ML18039A444

Issuance of Amendments to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control Revision 2

ML18039A444
Person / Time
Site:	Brunswick
Issue date:	04/13/2018
From:	Hon A L Plant Licensing Branch II
To:	Gideon W R Duke Energy Progress
Hon A L, NRR/DORL/LPL2-2, 415-8480
References
CAC MF9905, CAC MF9906, EPID L-2017-LLA-0162
Download: ML18039A444 (138)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. William R. Gideon, Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd., SE (M/C BNP001) Southport, NC 28461 April 13, 2018

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NOS. MF9905 AND MF9906; EPID L-2017-LLA-0242)

Dear Mr. Gideon:

The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment Nos. 283 and 311 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant (Brunswick), Units 1 and 2, respectively.

These amendments are in response to your application dated June 29, 2017, as supplemented by letters dated January 4 and 23, 2018. The amendments adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," and replace the existing requirements in the technical specifications (TSs) related to operations with a potential for draining the reactor vessel with revised TSs providing an alternative for reactor pressure vessel water inventory control. A copy of the related Safety Evaluation is also enclosed.

A Notice of Issuance will be included in the Commission's biweekly Federal Register Notice. Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 283 to DPR-71 2. Amendment No. 311 to DPR-62 3. Safety Evaluation cc: Listserv Sincerely,

6. S-o~'--/vr Andrew Hon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 283 Renewed License No. DPR-71 1. The Nuclear Regulatory Commission (the Commission) has found that: A The application for amendment filed by Duke Energy Progress, LLC, dated June 29, 2017, as supplemented by letters dated January 4 and 23, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-71 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 283, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 180 days.

Attachment:

FOR THE NUCLEAR REGULA TORY COMMISSION P~, u rr-~ Brian W. Tindell, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Changes to the Renewed Operating License and Technical Specifications Date of Issuance:

April 13, 2018 ATTACHMENT TO LICENSE AMENDMENT NO. 283 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace Page 6 of Renewed Facility Operating License No. DPR-71 with the attached revised Page 6. Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove Pages 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 1.1-8 3.3-35 3.3-36 3.3-41 3.3-42 3.3-43 3.3-44 3.3-51 3.3-58 3.3-62 3.3-65 3.5-1 3.5-8 3.5-9 3.5-10 3.5-11 3.5-12 3.5-13 3.5-14 3.6-10 3.6-28 3.6-29 Insert Pages 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 1.1-8 3.3-35 3.3-36 3.3-41 3.3-42 3.3-43 3.3-44 3.3-48a 3.3-48b 3.3-48c 3.3-51 3.3-58 3.3-62 3.3-65 3.5-1 3.5-8 3.5-9 3.5-10 3.5-11 3.5-12 3.5-13 3.5-14 3.5-15 3.6-10 3.6-28 3.6-29 ATTACHMENT TO LICENSE AMENDMENT NO. 283 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 3.6-30 3.6-32 3.6-33 3.6-34 3.6-35 3.7-11 3.7-12 3.7-13 3.7-15 3.7-16 3.7-17 3.8-17 3.8-18 3.8-19 3.8-28 3.8-39 (TS pages) -Continued 3.6-30 3.6-32 3.6-33 3.6-34 3.6-35 3.7-11 3.7-12 3.7-13 3.7-15 3.7-16 3.7-17 3.8-17 3.8-18 3.8-19 3.8-28 3.8-39 (c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above. 2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation.

The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180 1 h day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal. (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 283, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 283

1.1 Definitions

DOSE EQUIVALENT 1-131 (continued)

DRAIN TIME Brunswick Unit 1 Definitions 1.1 Submersion, and Ingestion," 1989 and FGR 12, "External Exposure to Radionuclides in Air, Water, and Soil," 1993. 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 T AF except: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are 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 T AF 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) 1.1-3 Amendment No. 283

1.1 Definitions

DRAIN TIME (continued) d) No additional draining events occur; and Definitions 1.1 e) Realistic cross-sectional areas and drain rates are used. A bounding DRAIN TIME may be used in lieu of a calculated value. EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval from SYSTEM (ECCS) RESPONSE when the monitored parameter exceeds its ECCS initiation TIME setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

INSERVICE TESTING PROGRAM The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION INSTRUMENTATION The ISOLATION INSTRUMENTATION RESPONSE TIME RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves receive the isolation signal (e.g., de-energization of the MSIV solenoids).

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

LEAKAGE Brunswick Unit 1 LEAKAGE shall be: a. Identified LEAKAGE 1. LEAKAGE into the drywell, such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or 2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE; (continued) 1.1-4 Amendment No. 283

1.1 Definitions

LEAKAGE ( continued)

LINEAR HEAT GENERATION RATE (LHGR) b. Unidentified LEAKAGE Definitions 1.1 All LEAKAGE into the drywell that is not identified LEAKAGE; c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall. The LHGR shall be the heat generation rate per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length. LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of TEST all required logic components (i.e., all required relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY.

The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested. MINIMUM CRITICAL POWER RA TIO (MCPR) MODE Brunswick Unit 1 The MCPR shall be the smallest critical power ratio (CPR) that exists in the core. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power. A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel. ( continued) 1.1-5 Amendment No. 283 I

1.1 Definitions

(continued)

OPERABLE-OPERABILITY RATED THERMAL POWER (RTP) REACTOR PROTECTION SYSTEM(RPS)RESPONSE TIME SHUTDOWN MARGIN (SOM) Brunswick Unit 1 Definitions 1.1 A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 2923 MWt. The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that: a. The reactor is xenon free; b. The moderator temperature is~ 68°F, corresponding to the most reactive state; and c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SOM. (continued) 1.1-6 Amendment No. 283

1.1 Definitions

(continued)

STAGGERED TEST BASIS THERMAL POWER TURBINE BYPASS SYSTEM RESPONSE TIME Brunswick Unit 1 Definitions 1.1 A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. The TURBINE BYPASS SYSTEM RESPONSE TIME consists of two components:

a. The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established; and b. The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

1.1-7 Amendment No. 283 I MODE TITLE 1 Power Operation 2 Startup 3 Hot Shutdown<aJ 4 Cold Shutdown<aJ 5 Refueling(b)

Table 1.1-1 (page 1 of 1) MODES REACTOR MODE SWITCH POSITION Run Refue1<aJ or Startup/Hot Standby Shutdown Shutdown Shutdown or Refuel (a) All reactor vessel head closure bolts fully tensioned.

Definitions

1.1 AVERAGE

REACTOR COOLANT TEMPERATURE (OF) NA NA > 212 :s; 212 NA (b) One or more reactor vessel head closure bolts less than fully tensioned.

Brunswick Unit 1 1.1-8 Amendment No. 283 I

3.3 INSTRUMENTATION

3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation ECCS Instrumentation 3.3.5.1 LCO 3.3.5.1 The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.1-1.

ACTIONS -----------------------------------------------------------

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

Separate Condition entry is allowed for each channel. COMPLETION CONDITION REQUIRED ACTION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable.

referenced in Table 3.3.5.1-1 for the channel. B. As required by Required B.1 -------------NOTE---------------

Action A.1 and referenced in Only applicable for Table 3.3.5.1-1.

Functions 1.a, 1.b, 2.a, and 2.b. ------------------------------------

Declare supported 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from feature(s) inoperable when discovery of loss of its redundant feature initiation capability ECCS initiation capability for feature(s) in is inoperable.

both divisions AND (continued)

Brunswick Unit 1 3.3-35 Amendment No. 283 ACTIONS CONDITION B. (continued)

B.2 AND B.3 C. As required by Required C. 1 Action A.1 and referenced in Table 3.3.5.1-1.

AND C.2 Brunswick Unit 1 REQUIRED ACTION --------------NO TE-------------

Only applicable for Functions 3.a and 3.b. -----------------------------------

Declare High Pressure Coolant Injection (HPCI) System inoperable.

Place channel in trip. -------------NO TE---------------

Only applicable for Functions 1.c, 1.d, 2.c, 2.d, and 2.f. ------------------------------------

Declare supported feature{s) inoperable when its redundant feature ECCS initiation capability is inoperable.

