

Duke Energy requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by February 26, 2021. Once approved, the amendment shall be implemented within 120 days.

In accordance with 10 CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

This document contains no new regulatory commitments. Please refer any questions regarding this submittal to Mr. Art Zaremba, Director - Nuclear Fleet Licensing, at (980) 373-2062.

U.S. Nuclear Regulatory Commission Page 2 of 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September 24, 2020.

Sincerely, John A. Krakuszeski MAT/mat

Enclosures:

cc:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)- Unit 1
3. Proposed Technical Specification Changes (Mark-Up) - Unit 2
4. Revised Technical Specification Pages - Unit 1
5. Revised Technical Specification Pages - Unit 2
6. Proposed Technical Specification Bases Changes (Mark-Up)- Unit 1 (For Information Only)

Ms. Laura Dudes, Regional Administrator, Region II Mr. Andrew Hon, Project Manager Mr. Gale Smith, NRC Senior Resident Inspector Chair - North Carolina Utilities Commission Mr. W. Lee Cox, Ill Section Chief, Radiation Protection Section, NC DHHS

RA-20-0165 Page 1 of 7 Description and Assessment

1.0 DESCRIPTION

Duke Energy Progress, LLC (Duke Energy) requests adoption of TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Duke Energy has reviewed the safety evaluation for TSTF-582 provided to the Technical Specifications Task Force in a letter dated August 13, 2020. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. Duke Energy has concluded that the justifications presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to BSEP, Unit Nos. 1 and 2, and justify this amendment for the incorporation of the changes to the BSEP TS.

Duke Energy verifies that the required ECCS injection/spray subsystem can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (i.e., less than the minimum Drain Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) from the control room following plant procedures.

2.2 Optional Changes and Variations Duke Energy is proposing the following variations from the TS changes described in TSTF-582 or the applicable parts of the NRC staffs safety evaluation:

The BSEP TS use different numbering than the Standard Technical Specifications (STS) on which TSTF-582 was based. Specifically, the following differences exist.

These differences are administrative and do not affect the applicability of TSTF-582 to the BSEP TS.

RA-20-0165 Page 2 of 7 The BSEP TS requirements differ from the STS on which TSTF-582 was based but these differences do not affect the applicability of TSTF-582 justification to the BSEP TS. Specifically, the following differences exist.

As discussed in TSTF-582, BSEP does not have an Emergency Core Cooling System (ECCS) manual initiation signal. Crediting manual starting of pumps and manual valve alignment to permit the required ECCS injection/spray subsystem to inject into the Reactor Pressure Vessel (RPV) was approved as a variation to TSTF-542 (i.e. Amendments 283 and 311 for BSEP Units 1 and 2, respectively, issued on April 13, 2018 (ML18039A444)). Similarly, BSEP TS Table 3.3.5.3-1 does include Functions equivalent to STS Table 3.3.5.2-1 Function 1.b, "Core Spray Pump Discharge Flow - Low (Bypass)," and Function 2.b, "Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)." As a result of the above variations, requirements equivalent to STS TS 3.3.5.2, Condition D and SR 3.3.5.2.3 were not included in BSEP TS 3.3.5.3. Also, existing BSEP SR 3.5.2.8 is currently worded as proposed by TSTF-582. Each of these differences were approved as variations to TSTF-542 and do not impact the applicability of TSTF-582 to the BSEP TS.

TSTF-582, "RPV WIC Enhancements," states:

The ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense-in-depth against an unexpected draining event. The changes in TSTF-542 did not assume automatic actuation of the ECCS subsystem. TS 3.5.2, Required Action D.1 requires an additional method of water injection and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. However, LCO 3.5.2 does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal.

LCO 3.8.2, "AC Sources - Shutdown," requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5. SR 3.8.2.1 lists the TS 3.8.1, "AC Sources -

Operating," SRs that are applicable in Modes 4 and 5. In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were not excluded from SR 3.8.2.1.

TSTF-582 revises Technical Specification (TS) 3.8.2, "AC Sources - Shutdown," Surveillance Requirement (SR) 3.8.2.1, to exclude SRs that verify the ability of the diesel generators to automatically start and load on an ECCS initiation signal or loss of offsite power signal.

The NRC Safety Evaluation for TSTF-582 (ADAMS Accession No. ML20219A333, dated August 13, 2020), Section 3.6, "Alternating Current Sources - Shutdown, STS 3.8.2," states:

STS 3.5.2, "Reactor Pressure Vessel Water Inventory Control (RPV WIC)," does not require automatic ECCS initiation to mitigate a draining event in Modes 4 and 5, and the ECCS initiation signal related to the automatic ECCS initiation is removed from the STS.