Restore channel to OPERABLE status. 3.3-36 ECCS Instrumentation 3.3.5.1 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of HPCI initiation capability 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1 hour from discovery of loss of initiation capability for feature(s) in both divisions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (continued)

Amendment No. 283 FUNCTION 1. Core Spray System a. Reactor Vessel Water Level-Low Level 3 b. Drywell Pressure-High C. Reactor Steam Dome Pressure-Low d Core Spray Pump Start-Time Delay Relay 2 Low Pressure Coolant Injection (LPCI) System a Reactor Vessel Water Level-Low Level 3 b Drywell Pressure-High Brunswick Unit 1 Table 3.3.5.1-1 (page 1 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED CONDITIONS FUNCTION ACTIONA1 1,2,3 4 B 1,2,3 4 B 1,2,3 4 C 1,2,3 2 C 1 per pump 1,2,3 4 B 1,2,3 4 B 3.3-41 ECCS Instrumentation 3.3.5.1 SURVEILLANCE ALLOWABLE REQUIREMENTS VALUE SR 3.3.5.1.1

13 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 s 1.8 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 402 psig SR 3.3.5.1.2 and 425 psig SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.4 2 14 seconds SR 3.3.5.1.5 and 16 seconds SR 3.3.5.1.6 SR 3.3.5.1.1 2 13 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 s 1.8 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued)

Amendment No. 283 Table 3.3.5.1-1 (page 2 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED FUNCTION CONDITIONS FUNCTION ACTIONA.1

2. LPCI System (continued)

C. Reactor Steam Dome Pressure-Low 1,2,3 4 C d. Reactor Steam Dome Pressure-Low 1 (a)12 (a)1 4 C (Recirculation Pump Discharge Valve Permissive) 3(a) e. Reactor Vessel Shroud Level 1,2,3 2 B f. RHR Pump Start-Time Delay Relay 1,2,3 4 C 1 per pump 3. High Pressure Coolant Injection (HPCI) System a. Reactor Vessel Water Level-Low 4 B Level 2 2Cb)1 J(bl b. Drywall Pressure-High 1, 4 B 2'bl,3{b) (a) With associated recirculation pump discharge valve or recirculation pump discharge bypass valve open. (b) With reactor steam dome pressure > 150 psig. Brunswick Unit 1 3.3-42 ECCS Instrumentation 3.3.5.1 SURVEILLANCE ALLOWABLE REQUIREMENTS VALUE SR 3.3.5.1.1

,402 psig SR 3.3.5.1.2 and s 425 psig SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1

, 302 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 2 -50 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.4

, 9 seconds SR 3.3.5.1.5 and SR 3.3.5.1.6 s 11 seconds SR 3.3.5.1.1

, 101 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 s 1.8 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 ( continued)

Amendment No. 283 ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTIONA.1 REQUIREMENTS VALUE 3. HPCI System (continued)

C. Reactor Vessel Water Level-High 1, 2 C SR 3.3.5.1.1 s 207 inches SR 3.3.5.1.2 2l, 3(b) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Condensate Storage Tank Level-Low 1, 2 D SR 3.3.5.1.2 2 23 feet 4 inches SR 3.3.5.1.4 2'bl,3(b)

SR 3.3.5.1.5

e. Suppression Chamber Water Level-1, 2 D SR 3.3.5.1.2 s-2feet High SR 3.3.5.1.4 2'bl, 3(b) SR 3.3.5.1.5

4. Automatic Depressurization System (ADS) Trip System A a. Reactor Vessel Water Level-Low 1, 2 E SR 3.3.5.1.1 213 inches Level 3 SR 3.3.5.1.2 2'bl, 3(b) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

b. ADS Timer 1, F SR 3.3.5.1.4 s 108 seconds SR 3.3.5.1.5 2(bl, 3(b) SR 3.3.5.1.6 C. Reactor Vessel Water Level-Low 1, E SR 3.3.5.1.1 2153 inches Level 1 SR 3.3.5.1.2 ib>. 3(b) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Core Spray Pump Discharge 1, 2 F SR 3.3.5.1.2 2102 psig Pressure-High SR 3.3.5.1.4 and s 130 psig 2Cb)1 3Cb) SR 3.3.5.1.5

e. RHR (LPCI Mode) Pump Discharge 1, 4 F SR 3.3.5.1.2 102 psig Pressure-High 2 per pump SR 3.3.5.1.4 and s 130 psig ib>, 3(b) SR 3.3.5.1.5 ( continued) (b) With reactor steam dome pressure > 150 psig. Brunswick Unit 1 3.3-43 Amendment No. 283 ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE 5 ADS Trip System B a. Reactor Vessel Water Level-Low 1, 2 E SR 3.3.5.1.1 2 13 inches Level 3 SR 3.3.5.1.2 2(b)' 3(b) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

b. ADS Timer 1, F SR 3.3.5.1.4

,; 108 seconds SR 3.3.5.1.5 z!bl, 3(b) SR 3.3.5.1.6 C. Reactor Vessel Water Level-Low 1, E SR 3.3.5.1.1 z 153 inches Level 1 SR 3.3.5.1.2 2<b)' 3(b) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Core Spray Pump Discharge 1, 2 F SR 3.3.5.1.2 2 102 psig Pressure-High SR 3.3.5.1.4 and z!b}' 3{b) SR 3.3.5.1.5 s 130 psig e. RHR (LPCI Mode) Pump Discharge 1, 4 F SR 3.3.5.1.2 2 102 psig Pressure-High 2 per pump SR 3.3.5.1.4 and ,; 130 psig ibl, 3(b) SR 3.3.5.1.5 (b) With reactor steam dome pressure>

150 psig. Brunswick Unit 1 3.3-44 Amendment No. 283

3.3 INSTRUMENTATION

RPV Water Inventory Control Instrumentation 3.3.5.3 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 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS -----------------------------------------------------------

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

Separate Condition entry is allowed for each channel. COMPLETION CONDITION REQUIRED ACTION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable.

referenced in Table 3.3.5.3-1 for the channel. B. As required by Required B.1 Declare associated Immediately Action A.1 and referenced in penetration flow path(s) Table 3.3.5.3-1.

incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by Required 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 /> Action A.1 and referenced in Table 3.3.5.3-1. (continued)

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

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Declare associated low Immediately associated Completion Time pressure ECCS of Condition C not met. injection/spray subsystem inoperable.

SURVEILLANCE REQUIREMENTS

---

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

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

SURVEILLANCE SR 3.3.5.3.1 Perform CHANNEL CHECK. SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. Brunswick Unit 1 3.3-48b FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 283 RPV Water Inventory Control Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1) RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE 1. Core Spray System a. Reactor Steam Dome 4,5 4(a) C SR 3.3.5.3.1 s 425 psig Pressure-Low SR 3.3.5.3.2

2. Low Pressure Coolant Injection (LPCI) System a. Reactor Steam Dome 4,5 4(a) C SR 3.3.5.3.1 s 425 psig Pressure-Low SR 3.3.5.3.2

3. RHR System Isolation

a. Reactor Vessel Water (b) 2 in one trip B SR 3.3.5.3.1 2: 153 inches Level-Low Level 1 system SR 3.3.5.3.2

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (b) 2 in one trip B SR 3.3.5.3.1 2: 101 inches Level-Low Level 2 system SR 3.3.5.3.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control." (b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME. Brunswick Unit 1 3.3-48c Amendment No. 283 ACTIONS (continued)

CONDITION I. As required by Required 1.1 Action C.1 and referenced in Table 3.3.6.1-1.

OR 1.2 J. As required by Required J.1 Action C.1 and referenced in Table 3.3.6.1-1.

Brunswick Unit 1 Primary Containment Isolation Instrumentation 3.3.6.1 COMPLETION REQUIRED ACTION TIME Declare associated 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> standby liquid control subsystem (SLC) inoperable.

Isolate the Reactor Water 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Cleanup (RWCU) System. Initiate action to restore Immediately channel to OPERABLE status. 3.3-51 Amendment No. 283 I FUNCTION 6. RHR Shutdown Cooling System Isolation a Reactor Steam Dome Pressure-High

b. Reactor Vessel Water Level-Low Level 1 7 Traversing In-core Probe Isolation

a. Reactor Vessel Water Level -Low Level 1 b. Drywell Pressure -High Brunswick Unit 1 Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 5 of 5) Primary Containment Isolation Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1,2,3 3 1,2,3 1,2,3 REQUIRED CHANNELS PER TRIP SYSTEM 2 2 2 3.3-58 CONDITIONS REFERENCED FROM REQUIRED ACTIONC.1 F G G SURVEILLANCE REQUIREMENTS SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.7 SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.36.13 SR 3.3.6.1.6 SR 3.3.6.1. 7 ALLOWABLE VALUE s 137 psig 2 153 inches 153 inches s 1.8 psig Amendment No. 283 FUNCTION 1. Reactor Vessel Water Level-Low Level 2 2. Drywell Pressure-High

3. Reactor Building Exhaust Radiation-High Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1) Secondary Containment Isolation Instrumentation APPLICABLE REQUIRED MODES OR OTHER CHANNELS SPECIFIED PER SURVEILLANCE ALLOWABLE CONDITIONS TRIP SYSTEM REQUIREMENTS VALUE 1,2,3 2 SR 3.3.6.2.1

,-101 inches SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5 1,2,3 2 SR 3.3.6.2.1 1.8 psig SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5 1,2,3 SR 3.3.6.2.1 16 mR/hr (a) SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.5 (a) During movement of recently irradiated fuel assemblies in secondary containment.

Brunswick Unit 1 3.3-62 Amendment No. 283 Table 3.3.7.1-1 (page 1 of 1) CREV System Instrumentation 3.3.7.1 Control Room Emergency Ventilation (CREV) System Isolation Instrumentation FUNCTION 1. Control Building Air Intake Radiation

-High 2. Unit 1 Secondary Containment Isolation

-CREV Auto-Start APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1,2,3 (a) 1,2,3 REQUIRED CHANNELS PER TRIP SYSTEM 2 2 SURVEILLANCE REQUIREMENTS SR 3.3.7.1.1 SR 3.3.7.1.2 SR 3.3.7.1.3 SR 3.3.7.1.4 SR 3.3.6.2.2 SR 3.3.6.2.5 (a) During movement of recently irradiated fuel assemblies in secondary containment.

ALLOWABLE VALUE :<; 27 mR/hr (b) (b) The auto-start signal is provided from Secondary Containment Isolation logic and does not depend on a specific instrument; for Secondary Containment Isolation Instrumentation, refer to Table 3.3.6.2-1.

Brunswick Unit 1 3.3-65 Amendment No. 283 ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig. ACTIONS -----------------------------------------------------------

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

LCO 3.0.4.b is not applicable to HPCI. CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray subsystem ECCS injection/spray inoperable.

subsystem to OPERABLE status. OR One low pressure coolant injection (LPCI) pump in each subsystem inoperable.

B. One LPCI pump inoperable.

8.1 Restore

LPCI pump to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status. AND OR One core spray (CS) subsystem inoperable.

8.2 Restore

CS subsystem to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status. (continued)

Brunswick Unit 1 3.5-1 Amendment No. 283 I RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be ;:c: 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. One low pressure ECCS injection/spray subsystem shall be OPERABLE.

---

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY:

MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> injection/spray subsystem injection/spray subsystem inoperable.

to OPERABLE status. B. Required Action and 8.1 Initiate action to establish a Immediately associated Completion Time method of water injection of Condition A not met. capable of operating without offsite electrical power. C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and C.1 Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ;:c: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. containment boundary is capable of being established in less than the DRAIN TIME. AND (continued)

Brunswick Unit 1 3.5-8 Amendment No. 283 ACTIONS CONDITION C. (continued)

C.2 AND C.3 D. DRAIN TIME< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 0.1 AND 0.2 AND Brunswick Unit 1 RPV Water Inventory Control 3.5.2 REQUIRED ACTION COMPLETION TIME Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of . being isolated in less than the DRAIN TIME. Verify one standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment subsystem is capable of being placed in operation in less than the DRAIN TIME. --------------NO TE--------------

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

Initiate action to establish Immediately 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 />. Initiate action to establish Immediately secondary containment boundary. (continued) 3.5-9 Amendment No. 283 I RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION 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 standby gas treatment subsystem is capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore associated Completion Time DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 />. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.2.1 SR 3.5.2.2 Brunswick Unit 1 Verify DRAIN TIME~ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Verify, for a required low pressure coolant injection (LPCI) subsystem, the suppression pool water level is -31 inches. 3.5-10 COMPLETION TIME Immediately Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 283 I RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.3 SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 Brunswick Unit 1 SURVEILLANCE 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. Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water. -------------------------------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.

Operate the required ECCS injection/spray subsystem through the recirculation line for~ 10 minutes. 3.5-11 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 283 I RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.7 SR 3.5.2.8 Brunswick Unit 1 SURVEILLANCE Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal. -------------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

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

3.5-12 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 283 I RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS}, RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS -----------------------------------------------------------

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

LC O 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable.

A.1 Verify by administrative Immediately means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status. B. Required Action and 8.1 --------------NO TE--------------

associated Completion Time LCO 3.0.4.a is not not met. applicable when entering MODE 3. ------------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Brunswick Unit 1 3.5-13 Amendment No. 283 I SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 Brunswick Unit 1 SURVEILLANCE Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled with water. --------------------------------NOTE-------------------------------

Not required to be met for system vent flow paths opened under administrative control. Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

---

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

1. Use of auxiliary steam for the performance of the SR is not allowed. 2. Not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor steam pressure is adequate to perform the test. Verify, with reactor pressure?:

945 psig and :,; 1045 psig, the RCIC pump can develop a flow rate ?: 400 gpm against a system head corresponding to reactor pressure.

3.5-14 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 283 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.3.4 SR 3.5.3.5 Brunswick Unit 1 SURVEILLANCE

---

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

1. Use of auxiliary steam for the performance of the SR is not allowed with reactor pressure 150 psig. 2. Not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor steam pressure is adequate to perform the test. Verify, with turbine inlet pressure~

135 psig and::;; 165 psig, the RCIC pump can develop a flow rate 400 gpm against a system head corresponding to an equivalent reactor pressure.

---

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

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal. 3.5-15 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 283 I ACTIONS (continued)

CONDITION D. One or more penetration flow paths with one or more MSIVs not within MSIV leakage rate limits. E. Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3. 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. Brunswick Unit 1 REQUIRED ACTION D.1 Restore leakage rate to within limit. E.1 Be in MODE 3. AND E.2 Be in MODE4. F.1 Initiate action to restore valve(s) to OPERABLE status. 3.6-10 PCIVs 3.6.1.3 COMPLETION TIME 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 12 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Immediately Amendment No. 283

3.6 CONTAINMENT

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

APPLICABILITY:

MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in MODE 1, 2, containment to OPERABLE or 3. status. B. Required Action and 8.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE3. -----------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Secondary containment C.1 --------------NOTE-------------

inoperable during movement LCO 3.0.3 is not applicable.

of recently irradiated fuel ------------------------------------

assemblies in the secondary containment.

Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

Brunswick Unit 1 3.6-28 Amendment No. 283 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS SR 3.6.4.1.1 SR 3.6.4.1.2 SR 3.6.4.1.3 Brunswick Unit 1 SURVEILLANCE Verify all secondary containment equipment hatches are closed and sealed. Verify one secondary containment access door is closed in each access opening. Verify each SGT subsystem can maintain 0.25 inch of vacuum water gauge in the secondary containment for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate ::;; 3000 cfm. 3.6-29 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 283

3.6 CONTAINMENT

SYSTEMS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs) LCO 3.6.4.2 Each SCIO ~hall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, SCIDs 3.6.4.2 During movement of recently irradiated fuel assemblies in the secondary containment, ACTIONS ----------------------------------------------------------

NO TES ----------------------------------------------------------

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 SCIDs. CONDITION A. One or more penetration flow paths with one SCIO inoperable.

Brunswick Unit 1 A.1 REQUIRED ACTION COMPLETION TIME Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow path by use of at least one closed and de-activated automatic damper, closed manual damper, or blind flange. (continued) 3.6-30 Amendment No. 283 ACTIONS (continued)

CONDITION D. Required Action and D.1 associated Completion Time REQUIRED ACTION -------------NOTE--------------

LCO 3.0.3 is not applicable.

SCIDs 3.6.4.2 COMPLETION TIME of Condition A or B not met during movement of recently irradiated fuel assemblies in Suspend movement of Immediately the secondary containment.

recently irradiated fuel assemblies in the secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.4.2.1 Verify the isolation time of each automatic SCIO is within limits. SR 3.6.4.2.2 Verify each automatic SCIO actuates to the isolation position on an actual or simulated actuation signal. Brunswick Unit 1 3.6-32 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 283 I

3.6 CONTAINMENT

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

APPLICABILITY:

MODES 1, 2, and 3, SGT System 3.6.4.3 During movement of recently irradiated fuel assemblies in the secondary containment, ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SGT subsystem A.1 Restore SGT subsystem to 7 days inoperable in MODE 1, 2 or OPERABLE status. 3. B. Required Action and 8.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3. OR -----------------------------------

Two SGT subsystems Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable in MODE 1, 2, or 3. (continued)

Brunswick Unit 1 3.6-33 Amendment No. 283 A CTIONS (continued)

CONDITION C. One SGT subsystem inoperable during movement of recently irradiated fuel assemblies in the secondary containment.

D. Required Action and associated Completion Time of Condition C not met. Brunswick Unit 1 REQUIRED ACTION C.1 Restore SGT subsystem to OPERABLE status. ---------------------NOTE------------------

LCO 3.0.3 is not applicable.

---

D. 1 Place OPERABLE SGT subsystem in operation.

OR D.2 Suspend movement of recently irradiated fuel assemblies in secondary containment.

3.6-34 SGT System 3.6.4.3 COMPLETION TIME 31 days Immediately Immediately (continued)

Amendment No. 283 ACTIONS (continued)

CONDITION E. Two SGT subsystems E.1 inoperable during movement REQUIRED ACTION --------------NOTE-------------

LCO 3.0.3 is not applicable.

SGT System 3.6.4.3 COMPLETION TIME of recently irradiated fuel assemblies in the secondary containment.

Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 Brunswick Unit 1 SURVEILLANCE Operate each SGT subsystem for ;;:: 15 continuous minutes with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP). Verify each SGT subsystem actuates on an actual or simulated initiation signal. 3.6-35 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Amendment No. 283

3. 7 PLANT SYSTEMS 3.7.3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

CREV System 3.7.3 -------------------------------------NOTE----------------------------------------

The main control room envelope (CRE) boundary may be opened intermittently under administrative control. APPLICABILITY:

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

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons other to OPERABLE status. than Condition B. B. One or more CREV 8.1 Initiate action to implement Immediately subsystems inoperable due mitigating actions. to inoperable CRE Boundary in Mode 1, 2, or 3. AND 8.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND 8.3 Restore CRE boundary to 90 days Operable status. (continued)

Brunswick Unit 1 3.7-11 Amendment No. 283 A CTIONS (continued)

CONDITION C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or 3. OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B. D. Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

Brunswick Unit 1 REQUIRED ACTION C. 1 -------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 3. -----------------------------------

Be in MODE 3. -------------------NOTE---------------------

LCO 3.0.3 is not applicable.