RA-20-0165 Page 3 of 7 Because the automatic ECCS initiation and related ECCS initial signal in Modes 4 and 5 are eliminated, the automatic start of the DG on an ECCS initiation signal is not required in Modes 4 and 5. [T]he NRC staff finds that STS 3.5.2 provides enough time from the onset of the [loss of offsite power] LOOP event for the operator to manually start the DG required to supply power to the water injection equipment to mitigate the draining event in Modes 4 and 5. In addition, STS 3.5.2 does not require the automatic initiation of the ECCS injection/spray subsystem or the additional method of water injection. Therefore, since STS 3.5.2 allows enough time to manually start the DG and the equipment for water injection, the NRC staff finds that the automatic start and loading of the DG are not necessary on a LOOP signal or LOOP concurrent with an ECCS initiation signal to mitigate a draining event in Modes 4 and 5.

Furthermore, the NRC staff notes that other events postulated in Modes 4 and 5 (e.g.,

FHA, waste gas tank rupture) and during movement of [recently] irradiated fuel assemblies in the [primary and secondary containment] do not assume a LOOP event or an automatic ECCS initiation.

TSTF-582 did not include all of the TS changes needed to reflect that TS 3.8.2 should not require automatic start and loading of a diesel generator on an ECCS initiation signal or a loss of offsite power signal.

TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is applicable in Modes 1, 2, and 3, and when the associated diesel generator is required to be operable by TS 3.8.2. TSTF-582 revised TS 3.8.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal. Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the diesel generator is required to be operable by TS 3.8.2. The Applicability of LCO 3.3.8.1 is revised to not include the specified condition "When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources - Shutdown'."

BSEP SR 3.8.1.7 requires that the DG starts from standby condition and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions in the design basis LOCA analysis. This capability is not required during a manual diesel generator start to respond to a draining event, which has a minimum Drain Time of one hour. Therefore, SR 3.8.1.7 is added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

BSEP SR 3.8.1.13 (i.e., STS SR 3.8.1.18) states, "Verify interval between each sequenced load block is within +/- 10% of design interval for each load sequencer relay." TSTF-582 retained STS SR 3.8.1.18 as a test that must be met but not performed. The load sequencer relay logic schemes are only used for the automatic start and loading of the diesel generator and are not used during a manual diesel generator start. Therefore, SR 3.8.1.13 is added to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.

The TS 3.8.2 LCO Bases were not updated by TSTF-542 or TSTF-582 to reflect that automatic start and loading of a diesel generator is not required. The LCO 3.8.2 and SR 3.8.2.1 Bases are revised to reflect the TS requirements.

This variation provides consistency within the TS after incorporating the TSTF-582 changes to SR 3.8.2.1.

RA-20-0165 Page 4 of 7 As an editorial improvement, SR 3.8.2.1 is revised to list the TS 3.8.1 SRs that are applicable instead of listing the TS 3.8.1 SRs that are not applicable. The SR 3.8.2.1 Bases are not affected and explain why the omitted TS 3.8.1 SRs are not applicable to TS 3.8.2.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Duke Energy Progress, LLC (Duke Energy), requests adoption of TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

TSTF-582 includes the following changes to the Technical Specifications (TS):

1.

The TS are revised to eliminate permissive functions related to starting the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2.

The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

3.

The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are "locked, sealed, or otherwise secured" is revised to apply the exception for manual or automatic valves that are "closed and administratively controlled."

4.

The TS are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5.

A Surveillance Requirement (SR) that requires operating the required Emergency Core Cooling System (ECCS) injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

6.

TS 3.8.2, "AC Sources - Shutdown," SR 3.8.2.1, is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542. This was an oversight in TSTF-542.

7.

The Applicability of TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is revised to delete the phrase, "When associated instrumentation is required to be OPERABLE per LCO 3.8.2, "AC Sources - Shutdown." Since TSTF-582 revises TS 3.8.2 to no longer require automatic start and loading of a diesel generator on a loss of offsite power signal, the LOP instrumentation that generates the loss of offsite power signal is not required to be operable when the diesel generator is required to be operable by TS 3.8.2.

8.

The Applicability of TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," is revised to delete the phrase, "When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, 'Primary Containment Isolation Instrumentation'." This

RA-20-0165 Page 5 of 7 makes TS 3.6.1.3 only applicable in Modes 1, 2, and 3. Following adoption of TSTF-542, no functions in LCO 3.3.6.1 are applicable outside of Modes 1, 2, or 3.

The Actions and SRs are revised to reflect this change. These changes are made for clarity and have no effect on the application of the TS.

9.

The TS are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

Duke Energy has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." Draining of RPV water inventory in Mode 4 (i.e., cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Final Safety Analysis Report (UFSAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases that would have been considered a design basis accident in the UFSAR had it been previously identified.