---

D. 1 Place OPERABLE CREV subsystem in radiation/smoke protection mode. OR D.2.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE ALTERATIONS.

3.7-12 CREV System 3.7.3 COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Immediately Immediately Immediately (continued)

Amendment No. 283 ACTIONS (continued)

E. CONDITION Two CREV subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

OR REQUIRED ACTION -------------------NOTE---------------------

LCO 3.0.3 is not applicable.

E.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

One or more CREV AND subsystems inoperable due to an inoperable CRE E.2 boundary during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

Suspend CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTS SR 3.7.3.1 SR 3.7.3.2 Brunswick Unit 1 SURVEILLANCE Operate each CREV subsystem for 15 continuous minutes. Perform required CREV filter testing in accordance with the Ventilation Filter Testing Program (VFTP). 3.7-13 CREV System 3.7.3 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP (continued)

Amendment No. 283

3.7 PLANT

SYSTEMS Control Room AC System 3.7.4 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE AL TERA TIONS. ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable.

subsystem to OPERABLE status. B. Two control room AC 8.1 Restore one inoperable 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystems inoperable.

control room AC subsystem to OPERABLE status. C. Required Action and C. 1 -------------NO TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met applicable when entering in MODE 1, 2, or 3. MODE 3. -----------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

Brunswick Unit 1 3.7-15 Amendment No. 283 ACTIONS (continued)

CONDITION D. Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

E. Three control room AC subsystems inoperable in MODE 1, 2, or 3. Brunswick Unit 1 Control Room AC System 3.7.4 COMPLETION REQUIRED ACTION TIME -------------------NOTE---------------------

LCO 3.0.3 is not applicable.

---

0.1 Place

OPERABLE control Immediately room AC subsystem(s) in operation.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately AL TERA TIONS. E.1 -------------NO TE--------------

LCO 3.0.4.a is not applicable when entering MODE 3. -----------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued) 3.7-16 Amendment No. 283 Control Room AC System 3.7.4 ACTIONS (continued)

F. CONDITION Three control room AC subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION -------------------NOTE---------------------

LCO 3.0.3 is not applicable.

F. 1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

SURVEILLANCE SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load. Brunswick Unit 1 3.7-17 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 283 ACTIONS

• AC Sources-Shutdown 3.8.2 -----------------------------------------------------------

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION A. One or more required offsite ----------------------NOTE-------------------

circuits inoperable.

Enter applicable Condition and Required Actions of LCO 3.8.8, with one or more required 4.16 kV emergency buses de-energized as a result of Condition A. COMPLETION TIME A.1 Declare affected required Immediately feature(s), with no offsite Brunswick Unit 1 OR A.2.1 power available, inoperable.

Suspend CORE ALTERATIONS.

Immediately A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment. (continued) 3.8-17 Amendment No. 283 ACTIONS CONDITION A. (continued)

A.2.3 B. One required DG 8.1 inoperable.

OR 8.2.1 AND B.2.2 AND B.2.3 Brunswick Unit 1 REQUIRED ACTION Initiate action to restore required offsite power circuit to OPERABLE status. Declare affected required feature(s) with no DG available inoperable.

Suspend CORE ALTERATIONS.

Suspend movement of AC Sources-Shutdown

3.8.2 COMPLETION

TIME Immediately Immediately Immediately Immediately irradiated fuel assemblies in secondary containment.

Initiate action to restore Immediately required DG to OPERABLE status. (continued) 3.8-18 Amendment No. 283 I AC Sources-Shutdown

3.8.2 ACTIONS

(continued)

CONDITION REQUIRED ACTION 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. SURVEILLANCE REQUIREMENTS SR 3.8.2.1 SURVEILLANCE

---

NO TE---------------------------------U n less required to be performed by Unit 2 Specification 3.8.1, the following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.14.

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

Brunswick Unit 1 3.8-19 Amendment No. 283 I ACTIONS CONDITION A. (continued)

REQUIRED ACTION DC Sources-Shutdown

3.8.5 COMPLETION

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

A.2.3 Initiate action to restore required DC electrical power subsystems to OPERABLE status. Immediately Brunswick Unit 1 3.8-28 Amendment No. 283 I ACTIONS Distribution Systems-Shutdown

3.8.8 CONDITION

REQUIRED ACTION COMPLETION TIME A. (continued)

A.2.3 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status. A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SR 3.8.8.1 Brunswick Unit 1 SURVEILLANCE Verify correct breaker alignments and indicated power availability to required AC and DC electrical power distribution subsystems.

3.8-39 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 283 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS.

LLC DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 311 Renewed License No. DPR-62 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment filed by Duke Energy Progress, LLC, dated June 29, 2017, as supplemented by letters dated January 4 and 23, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-62 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 311, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented prior to the 2019 Unit 2 refueling outage.

Attachment:

FOR THE NUCLEAR REGULATORY COMMISSION Brian W. Tindell, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Changes to the Renewed Operating License and Technical Specifications Date of Issuance:

Apr i 1 1 3 , 2 o 1 8 ATTACHMENT TO LICENSE AMENDMENT NO. 311 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace Page 6 of Renewed Facility Operating License No. DPR-62 with the attached revised Page 6. Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove Pages 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 1.1-8 3.3-35 3.3-36 3.3-41 3.3-42 3.3-43 3.3-44 3.3-51 3.3-58 3.3-62 3.3-65 3.5-1 3.5-8 3.5-9 3.5-10 3.5-11 3.5-12 3.5-13 3.5-14 3.6-10 3.6-28 3.6-29 Insert Pages 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 1.1-8 3.3-35 3.3-36 3.3-41 3.3-42 3.3-43 3.3-44 3.3-48a 3.3-48b 3.3-48c 3.3-51 3.3-58 3.3-62 3.3-65 3.5-1 3.5-8 3.5-9 3.5-10 3.5-11 3.5-12 3.5-13 3.5-14 3.5-15 3.6-10 3.6-28 3.6-29 ATTACHMENT TO LICENSE AMENDMENT NO. 311 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 3.6-30 3.6-32 3.6-33 3.6-34 3.6-35 3.7-11 3.7-12 3.7-13 3.7-15 3.7-16 3.7-17 3.8-17 3.8-18 3.8-19 3.8-28 3.8-39 {TS pages) -Continued 3.6-30 3.6-32 3.6-33 3.6-34 3.6-35 3.7-11 3.7-12 3.7-13 3.7-15 3.7-16 3.7-17 3.8-17 3.8-18 3.8-19 3.8-28 3.8-39 (c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above. 2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation.

The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180 1 h day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 311, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 311

1.1 Definitions

DOSE EQUIVALENT 1-131 (continued)

DRAIN TIME Brunswick Unit 2 Definitions 1.1 Submersion, and Ingestion," 1989 and FGR 12, "External Exposure to Radionuclides in Air, Water, and Soil," 1993. 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 (T AF) 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 T AF except: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are 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 T AF 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) 1.1-3 Amendment No. 311

1.1 Definitions

DRAIN TIME (continued)

EMERGENCY CORE COOLING SYSTEM(ECCS)RESPONSE TIME INSERVICE TESTING PROGRAM d) No additional draining events occur; and Definitions 1.1 e) Realistic cross-sectional areas and drain rates are used. A bounding DRAIN TIME may be used in lieu of a calculated value. The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION INSTRUMENTATION The ISOLATION INSTRUMENTATION RESPONSE TIME RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves receive the isolation signal (e.g., de-energization of the MSIV solenoids).

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

LEAKAGE Brunswick Unit 2 LEAKAGE shall be: a. Identified LEAKAGE 1. LEAKAGE into the drywell, such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or 2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE; (continued) 1.1-4 Amendment No. 311

1.1 Definitions

LEAKAGE (continued)

LINEAR HEAT GENERATION RATE (LHGR) b. Unidentified LEAKAGE Definitions 1.1 All LEAKAGE into the drywell that is not identified LEAKAGE; c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall. The LHGR shall be the heat generation rate per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length. LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST of all required logic components (i.e., all required relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY.

The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested. MINIMUM CRITICAL POWER RATIO (MCPR) MODE Brunswick Unit 2 The MCPR shall be the smallest critical power ratio (CPR) that exists in the core. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power. A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel. (continued) 1.1-5 Amendment No. 311

1.1 Definitions

(continued)

OPERABLE-OPERABILITY RATED THERMAL POWER (RTP) REACTOR PROTECTION SYSTEM(RPS)RESPONSE TIME SHUTDOWN MARGIN (SDM) Brunswick Unit 2 Definitions 1.1 A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 2923 Mwt. The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that: a. The reactor is xenon free; b. The moderator temperature is~ 68°F, corresponding to the most reactive state; and c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM. (continued) 1.1-6 Amendment No. 311

1.1 Definitions

(continued)

STAGGERED TEST BASIS THERMAL POWER TURBINE BYPASS SYSTEM RESPONSE TIME Brunswick Unit 2 Definitions 1.1 A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. The TURBINE BYPASS SYSTEM RESPONSE TIME consists of two components:

a. The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established; and b. The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

1.1-7 Amendment No. 311 MODE TITLE 1 Power Operation 2 Startup 3 Hot Shutdown<a>

4 Cold Shutdown<a>

5 Refueling

Table 1.1-1 (page 1 of 1) MODES REACTOR MODE SWITCH POSITION Run Refue1<a>

or Startup/Hot Standby Shutdown Shutdown Shutdown or Refuel (a) All reactor vessel head closure bolts fully tensioned.

Definitions

1.1 AVERAGE

REACTOR COOLANT TEMPERATURE (OF) NA NA > 212 :s; 212 NA (b) One or more reactor vessel head closure bolts less than fully tensioned.

Brunswick Unit 2 1.1-8 Amendment No. 311

3.3 INSTRUMENTATION

3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation ECCS Instrumentation 3.3.5.1 LCO 3.3.5.1 The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.1-1.

ACTIONS -----------------------------------------------------------

N OT E -----------------------------------------------------------

Se pa rate Condition entry is allowed for each channel. COMPLETION CONDITION REQUIRED ACTION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable.

referenced in Table 3.3.5.1-1 for the channel. B. As required by Required B.1 ------------NO TE---------------

Action A.1 and referenced in Only applicable for Table 3.3.5.1-1.

Functions 1.a, 1.b, 2.a, and 2.b. -----------------------------------

Declare supported 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from feature(s) inoperable when discovery of loss of its redundant feature ECCS initiation capability initiation capability is for feature(s) in inoperable.

both divisions AND (continued)

Brunswick Unit 2 3.3-35 Amendment No. 311 ACTIONS CONDITION B. (continued) 8.2 AND 8.3 C. As required by Required C.1 Action A. 1 and referenced in Table 3.3.5.1-1.

AND C.2 Brunswick Unit 2 REQUIRED ACTION -------------NOTE--------------

Only applicable for Functions 3.a and 3.b. -----------------------------------

Declare High Pressure Coolant Injection (HPCI) System inoperable.

Place channel in trip. ------------NO TE---------------

Only applicable for Functions 1.c, 1.d, 2.c, 2.d, and 2.f. -----------------------------------

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

Restore channel to OPERABLE status. 3.3-36 ECCS Instrumentation 3.3.5.1 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of HPCI initiation capability 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1 hour from discovery of loss of initiation capability for feature(s) in both divisions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (continued)

Amendment No. 311 FUNCTION 1. Core Spray System a. Reactor Vessel Water Level-Low Level 3 b. Drywell Pressure-High C. Reactor Steam Dome Pressure-Low

d. Core Spray Pump Start-Time Delay Relay 2. Low Pressure Coolant Injection (LPCI) System a. Reactor Vessel Water Level-Low Level 3 b. Drywall Pressure-High Brunswick Unit 2 Table3.3.5.1-1

{page 1 of4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED CONDITIONS FUNCTION ACTIONA.1 1,2,3 4 B 1,2,3 4 B 1,2,3 4 C 1,2,3 2 C 1 per pump 1,2,3 4 B 1,2,3 4 B 3.3-41 ECCS Instrumentation 3.3.5.1 SURVEILLANCE ALLOWABLE REQUIREMENTS VALUE SR 3.3.5.1.1 13 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1

,; 1.8 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 402 psig SR 3.3.5.1.2 and SR 3.3.5.1.3

,; 425 psig SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.4 14 seconds SR 3.3.5.1.5 and SR 3.3.5.1.6

,; 16 seconds SR 3.3.5.1.1

?

13 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1

,; 1.8 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued)

Amendment No. 311 Table 3.3.5.1-1 (page 2 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED FUNCTION CONDITIONS FUNCTION ACTIONA.1

2. LPCI System (continued)

C. Reactor Steam Dome Pressure-Low 1,2,3 4 C d. Reactor Steam Dome Pressure-Low 1(a),2(a), 4 C (Recirculation Pump Discharge Valve 3fa) Permissive)

e. Reactor Vessel Shroud Level 1,2,3 2 B f. RHR Pump Start-Time Delay Relay 1,2,3 4 C 1 per pump 3. High Pressure Coolant Injection (HPCI) System a. Reactor Vessel Water Level-Low 1, 4 B Level 2 2(b)' 3(b) b. Drywall Pressure-High 1, 4 B 2'bl,3(b) (a) With associated recirculation pump discharge valve or recirculation pump discharge bypass valve open. (b) With reactor steam dome pressure > 150 psig. Brunswick Unit 2 3.3-42 ECCS Instrumentation 3.3.5.1 SURVEILLANCE ALLOWABLE REQUIREMENTS VALUE SR 3.3.5.1.1 2 402 psig SR 3.3.5.1.2 and SR 3.3.5.1.3 s425 psig SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 2 302 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 2:' -50 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.4 9 seconds SR 3.3.5.1.5 and SR 3.3.5.1.6 11 seconds SR 3.3.5.1.1 2 101 inches SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 SR 3.3.5.1.1 s 1.8 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued)

Amendment No. 311 ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE 3. HPCI System (continued)

c. Reactor Vessel Water Level-High 1, 2 C SR 3.3.5.1.1 "207 inches 2'". 3<bJ SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Condensate Storage Tank Level-Low 1, 2 D SR 3.3.5.1.2

, 23 feet 4 inches 2<*l, 3(b) SR 3.3.5.1.4 SR 3.3.5.1.5

e. Suppression Chamber Water Level-1, 2 D SR 3.3.5.1.2 5"-2feet High 2'b)' 3(b) SR 3.3.5.1.4 SR 3.3.5.1.5

4. Automatic Depressurization System (ADS) Trip System A a. Reactor Vessel Water Level-Low 1, 2 E SR 3.3.5.1.1

, 13 inches Level 3 2(b)' 3(b) SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

b. ADS Timer 1, F SR 3.3.5.1.4 " 108 seconds ibl,3(b) SR 3.3.5.1.5 SR 3.3.5.1.6 C. Reactor Vessel Water Level-Low 1, E SR 3.3.5.1.1

, 153 inches Level 1 2(bl, 3(b) SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Core Spray Pump Discharge 1, 2 F SR 3.3.5.1.2

, 102 psig Pressure-High 2(b)' 3(b) SR 3.3.5.1.4 and SR 3.3.5.1.5 "130 psig e. RHR (LPCI Mode) Pump Discharge 1, 4 F SR 3.3.5.1.2

, 102 psig Pressure-High 2, 3(b) 2 per pump SR 3.3.5.1.4 and SR 3.3.5.1.5 "130 psig (continued) (b) With reactor steam dome pressure>

150 psig. Brunswick Unit 2 3.3-43 Amendment No. 311 ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 4) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE 5. ADS Trip System B a. Reactor Vessel Water Level-Low 1, 2 E SR 3.3.5.1.1 13 inches Level 3 2'bl, 3(b) SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

b. ADS Timer 1, F SR 3.3.5.1.4 s 108 seconds 2'b)I 3(b) SR 3.3.5.1.5 SR 3.3.5.1.6

c. Reactor Vessel Water Level-Low 1, E SR 3.3.5.1.1 153 inches Level 1 2<bl, 3(b) SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Core Spray Pump Discharge 1, 2 F SR 3.3.5.1.2 102 psig Pressur&-High 2'bl,3(b)

SR 3.3.5.1.4 and SR 3.3.5.1.5 s 130 psig e. RHR (LPCI Mode) Pump Discharge 1, 4 F SR 3.3.5.1.2 102 psig Pressure-High ibl,3(b) 2 per pump SR 3.3.5.1.4 and SR 3.3.5.1.5 s 130 psig (b) With reactor steam dome pressure>

150 psig. Brunswick Unit 2 3.3-44 Amendment No. 311

3.3 INSTRUMENTATION

RPV Water Inventory Control Instrumentation 3.3.5.3 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. COMPLETION CONDITION REQUIRED ACTION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable.

referenced in Table 3.3.5.3-1 for the channel. B. As required by Required B.1 Declare associated Immediately Action A.1 and referenced in penetration flow path(s) Table 3.3.5.3-1.

incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by Required 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 /> Action A. 1 and referenced in Table 3.3.5.3-1. (continued)

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

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Declare associated low Immediately associated Completion Time pressure ECCS of Condition C not met. injection/spray subsystem inoperable.