RA-20-0165 Page 6 of 7 None of the equipment affected by the proposed change has a design function described in the UFSAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose. Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will effect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control."

The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3.

The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license. Therefore, the proposed change does not significantly reduce the margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Duke Energy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

RA-20-0165 Page 7 of 7

4.

ENVIRONMENTAL CONSIDERATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

RA-20-0165 Proposed Technical Specification Changes (Mark-Up) -

Unit 1

Definitions 1.1 Brunswick Unit 1 1.1-3 Amendment No. 283 1.1 Definitions DOSE EQUIVALENT I-131 Submersion, and Ingestion," 1989 and FGR 12, "External (continued)

Exposure to Radionuclides in Air, Water, and Soil," 1993.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 1 3.3-48a Amendment No. 283 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.3-1 for the channel.

Immediately AB. One or more channels inoperable.As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

A.1 Initiate action to place channel in trip.

OR A.2.1B.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2B.2 Initiate action to Ccalculate DRAIN TIME.

Immediately Immediately Immediately C.

As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 1 3.3-48b Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and associated Completion Time of Condition C not met.

D.1 Declare associated low pressure ECCS injection/spray subsystem inoperable.

Immediately SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.3-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 1 3.3-48c Amendment No. 283 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

1. Core Spray System
a. Reactor Steam Dome PressureLow 4, 5 4(a)

C SR 3.3.5.3.1 SR 3.3.5.3.2 425 psig

2. Low Pressure Coolant Injection (LPCI) System
a. Reactor Steam Dome PressureLow 4, 5 4(a)

C SR 3.3.5.3.1 SR 3.3.5.3.2 425 psig

13. RHR System Isolation
a. Reactor Vessel Water LevelLow Level 1 (ab) 2 in one trip system B

SR 3.3.5.3.1 SR 3.3.5.3.2 153 inches

24. Reactor Water Cleanup (RWCU)

System Isolation

a. Reactor Vessel Water LevelLow Level 2 (ab) 2 in one trip system B

SR 3.3.5.3.1 SR 3.3.5.3.2 101 inches (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control."

(ab) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

LOP Instrumentation 3.3.8.1 Brunswick Unit 1 3.3-69 Amendment No. 239 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3,.

When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, "AC SourcesShutdown."

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.

Required Action and associated Completion Time not met.

B.1 Declare associated diesel generator (DG) inoperable.

Immediately

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-9 Amendment No. 283 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

(continued)

C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours D.

DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

D.1

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

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to establish secondary containment boundary.

AND Immediately Immediately (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-10 Amendment No. 283 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

(continued)

D.3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one SGT standby gas treatment subsystem is capable of being placed in operation.

Immediately Immediately E.

Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

E.1 Initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection (LPCI) subsystem, the suppression pool water level is

-31 inches.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-11 Amendment No. 283 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required core spray (CS) subsystem, the:

a.

Suppression pool water level is -31 inches; or

b.

Condensate storage tank water volume is 228,200 gallons.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5

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

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

Verify for the required ECCS injection/spray subsystem each 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.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.56

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

1.

Operation may be through the test return line.

2.

Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-12 Amendment No. 283 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.67 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.78

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 Brunswick Unit 1 3.6-7 Amendment No. 203 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.,

When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation."

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment,"

when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

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

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with one PCIV inoperable except for MSIV leakage not within limit.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)

PCIVs 3.6.1.3 Brunswick Unit 1 3.6-10 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

One or more penetration flow paths with one or more MSIVs not within MSIV leakage rate limits.

D.1 Restore leakage rate to within limit.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E.

Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours F.

Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during MODE 4 or 5.

F.1 Initiate action to restore valve(s) to OPERABLE status.

Immediately

AC SourcesShutdown 3.8.2 Brunswick Unit 1 3.8-19 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Two required DGs inoperable.

C.1 Suspend CORE ALTERATIONS.

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

AND C.3 Initiate action to restore required DGs to OPERABLE status.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

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

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

For The following SRs are applicable for AC sources required to be OPERABLE: the SRs of Specification 3.8.1, except SR 3.8.1.8 and SR 3.8.1.12, are applicable.

SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.2 SR 3.8.1.6 SR 3.8.1.3 SR 3.8.1.9 SR 3.8.1.4 SR 3.8.1.11 In accordance with applicable SRs

RA-20-0165 Proposed Technical Specification Changes (Mark-Up) -

Unit 2

Definitions 1.1 Brunswick Unit 2 1.1-3 Amendment No. 311 1.1 Definitions DOSE EQUIVALENT I-131 Submersion, and Ingestion," 1989 and FGR 12, "External (continued)

Exposure to Radionuclides in Air, Water, and Soil," 1993.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48a Amendment No. 311 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.3-1 for the channel.