SURVEILLANCE REQUIREMENTS

---

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

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

SURVEILLANCE SR 3.3.5.3.1 Perform CHANNEL CHECK. SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. Brunswick Unit 2 3.3-48b FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 311 RPV Water Inventory Control Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1) RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE 1. Core Spray System a. Reactor Steam Dome 4, 5 4(a) C SR 3.3.5.3.1 s 425 psig Pressure-Low SR 3.3.5.3.2

2. Low Pressure Coolant Injection (LPCI) System a. Reactor Steam Dome 4,5 4(a) C SR 3.3.5.3.1 s 425 psig Pressure-Low SR 3.3.5.3.2

3. RHR System Isolation

a. Reactor Vessel Water (b) 2 in one trip B SR 3.3.5.3.1 2 153 inches Level-Low Level 1 system SR 3.3.5.3.2

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (b) 2 in one trip B SR 3.3.5.3.1 2 101 inches Level-Low Level 2 system SR 3.3.5.3.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control." (b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME. Brunswick Unit 2 3.3-48c Amendment No. 311 A CTIONS (continued)

CONDITION I. As required by Required 1.1 Action C.1 and referenced in Table 3.3.6.1-1.

OR 1.2 J. As required by Required J.1 Action C.1 and referenced in Table 3.3.6.1-1.

Brunswick Unit 2 Primary Containment Isolation Instrumentation 3.3.6.1 COMPLETION REQUIRED ACTION TIME Declare associated 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> standby liquid control subsystem (SLC) inoperable.

Isolate the Reactor Water 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Cleanup (RWCU) System. Initiate action to restore Immediately channel to OPERABLE status. 3.3-51 Amendment No. 311 FUNCTION 6. RHR Shutdown Cooling System Isolation

a. Reactor Steam Dome Pressure-High

b. Reactor Vessel Water Level--Low Level 1 7. Traversing In-core Probe Isolation

a. Reactor Vessel Water Level -Low Level 1 b. Drywall Pressure -High Brunswick Unit 2 Primary Containment Isolation Instrumentation 3.3.6.1 Table3.3.6.1-1 (page5of5)

Primary Containment Isolation Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1,2,3 3 1,2,3 1,2,3 REQUIRED CHANNELS PER TRIP SYSTEM 2 2 2 3.3-58 CONDITIONS REFERENCED FROM REQUIRED ACTIONC.1 F G G SURVEILLANCE REQUIREMENTS SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.7 SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1. 7 SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1. 7 ALLOWABLE VALUE ,c 137 psig ;, 153 inches "153 inches s 1.8 psig Amendment No. 311 FUNCTION 1. Reactor Vessel Water Level-Low Level 2 2. Drywall Pressure-High

3. Reactor Building Exhaust Radiation-High Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1) Secondary Containment Isolation Instrumentation APPLICABLE REQUIRED MODES OR OTHER CHANNELS SPECIFIED PER SURVEILLANCE ALLOWABLE CONDITIONS TRIP SYSTEM REQUIREMENTS VALUE 1,2,3 2 SR 3.3.6.2.1 "101 inches SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5 1,2,3 2 SR 3.3.6.2.1

<; 1.8 psig SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5 1,2,3 SR 3.3.6.2.1

<; 16 mR/hr (a) SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.5 (a) During movement of recently irradiated fuel assemblies in secondary containment.

Brunswick Unit 2 3.3-62 Amendment No. 311 Table 3.3.7.1-1 (page 1 of 1) GREV System Instrumentation 3.3.7.1 Control Room Emergency Ventilation (CREV) System Isolation Instrumentation FUNCTION 1. Control Building Air Intake Radiation

-High 2. Unit 2 Secondary Containment Isolation

-CREV Auto-Start APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1,2,3 (a) 1, 2, 3 REQUIRED CHANNELS PER TRIP SYSTEM 2 2 SURVEILLANCE REQUIREMENTS SR 3.3.7.1.1 SR 3.3.7.1.2 SR 3.3.7.1.3 SR 3.3.7.1.4 SR 3.3.6.2.2 SR 3.3.6.2.5 (a) During movement of recently irradiated fuel assemblies in secondary containment.

ALLOWABLE VALUE :, 27 mR/hr (b) (b) The auto-start signal is provided from Secondary Containment Isolation logic and does not depend on a specific instrument; for Secondary Containment Isolation Instrumentation, refer to Table 3.3.6.2-1.

Brunswick Unit 2 3.3-65 Amendment No. 311 ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure :,;; 150 psig. ACTIONS -----------------------------------------------------------

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

LCO 3.0.4.b is not applicable to HPCI. CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray subsystem ECCS injection/spray inoperable.

subsystem to OPERABLE status. OR One low pressure coolant injection (LPCI) pump in each subsystem inoperable.

B. One LPCI pump inoperable.

8.1 Restore

LPCI pump to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status. AND OR One core spray (CS) subsystem inoperable.

8.2 Restore

CS subsystem to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status. (continued)

Brunswick Unit 2 3.5-1 Amendment No. 311 RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. One low pressure ECCS injection/spray subsystem shall be OPERABLE.

---

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY:

MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> injection/spray subsystem injection/spray subsystem inoperable.

to OPERABLE status. 8. Required Action and 8.1 Initiate action to establish a Immediately associated Completion Time method of water injection of Condition A not met. capable of operating without offsite electrical power. C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and C.1 Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 8 hours. containment boundary is capable of being established in less than the DRAIN TIME. AND (continued)

Brunswick Unit 2 3.5-8 Amendment No. 311 I ACTIONS CONDITION C. (continued)

C.2 AND C.3 D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. 0.1 AND D.2 AND Brunswick Unit 2 RPV Water Inventory Control

3.5.2 REQUIRED

ACTION COMPLETION TIME Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME. Verify one standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment subsystem is capable of being placed in operation in less than the DRAIN TIME. --------------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 Immediately an additional method of water injection with water sources capable of maintaining RPV water level > T AF for :::: 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Initiate action to establish Immediately secondary containment boundary. (continued) 3.5-9 Amendment No. 311 RPV Water Inventory Control 3.5.2 SACTIONS CONDITION REQUIRED ACTION D. (continued)

0.3 Initiate

action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room. AND 0.4 Initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore associated Completion Time DRAIN TIME to~ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 />. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.2.1 SR 3.5.2.2 Brunswick Unit 2 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Verify, for a required low pressure coolant injection (LPCI) subsystem, the suppression pool water level is -31 inches. 3.5-10 COMPLETION TIME Immediately Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 311 RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.3 SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 Brunswick Unit 2 SURVEILLANCE 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. Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water. -------------------------------NO TE------------------------------

N ot 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.

Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes. 3.5-11 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 311 I RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.7 SR 3.5.2.8 Brunswick Unit 2 SURVEILLANCE Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal. -------------------------------NOTE--------------------------------

Vesse I injection/spray may be excluded.

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

3.5-12 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 311 I RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS -----------------------------------------------------------

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

LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable.

A.1 Verify by administrative Immediately means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status. B. Required Action and B.1 --------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not not met. applicable when entering MODE 3. ------------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Brunswick Unit 2 3.5-13 Amendment No. 311 SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 Brunswick Unit 2 SURVEILLANCE Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled with water. ----------------------------------NOTE-----------------------------

Not required to be met for system vent flow paths opened under administrative control. Verify each RCIC System 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.

---

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

1. Use of auxiliary steam for the performance of the SR is not allowed. 2. Not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor steam pressure is adequate to perform the test. Verify, with reactor pressure 945 psig and 1045 psig, the RCIC pump can develop a flow rate 400 gpm against a system head corresponding to reactor pressure.

3.5-14 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 311 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.3.4 SR 3.5.3.5 Brunswick Unit 2 SURVEILLANCE

---

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

1. Use of auxiliary steam for the performance of the SR is not allowed with reactor pressure 150 psig. 2. Not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor steam pressure is adequate to perform the test. Verify, with turbine inlet pressure~

135 psig and::; 165 psig, the RCIC pump can develop a flow rate 400 gpm against a system head corresponding to an equivalent reactor pressure.

---

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

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal. 3.5-15 RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 311 A CTIONS ( continued)

CONDITION D. One or more penetration flow paths with one or more MSIVs not within MSIV leakage rate limits. E. Required Action and associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3. 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. Brunswick Unit 2 REQUIRED ACTION D.1 Restore leakage rate to within limit. E.1 Be in MODE 3. AND E.2 Be in MODE 4. F.1 Initiate action to restore valve(s) to OPERABLE status. 3.6-10 PCIVs 3.6.1.3 COMPLETION TIME 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 12 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Immediately Amendment No. 311

3.6 CONTAINMENT

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

APPLICABILITY:

MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in MODE 1, 2, containment to or 3. OPERABLE status. B. Required Action and 8.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3. -----------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Secondary containment C.1 -------------NOTE--------------

inoperable during movement LCO 3.0.3 is not applicable.

of recently irradiated fuel -----------------------------------

assemblies in the secondary containment.

Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

Brunswick Unit 2 3.6-28 Amendment No. 311 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS SR 3.6.4.1.1 SR 3.6.4.1.2 SR 3.6.4.1.3 Brunswick Unit 2 SURVEILLANCE Verify all secondary containment equipment hatches are closed and sealed. Verify one secondary containment access door is closed in each access opening. Verify each SGT subsystem can maintain 0.25 inch of vacuum water gauge in the secondary containment for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate:=;; 3000 cfm. 3.6-29 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 311

3.6 CONTAINMENT

SYSTEMS 3.6.4.2 Secondary Containment Isolation Dampers (SCIDs) LCO 3.6.4.2 Each SCID shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, SCIDs 3.6.4.2 During movement of recently irradiated fuel assemblies in the secondary containment.