Immediately AB. One or more channels inoperable.As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

A.1 Initiate action to place channel in trip.

OR A.2.1B.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2B.2 Initiate action to Ccalculate DRAIN TIME.

Immediately Immediately C.

As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48b Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and associated Completion Time of Condition C not met.

D.1 Declare associated low pressure ECCS injection/spray subsystem inoperable.

Immediately SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.3-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48c Amendment No. 311 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION CONDITIONS REFERENCED FROM REQUIRED ACTION A.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE

1. Core Spray System
a. Reactor Steam Dome PressureLow 4, 5 4(a)

C SR 3.3.5.3.1 SR 3.3.5.3.2 425 psig

2. Low Pressure Coolant Injection (LPCI) System
a. Reactor Steam Dome PressureLow 4, 5 4(a)

C SR 3.3.5.3.1 SR 3.3.5.3.2 425 psig

13. RHR System Isolation
a. Reactor Vessel Water LevelLow Level 1 (ab) 2 in one trip system B

SR 3.3.5.3.1 SR 3.3.5.3.2 153 inches

24. Reactor Water Cleanup (RWCU)

System Isolation

a. Reactor Vessel Water LevelLow Level 2 (ab) 2 in one trip system B

SR 3.3.5.3.1 SR 3.3.5.3.2 101 inches (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control."

(ab) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

LOP Instrumentation 3.3.8.1 Brunswick Unit 2 3.3-69 Amendment No. 267 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3,.

When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, "AC SourcesShutdown."

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.

Required Action and associated Completion Time not met.

B.1 Declare associated diesel generator (DG) inoperable.

Immediately

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-9 Amendment No. 311 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

(continued)

C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours D.

DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

D.1

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

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to establish secondary containment boundary.

AND Immediately Immediately (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-10 Amendment No. 311 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

(continued)

D.3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one SGT standby gas treatment subsystem is capable of being placed in operation.

Immediately Immediately E.

Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

E.1 Initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection (LPCI) subsystem, the suppression pool water level is

-31 inches.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-11 Amendment No. 311 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required core spray (CS) subsystem, the:

a.

Suppression pool water level is -31 inches; or

b.

Condensate storage tank water volume is 228,200 gallons.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5

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

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

Verify for the required ECCS injection/spray subsystem each 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.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.56

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

1.

Operation may be through the test return line.

2.

Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-12 Amendment No. 311 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.67 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.78

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 Brunswick Unit 2 3.6-7 Amendment No. 233 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3,.

When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation."

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment,"

when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

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

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with one PCIV inoperable except for MSIV leakage not within limit.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)

PCIVs 3.6.1.3 Brunswick Unit 2 3.6-10 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

One or more penetration flow paths with one or more MSIVs not within MSIV leakage rate limits.

D.1 Restore leakage rate to within limit.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E.

Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours F.

Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during MODE 4 or 5.

F.1 Initiate action to restore valve(s) to OPERABLE status.

Immediately

AC SourcesShutdown 3.8.2 Brunswick Unit 2 3.8-19 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Two required DGs inoperable.

C.1 Suspend CORE ALTERATIONS.

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

AND C.3 Initiate action to restore required DGs to OPERABLE status.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

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

Unless required to be performed by Unit 1 Specification 3.8.1, the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9, and through SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.14.

For The following SRs are applicable for AC sources required to be OPERABLE:, the SRs of Specification 3.8.1, except SR 3.8.1.8 and SR 3.8.1.12, are applicable.

SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.2 SR 3.8.1.6 SR 3.8.1.3 SR 3.8.1.9 SR 3.8.1.4 SR 3.8.1.11 In accordance with applicable SRs

RA-20-0165 Revised Technical Specification Pages - Unit 1

Definitions 1.1 Brunswick Unit 1 1.1-3 Amendment No. 283 1.1 Definitions DOSE EQUIVALENT I-131 Submersion, and Ingestion," 1989 and FGR 12, "External (continued)

Exposure to Radionuclides in Air, Water, and Soil," 1993.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, for all penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 1 3.3-48a Amendment No. 283 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Initiate action to place channel in trip.

OR A.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 1 3.3-48b Amendment No. 283 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.3-1.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 1 3.3-48c Amendment No. 283 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION ALLOWABLE VALUE

1. RHR System Isolation
a. Reactor Vessel Water LevelLow Level 1 (a) 2 in one trip system 153 inches
2. Reactor Water Cleanup (RWCU)

System Isolation

a. Reactor Vessel Water LevelLow Level 2 (a) 2 in one trip system 101 inches (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

LOP Instrumentation 3.3.8.1 Brunswick Unit 1 3.3-69 Amendment No. 239 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.

Required Action and associated Completion Time not met.

B.1 Declare associated diesel generator (DG) inoperable.

Immediately

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-9 Amendment No. 283 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

(continued)

C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours D.

DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

D.1

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

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to establish secondary containment boundary.

AND Immediately Immediately (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-10 Amendment No. 283 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

(continued)

D.3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

Immediately Immediately E.

Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

E.1 Initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the suppression pool water level is -31 inches.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-11 Amendment No. 283 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required core spray (CS) subsystem, the:

a.

Suppression pool water level is -31 inches; or

b.

Condensate storage tank water volume is 228,200 gallons.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5

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

1.

Operation may be through the test return line.

2.

Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 1 3.5-12 Amendment No. 283 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 Brunswick Unit 1 3.6-7 Amendment No. 203 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment,"

when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

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

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with one PCIV inoperable except for MSIV leakage not within limit.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)

PCIVs 3.6.1.3 Brunswick Unit 1 3.6-10 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

One or more penetration flow paths with one or more MSIVs not within MSIV leakage rate limits.

D.1 Restore leakage rate to within limit.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E.

Required Action and associated Completion Time of Condition A, B, C, or D not met.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours

AC SourcesShutdown 3.8.2 Brunswick Unit 1 3.8-19 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Two required DGs inoperable.

C.1 Suspend CORE ALTERATIONS.

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

AND C.3 Initiate action to restore required DGs to OPERABLE status.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

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

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

The following SRs are applicable for AC sources required to be OPERABLE:

SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.2 SR 3.8.1.6 SR 3.8.1.3 SR 3.8.1.9 SR 3.8.1.4 SR 3.8.1.11 In accordance with applicable SRs

RA-20-0165 Revised Technical Specification Pages - Unit 2

Definitions 1.1 Brunswick Unit 2 1.1-3 Amendment No. 311 1.1 Definitions DOSE EQUIVALENT I-131 Submersion, and Ingestion," 1989 and FGR 12, "External (continued)

Exposure to Radionuclides in Air, Water, and Soil," 1993.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure, for all penetration flow paths below the TAF except:

1.

Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2.

Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3.

Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48a Amendment No. 311 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Initiate action to place channel in trip.

OR A.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48b Amendment No. 311 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.3-1.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48c Amendment No. 311 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER FUNCTION ALLOWABLE VALUE

1. RHR System Isolation
a. Reactor Vessel Water LevelLow Level 1 (a) 2 in one trip system 153 inches
2. Reactor Water Cleanup (RWCU) System Isolation
a. Reactor Vessel Water LevelLow Level 2 (a) 2 in one trip system 101 inches (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

LOP Instrumentation 3.3.8.1 Brunswick Unit 2 3.3-69 Amendment No. 267 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.

Required Action and associated Completion Time not met.

B.1 Declare associated diesel generator (DG) inoperable.

Immediately

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-9 Amendment No. 311 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

(continued)

C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours D.

DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

D.1

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

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to establish secondary containment boundary.

AND Immediately Immediately (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-10 Amendment No. 311 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

(continued)

D.3 Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

Immediately Immediately E.

Required Action and associated Completion Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

E.1 Initiate action to restore DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the suppression pool water level is -31 inches.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-11 Amendment No. 311 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required core spray (CS) subsystem, the:

a.

Suppression pool water level is -31 inches; or

b.

Condensate storage tank water volume is 228,200 gallons.

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

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5

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

1.

Operation may be through the test return line.

2.

Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program (continued)

RPV Water Inventory Control 3.5.2 Brunswick Unit 2 3.5-12 Amendment No. 311 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 Brunswick Unit 2 3.6-7 Amendment No. 233 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment,"

when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

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

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with one PCIV inoperable except for MSIV leakage not within limit.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)

PCIVs 3.6.1.3 Brunswick Unit 2 3.6-10 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

One or more penetration flow paths with one or more MSIVs not within MSIV leakage rate limits.

D.1 Restore leakage rate to within limit.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E.

Required Action and associated Completion Time of Condition A, B, C, or D not met.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours

AC SourcesShutdown 3.8.2 Brunswick Unit 2 3.8-19 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Two required DGs inoperable.

C.1 Suspend CORE ALTERATIONS.

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

AND C.3 Initiate action to restore required DGs to OPERABLE status.

Immediately Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1

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

Unless required to be performed by Unit 1 Specification 3.8.1, the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9, and SR 3.8.1.11,.