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 SCIDs. CONDITION A. One or more penetration flow paths with one SCID inoperable.

Brunswick Unit 2 A.1 REQUIRED ACTION COMPLETION TIME Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow path by use of at least one closed and de-activated automatic damper, closed manual damper, or blind flange. (continued) 3.6-30 Amendment No. 311 ACTIONS ( continued)

CONDITION D. Required Action and D.1 associated Completion Time of Condition A or B not met during movement of recently irradiated fuel assemblies in the secondary containment.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION --------------NOTE--------------

L CO 3.0.3 is not applicable.

Suspend movement of recently irradiated fuel assemblies in the secondary containment.

SURVEILLANCE SR 3.6.4.2.1 Verify the isolation time of each automatic SCIO is within limits. SR 3.6.4.2.2 Verify each automatic SCIO actuates to the isolation position on an actual or simulated actuation signal. Brunswick Unit 2 3.6-32 SCIDs 3.6.4.2 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. 311

3.6 CONTAINMENT

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

APPLICABILITY:

MODES 1, 2, and 3, SGT System 3.6.4.3 During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable in MODE 1, 2 or to OPERABLE status. 3. B. Required Action and 8.1 -------------NOTE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A not met. applicable when entering MODE 3. OR -----------------------------------

Two SGT subsystems Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable in MODE 1, 2, or 3. (continued)

Brunswick Unit 2 3.6-33 Amendment No. 311 ACTIONS (continued)

CONDITION C. One SGT subsystem inoperable during movement of recently irradiated fuel assemblies in the secondary containment.

D. Required Action and associated Completion Time of Condition C not met. Brunswick Unit 2 REQUIRED ACTION C.1 Restore SGT subsystem to OPERABLE status. --------------------NOTE-----------------

LCO 3.0.3 is not applicable.

---

D. 1 Place OPERABLE SGT subsystem in operation.

OR 0.2 Suspend movement of recently irradiated fuel assemblies in secondary containment.

3.6-34 SGT System 3.6.4.3 COMPLETION TIME 31 days Immediately Immediately (continued)

Amendment No. 311 ACTIONS (continued)

CONDITION E. Two SGT subsystems E.1 inoperable during movement REQUIRED ACTION -------------NOTE-------------

LCO 3.0.3 is not applicable.

SGT System 3.6.4.3 COMPLETION TIME of recently irradiated fuel assemblies in the secondary containment.

Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 Brunswick Unit 2 SURVEILLANCE Operate each SGT subsystem for 15 continuous minutes with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP). Verify each SGT subsystem actuates on an actual or simulated initiation signal. 3.6-35 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program Amendment No. 311

3. 7 PLANT SYSTEMS 3. 7 .3 Control Room Emergency Ventilation (CREV) System LCO 3.7.3 Two CREV subsystems shall be OPERABLE.

CREV System 3.7.3 -------------------------------------NO TE----------------------------------------

The main control room envelope (CRE) boundary may be opened intermittently under administrative control. APPLICABILITY:

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

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One CREV subsystem A.1 Restore CREV subsystem 7 days inoperable for reasons other to OPERABLE status. than Condition B. B. One or more CREV B.1 Initiate action to implement Immediately subsystems inoperable due mitigating actions. to inoperable CRE Boundary in Mode 1, 2, or 3. AND B.2 Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits. AND B.3 Restore CRE boundary to 90 days Operable status. (continued)

Brunswick Unit 2 3.7-11 Amendment No. 311 ACTIONS (continued)

CONDITION C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or 3. OR Two GREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B. D. Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

Brunswick Unit 2 REQUIRED ACTION C.1 -------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 3. -----------------------------------

Be in MODE 3. -------------------NOTE---------------------

LCO 3.0.3 is not applicable.

---

D.1 Place OPERABLE GREV subsystem in radiation/smoke protection mode. OR D.2.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE ALTERATIONS.

3.7-12 GREV System 3.7.3 COMPLETION TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Immediately Immediately Immediately (continued)

Amendment No. 311 ACTIONS (continued)

E. CONDITION Two GREV subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

One or more GREV subsystems inoperable due REQUIRED ACTION -------------------NOTE---------------------

L CO 3.0.3 is not applicable.

E.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

to an inoperable CRE E.2 Suspend CORE ALTERATIONS.

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

SURVEILLANCE REQUIREMENTS SR 3.7.3.1 SR 3.7.3.2 Brunswick Unit 2 SURVEILLANCE Operate each GREV subsystem for :2'. 15 continuous minutes. Perform required GREV filter testing in accordance with the Ventilation Filter Testing Program (VFTP). 3.7-13 GREV System 3.7.3 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP (continued)

Amendment No. 311

3.7 PLANT

SYSTEMS Control Room AC System 3.7.4 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE AL TERA TIO NS. ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable.

subsystem to OPERABLE status. B. Two control room AC 8.1 Restore one inoperable 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystems inoperable.

control room AC subsystem to OPERABLE status. C. Required Action and C.1 -------------NO TE--------------

associated Completion Time LCO 3.0.4.a is not of Condition A or B not met applicable when entering in MODE 1, 2, or 3. MODE 3. -----------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

Brunswick Unit 2 3.7-15 Amendment No. 311 ACTIONS (continued)

CONDITION D. Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment or ~uring CORE ALTERATIONS.

E. Three control room AC subsystems inoperable in MODE 1, 2, or 3. Brunswick Unit 2 Control Room AC System 3.7.4 COMPLETION REQUIRED ACTION TIME -------------------NOTE---------------------

LCO 3.0.3 is not applicable.

---

D. 1 Place OPERABLE control Immediately room AC subsystem(s) in operation.

OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

E.1 -------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 3. -----------------------------------

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued) 3.7-16 Amendment No. 311 Control Room AC System 3.7.4 ACTIONS (continued)

F. CONDITION Three control room AC subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION -------------------NOTE---------------------

L CO 3.0.3 is not applicable.

F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

SURVEILLANCE SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load. Brunswick Unit 2 3.7-17 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 311 ACTIONS AC Sources-Shutdown 3.8.2 -----------------------------------------------------------

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION A. One or more required offsite ----------------------NOTE-------------------

circuits inoperable.

Enter applicable Condition and Required Actions of LCO 3.8.8, with one or more required 4.16 kV emergency buses de-energized as a result of Condition A. COMPLETION TIME A.1 Declare affected required Immediately feature(s), with no offsite Brunswick Unit 2 A.2.1 power available, inoperable.

Suspend CORE AL TERA TIONS. Immediately A.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment. (continued) 3.8-17 Amendment No. 311 ACTIONS CONDITION A. (continued)

A.2.3 B. One required DG 8.1 inoperable.

OR B.2.1 AND B.2.2 AND B.2.3 Brunswick Unit 2 REQUIRED ACTION Initiate action to restore required offsite power circuit to OPERABLE status. Declare affected required feature(s) with no DG available inoperable.

Suspend CORE ALTERATIONS.

Suspend movement of AC Sources-Shutdown

3.8.2 COMPLETION

TIME Immediately Immediately Immediately Immediately irradiated fuel assemblies in secondary containment.

Initiate action to restore Immediately required DG to OPERABLE status. (continued) 3.8-18 Amendment No. 311 AC Sources-Shutdown

3.8.2 ACTIONS

(continued)

CONDITION REQUIRED ACTION 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. SURVEILLANCE REQUIREMENTS SR 3.8.2.1 SURVEILLANCE

---

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

Unless required to be performed by Unit 1 Specification 3.8.1, the following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.14.

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

Brunswick Unit 2 3.8-19 Amendment No. 311 ACTIONS CONDITION A. (continued)

REQUIRED ACTION DC Sources-Shutdown

3.8.5 COMPLETION

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

A.2.3 Initiate action to restore required DC electrical power subsystems to OPERABLE status. Immediately Brunswick Unit 2 3.8-28 Amendment No. 311 ACTIONS Distribution Systems-Shutdown

3.8.8 CONDITION

REQUIRED ACTION COMPLETION TIME A. (continued)

A.2.3 Initiate actions to restore Immediately required AC and DC electrical power distribution subsystems to OPERABLE status. A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SR 3.8.8.1 Brunswick Unit 2 SURVEILLANCE Verify correct breaker alignments and indicated power availability to required AC and DC electrical power distribution subsystems.

3.8-39 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 311 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 283 AND 311 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62 DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By application dated June 29, 2017 (Reference 1 ), as supplemented by letters dated January 4 and 23, 2018 (References 2 and 3, respectively), Duke Energy Progress, LLC (Duke Energy or the licensee) requested to adopt Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (Reference 4), for Brunswick Steam Electric Plant, Units 1 and 2 (BSEP). The safety evaluation (SE) for TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC or the Commission) on December 20, 2016 (Reference 5). The proposed changes would replace existing technical specification (TS) requirements associated with "operations with the potential for draining the reactor vessel" (OPDRV) with revised TSs providing alternative requirements for Reactor Pressure Vessel (RPV) Water Inventory Control (WIC). These alternative requirements would protect Safety Limit 2.1.1.3, which states "Reactor vessel water level shall be greater than the top of active irradiated fuel." Additionally, a new definition, "DRAIN TIME," would be added to the BSEP TS Section 1.1, "Definitions." Drain Time would establish requirements for the licensee to make RPV water level inventory determinations and to calculate RPV water inventory drain rates for MODE 4 (Cold Shutdown -Reactor Mode Switch in Shutdown and average reactor coolant temperature less than or equal to (s) 212 °F) and MODE 5 (Refueling

-Reactor Mode Switch in Shutdown or Refueling) outage related activities.