The following SRs are applicable for AC sources required to be OPERABLE:

SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.2 SR 3.8.1.6 SR 3.8.1.3 SR 3.8.1.9 SR 3.8.1.4 SR 3.8.1.11 In accordance with applicable SRs

RA-20-0165 Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only)

RPV Water Inventory Control Instrumentation B 3.3.5.3 Brunswick Unit 1 B 3.3.5.3-1 Revision No. 100 B 3.3 INSTRUMENTATION B 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the AF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation," or LCO 3.3.6.1, "Primary Containment Isolation instrumentation".

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses.

RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

(continued)

RPV Water Inventory Control Instrumentation B 3.3.5.3 Brunswick Unit 1 B 3.3.5.3-2 Revision No. 100 BASES BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses. RPV ANALYSES, LCO, water inventory control is required in MODES 4 and 5 to protect and APPLICABILITY Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated considered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulated considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

(continued)

RPV Water Inventory Control Instrumentation B 3.3.5.3 Brunswick Unit 1 B 3.3.5.3-3 Revision No. 100 BASES APPLICABLE Core Spray and Low Pressure Coolant Injection Systems SAFETY ANALYSES, LCO, and 1.a, 2.a Reactor Steam Dome PressureLow APPLICABILITY (continued)

Low reactor steam dome pressure signals are used as permissive for the low pressure ECCS injection/spray subsystem manual injection functions.

This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.

The Reactor Steam Dome PressureLow signals are initiated from four pressure transmitters that sense the reactor dome pressure.

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Steam Dome PressureLow Function are required to be OPERABLE in MODES 4 and 5 when manual operation is required to be OPERABLE by LCO 3.5.2.

RHR System Isolation 13.a Reactor Vessel Water LevelLow Level 1 The definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation. The Reactor Vessel Water LevelLow Level 1 Function associated with RHR System isolation may be credited for automatic isolation of penetration flow paths associated with the RHR System.

Reactor Vessel Water LevelLow Level 1 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 1 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low, Level 1 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 8 valves.

(continued)

RPV Water Inventory Control Instrumentation B 3.3.5.3 Brunswick Unit 1 B 3.3.5.3-4 Revision No. 100 BASES APPLICABLE Reactor Water Cleanup (RWCU) System Isolation SAFETY ANALYSES, LCO, and 24.a Reactor Vessel Water LevelLow Level 2 APPLICABILITY (continued)

The definition of DRAIN TIME allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF. The Reactor Vessel Water LevelLow Level 2 Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.

Reactor Vessel Water LevelLow Level 2 is initiated from two channels per trip system that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water LevelLow Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water LevelLow Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

This Function isolates the Group 3 valves.

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

RPV Water Inventory Control Instrumentation B 3.3.5.3 Brunswick Unit 1 B 3.3.5.3-6 Revision No. 100 BASES ACTIONS A.1, A.2.1, B.1 and A.2.2B.2 (continued)

RHR System Isolation, Reactor Vessel Water LevelLow Level 1, and Reactor Water Cleanup System, Reactor Vessel Water LevelLow Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action A.1B.1 directs an immediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires immediate declaration that the associated penetration flow path(s) to be immediately declared are incapable of automatic isolation. Required Action A.2.2 B.2 directs initiating action to calculate calculation of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

C.1 Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 With the Required Action and associated Completion Time of Condition C not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

SURVEILLANCE The following SRs apply to As noted in the beginning of the SRs, the SRs for each RPV Water REQUIREMENTS Inventory Control instrument Function are found in the SRs column of Table 3.3.5.3-1.

SR 3.3.5.3.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the 5

Primary Containment Isolation Instrumentation B 3.3.6.1 Brunswick Unit 1 B 3.3.6.1-27 Revision No. 100 BASES ACTIONS H.1 and H.2 (continued)

If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, or the Required Action of Condition F or G is not met and the associated Completion Time has expired, the plant must be placed in a MODE or other specified condition in which the LCO does not apply. This is done by placing the plant in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

I.1 and I.2 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the associated SLC subsystem(s) is declared inoperable or the RWCU System is isolated. Since this Function is required to ensure that the SLC System performs its intended function, sufficient remedial measures are provided by declaring the associated SLC subsystems inoperable or isolating the RWCU System.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is acceptable because it minimizes risk while allowing sufficient time for personnel to isolate the RWCU System.

J.1 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the associated penetration flow path should be closed. However, if the shutdown cooling function is needed to provide core cooling, the Required Action allows the penetration flow path to remain unisolated provided action is immediately initiated to restore the channel to OPERABLE status. Actions must continue until the channel is restored to OPERABLE status.

(continued)

LOP Instrumentation B 3.3.8.1 Brunswick Unit 1 B 3.3.8.1-3 Revision No. 78 BASES APPLICABLE

1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

SAFETY ANALYSES, LCO, and A loss of voltage on a 4.16 kV emergency bus indicates that offsite power APPLICABILITY may be completely lost to the respective emergency bus and is unable to (continued) supply sufficient power for proper operation of the applicable equipment.

The loss of voltage relay strips the rotating loads and cross-tie breakers from the emergency bus to provide a permissive for the diesel generator output breaker to close and restore power to the bus and applicable equipment when the bus voltage the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). The loss of voltage relay also provides a trip signal to the incoming line breaker to the associated emergency bus to allow the diesel generator to connect to the emergency bus.

The Bus Undervoltage Allowable Values are set low enough to prevent inadvertent load shedding and opening of the incoming line breaker. The Time Delay Allowable Values are set long enough to prevent inadvertent power supply transfer, but short enough to minimize the delay in providing backup power to the emergency bus.

One channel of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Function per associated emergency bus is only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the loading capability of three of the four DGs. (One channel inputs to each of the four DGs.) Refer to LCO 3.8.1, "AC SourcesOperating," and 3.8.2, "AC SourcesShutdown," for Applicability Bases for the DGs.

2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A degraded voltage condition on a 4.16 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function. When the bus voltage drops below the Degraded Voltage Function Allowable Values (degraded voltage with a fixed time delay), the degraded voltage relays will operate to separate the emergency bus from offsite power after a sufficient time delay to allow for recovery of the normal offsite power supply. The emergency bus loss of voltage relay strips the rotating loads and provides a trip signal to the cross-tie breakers. The load shedding provides a permissive to allow the diesel generator to connect to the bus.

The Bus Undervoltage Allowable Values of the degraded voltage relays are set low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Time Delay Allowable Values are long enough to allow (continued)

LOP Instrumentation B 3.3.8.1 Brunswick Unit 1 B 3.3.8.1-4 Revision No. 78 BASES APPLICABLE

2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY recovery of the normal offsite power supply and to prevent actuation during transient voltages created by starting large motors, but short enough to ensure that sufficient power is provided to the required equipment.

Three channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function per associated emergency bus are only required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function.

(Three channels input to each of the four emergency buses and DGs.)

Refer to LCO 3.8.1, "AC Sources-Operating," and LCO 3.8.2, "AC Sources-Shutdown," for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel.

A.1 With one or more channels of a Function inoperable, the Function is not capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to restore the inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure (within the LOP instrumentation), and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the channel in trip would result in a DG initiation), Condition B must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

(continued)

LOP Instrumentation B 3.3.8.1 Brunswick Unit 1 B 3.3.8.1-5 Revision No. 94 BASES ACTIONS B.1 (continued)

If any Required Action and associated Completion Time are not met, the associated Function is not capable of performing the intended function.

Therefore, the associated DG(s) is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provides appropriate actions for the inoperable DG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS instrumentation Function are located in the SRs column of Table 3.3.8.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided: (a) for Function 1, the associated Function maintains initiation capability for three DGs; and (b) for Function 2, the associate Function maintains DG initiation capability. For Function 1, the loss of function for one DG for this short period is appropriate since only three of four DGs are required to start within the required times and because there is no appreciable impact on risk. Also, upon completion of the Surveillance, or expiration of the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

SR 3.3.8.1.1 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

LOP Instrumentation B 3.3.8.1 Brunswick Unit 1 B 3.3.8.1-6 Revision No. 94 BASES SURVEILLANCE SR 3.3.8.1.2 and SR 3.3.8.1.3 REQUIREMENTS (continued)

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.8.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel and includes simulated automatic operation of the channel. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 6.3.

2.

UFSAR, Chapter 15.

3.

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

RPV Water Inventory Control B 3.5.2 Brunswick Unit 1 B 3.5.2-1 Revision No. 100 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not SAFETY ANALYSES required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not considered postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such as e.g., seismic event, loss of normal power, or a single human error). It is assumed, 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.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

(continued)

RPV Water Inventory Control B 3.5.2 Brunswick Unit 1 B 3.5.2-2 Revision No. 100 BASES LCO The Limiting Condition for Operation (LCO) requires the DRAIN TIME of (continued)

RPV water inventory to the TAF to be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A DRAIN TIME of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in-depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A low pressure ECCS injection/spray subsystem consists of either one Core Spray (CS) subsystem or one Low Pressure Coolant Injection (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 RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valve is not required to be closed.

The LCO is modified by a Note which allows a required LPCI subsystem 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 is not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

APPLICABILITY RPV water inventory control is required in MODES 4 and 5.

Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, "ECCS, RCIC, and RPV Water Inventory Control, and RCIC System."

RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

(continued)

RPV Water Inventory Control B 3.5.2 Brunswick Unit 1 B 3.5.2-6 Revision No. 100 BASES ACTIONS E.1 (continued)

If the Required Actions and associated Completion times of Conditions C or D are not met or if the DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, actions must be initiated immediately to restore the DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF.

Note that Required Actions D.1, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlledlocked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted.

Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

(continued)

RPV Water Inventory Control B 3.5.2 Brunswick Unit 1 B 3.5.2-7 Revision No. 100 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Ref. 6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

The exclusion of a single penetration flow paths, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME must should consider the potential effects of temporary alterations in support of maintenance a single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If reasonable controls are implemented to prevent If failure of such items temporary alterations from could result and would cause causing a draining event from a closed system, or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, the penetration flow path may not be excluded from the DRAIN TIME calculation.controls consistent with the guidance in NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 4, NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," or commitments to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of -31 inches required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CS subsystem or LPCI subsystem pump, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

The required CS System is OPERABLE only if it can take suction from the CST and the CST contains a total volume, which includes both usable and unusable volumes, of 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.

RPV Water Inventory Control B 3.5.2 Brunswick Unit 1 B 3.5.2-9 Revision No. 100 BASES SURVEILLANCE SR 3.5.2.4 REQUIREMENTS (continued)

The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS actuationinitiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.5 Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path provides assurance that the proper flow paths will be available for ECCS operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition 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 Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.56 Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that tTesting the ECCS injection/spray subsystem may be done through the test return recirculation line is necessary to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.67 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

(continued) 8

RPV Water Inventory Control B 3.5.2 Brunswick Unit 1 B 3.5.2-10 Revision No. 100 BASES SURVEILLANCE SR 3.5.2.78 REQUIREMENTS (continued)

The required ECCS subsystem shall be capable of being manually operated. This Surveillance verifies that a the required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPVoperated to provide additional RPV Water Inventory, if needed.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2.

Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3.

Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), " August 1992.

4.

NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5.

Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6.

General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

9

PCIVs B 3.6.1.3 Brunswick Unit 1 B 3.6.1.3-4 Revision No. 100 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, PCIVs are not required to be OPERABLE in MODES 4 and 5. Certain valves, however, are required to be OPERABLE when the associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation." (This does not include the valves that isolate the associated instrumentation.)

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose 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 PCIV. Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by Notes 3 and 4. Note 3 ensures that appropriate remedial actions are taken, if necessary, if the affected system(s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve). Note 4 ensures appropriate remedial actions are taken when the primary containment leakage limits are exceeded.

Pursuant to LCO 3.0.6, these actions are not required even when the associated LCO is not met. Therefore, Notes 3 and 4 are added to require the proper actions be taken.

(continued)

PCIVs B 3.6.1.3 Brunswick Unit 1 B 3.6.1.3-8 Revision No. 100 BASES ACTIONS D.1 (continued)

With one or more penetration flow paths with MSIV leakage rate not within limit, the assumptions of the safety analysis may not be met.

Therefore, the leakage must be restored to within limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time allows a period of time to restore the leakage to within limits given the fact that MSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown.

E.1 and E.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 LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1 If any Required Action and associated Completion Time cannot be met for PCIV(s) required to be OPERABLE in MODE 4 or 5, the unit must be placed in a condition in which the LCO does not apply. Action must be immediately initiated to restore the valve(s) to OPERABLE status. This allows RHR shutdown cooling to remain in service while actions are being taken to restore the valve.

(continued)

AC SourcesShutdown B 3.8.2 Brunswick Unit 1 B 3.8.2-3 Revision No. 100 BASES LCO transmission network and the onsite Class 1E AC electrical power (continued) 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 the ability to manually start two 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).

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 LCO 3.8.8. The Unit 2 qualified offsite circuit consists of the incoming breaker and disconnect to and 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 being manually startedstarting, 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.

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 meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode. Proper sequencing of loads, including tripping of (continued)

AC SourcesShutdown B 3.8.2 Brunswick Unit 1 B 3.8.2-4 Revision No. 100 BASES LCO nonessential loads, is required function for DG OPERABILITY. The (continued) 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 that provide core cooling;

b.

Systems needed to mitigate a fuel handling accident 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, 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 (continued)

AC SourcesShutdown B 3.8.2 Brunswick Unit 1 B 3.8.2-6 Revision No. 100 BASES ACTIONS A.2.1, A.2.2, A.2.3, B.2.1, B.2.2, B.2.3, C.1, C.2, and C.3 (continued) 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 LCO 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 whether or not a required bus is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de-energized bus.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the required AC 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 3.8.1.7, SR 3.8.1.8, SR 3.8.1.10, SR 3.8.1.13, and SR 3.8.1.14 are not required to be met because DG response on an offsite power or ECCS initiation signal is not required. 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 LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to which precludes requiring the OPERABLE DG(s) from being 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 (continued)

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