Adequate licensee management of secondary containment requirements or mitigation of certain emergency core cooling system (ECCS) safety injection/spray systems during MODE 4 and MODE 5 requires a properly calculated DRAIN TIME. The licensee has proposed several variations from the TS changes described in the applicable parts of TSTF-542, Revision 2, or the NRG-approved SE. These are explained in Section 2.2.5 and evaluated in Section 3.5 of this SE. The supplements dated January 4 and 23, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change Enclosure 3 the NRG staff's original proposed no significant hazards consideration determination as published in the Federal Register on September 12, 2017 (82 FR 42846).

2.0 REGULATORY EVALUATION

2.1 System

Description The boiling-water reactor (BWR) RPVs have a number of penetrations located below the top of active fuel {TAF). These penetrations provide entry for control rods, recirculation flow, and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release. During operation in MODE 1 (Power Operation

-Reactor Mode Switch in Run), MODE 2 (Startup -Reactor Mode Switch in Refuel or Startup/Hot Standby), and MODE 3 (Hot Shutdown -Reactor Mode Switch in Shutdown and average reactor coolant temperature greater than (>) 212 °F), the TSs for instrumentation and ECCS require operability of sufficient equipment to ensure large quantities of water will be injected into the vessel should the level decrease below the preselected value. These requirements are designed to mitigate the effects of a coolant accident (LOCA), but also provide protection for other accidents and transients that involve a water inventory loss. During BWR operation in MODE 4 and MODE 5, the high pressures and temperatures that could cause a LOCA are not present. During certain phases of refueling (MODE 5) a large volume of water is available above the RPV (i.e., the RPV head is removed, the water level is greater than or equal to(~) 21 feet 10 inches over the top of the RPV flange, and the spent fuel storage pool gates are removed).

The large volume of water available in and above the RPV (during much of the time when in MODE 5) provides time for operator detection and manual operator action to stop and mitigate an RPV draining event. However, at other times during a refueling outage, typically during Cold Shutdown (MODE 4) or Refueling (MODE 5), there may be a potential for significant drainage paths from certain outage activities, human error, and other events when it is more likely to have some normally available equipment, instrumentation, and systems inoperable due to maintenance and outage activities.

There may not be as much time for operator action as compared to times when there are large volumes of water above the RPV. In comparison to MODEs 1, 2, and 3, with high temperatures and pressures (especially in MODEs 1 and 2), MODEs 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the potential for sudden loss of large volumes of water due to a LOCA is not expected, operators monitor for BWR RPV water level decrease from potential significant or unexpected drainage paths. These potential drainage paths in MODEs 4 and 5 generally would require less water replacement capability to maintain water above TAF. To address the drain down potential during MODEs 4 and 5, the current BSEP TSs contain specifications that are applicable during an OPDRV, or require suspension of OPDRVs if certain equipment is inoperable.

The term OPDRV is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees.

The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIG TS with attendant equipment operability requirements, required actions, and surveillance requirements (SRs) and deleting references to OPDRVs throughout the TSs. 2.2 Proposed TS Changes Section 2.2.1 discusses the proposed addition of a new definition, "DRAIN TIME" (evaluated below in Section 3.1 ). Section 2.2.2 discusses the proposed revisions to TS 3.3, "Instrumentation," including the proposed revisions to TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation" (including TS Table 3.3.5.1-1

), the proposed addition of new TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" (including TS Table 3.3.5.3-1

), and the proposed revisions to TS 3.3.6.1, "Primary Containment Isolation Instrumentation" (including TS Table 3.3.6.1-1).

Section 2.2.3 discusses the proposed revisions to TS 3.5, "Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System," including the proposed revisions to TS 3.5.2, "RPV Water Inventory Control" (evaluated below in Section 3.3.1 ). Section 2.2.4 discusses the proposed deletion of existing TS references to OPDRVs (evaluated below in Section 3.6). Section 2.2.5 discusses BSEP plant-specific variations to TSTF-542, Revision 2 (evaluated below in Section 3.5). 2.2.1 Addition of DRAIN TIME Definition The license amendment request (LAR) includes the following definition of "DRAIN TIME" that would be added to BSEP TS Section 1.1, "Definitions." 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 T AF except: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are 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 is 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; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used. A bounding DRAIN TIME may be used in lieu of a calculated value. 2.2.2 TS 3.3, "Instrumentation" The following subsections describe the existing and proposed changes to the BSEP TS Section 3.3, "Instrumentation." 2.2.2.1 Table 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation" Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1 and C.1, which states: "Only applicable in MODEs 1, 2, and 3." For Table 3.3.5.1-1, the licensee proposed to delete the Applicability in MODEs 4 and 5 because the instrumentation requirements during shutdown would be consolidated into the new TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation." MODEs 4 and 5 Applicability and associated requirements would be deleted for the following functions:

1. Core Spray System (a) Reactor Vessel Water Level -Low Level 3 ( c) Reactor Steam Dome Pressure -Low (d) Core Spray Pump Start-Time Delay Relay 2. Low Pressure Coolant Injection (LPCI) System (a) Reactor Vessel Water Level -Low Level 3 (c) Reactor Steam Dome Pressure -Low (f) RHR [Residual Heat Removal] Pump Start -Time Delay Relay Table 3.3.5.1-1, Footnote (a), which states, "When associated subsystem(s) are required to be OPERABLE," would be deleted. As a result, existing Footnotes (b) and (c) would become (a) and (b), respectively.

2.2.2.2 TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The proposed new TS 3.3.5.3 would contain functions that are comprised of requirements moved from TSs 3.3.5.1 and 3.3.6.1, as well as new requirements.

The proposed new TS 3.3.5.3 is shown below: 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 A.1 Enter the Condition Immediately inoperable.

referenced in Table 3.3.5.3-1 for the channel. B. As required by 8.1 Declare associated Immediately Required Action A.1 penetration flow path( s) and referenced in incapable of automatic Table 3.3.5.3-1.

isolation.

AND 8.2 Calculate DRAIN TIME. Immediately C. As required by 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 /> Required Action A.1 and referenced in Table 3.3.5.3-1.

D. Required Action and D.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C not injection/spray subsystem met. inoperable.

SURVEILLANCE REQUIREMENTS

---

NOTE-------*--------------------------------------------------------

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.

6 Table 3.3.5.3-1 (Page 1 of 1) RPV Water Inventory Control Instrumentation FUNCTION APPLICABLE REQUIRED CONDITIONS SURVEILLANCE ALLOWABLE MODES CHANNELS REFERENCED REQUIREMENTS VALUE OR OTHER PER FROM SPECIFIED FUNCTION REQUIRED CONDITIONS ACTION A.1 1. Core Spray System a. Reactor Steam 4,5 4(a) C SR 3.3.5.3.1 s 425 psig Dome Pressure -SR 3.3.5.3.2 Low 2. Low Pressure Coolant Injection (LPCI) System 4,5 4(a) C SR 3.3.5.3.1 s 425 psig a. Reactor Steam SR 3.3.5.3.2 Dome Pressure -Low 3. RHR System Isolation

a. Reactor Vessel (b) 2 in one trip B SR 3.3.5.3.1 153 inches Water Level -Low system SR 3.3.5.3.2 Level 1 4. Reactor Water Cleanup (RWCU) System Isolation (b) 2 in one trip B SR 3.3.5.3.1 101 inches system SR 3.3.5.3.2

a. Reactor Vessel Water Level -Low Level2 a) Associated with an ECCS subsystem required to be OPERABLE by lCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control." b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME. 2.2.2.3 TS 3.3.6.1, "Primary Containment Isolation Instrumentation" In TS 3.3.6.1, Required Action J.2 was proposed to be deleted. This required action is related to RHR Shutdown Cooling, MODEs 4 and 5 reactor vessel low level 1, which is no longer needed in TS Table 3.3.6.1-1.

In TS Table 3.3.6.1-1, Function 6.b, RHR Shutdown Cooling System Isolation, Reactor Vessel Water Level -Low Level 1, the licensee proposed to delete the applicability in MODEs 4 and 5. Also, the licensee proposed to delete Footnote (d) to Table 3.3.6.1-1, as it is applicable only to Function 6.b during MODEs 4 and 5. Footnote (d) is related to RHR Shutdown Cooling System integrity.

This function would be moved to the proposed new TS Table 3.3.5.3-1, Function 3.a, as shown in Section 2.2.2.2 of this SE. 2.2.3 TS Section 3.5, "Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System" The title of BSEP TS Section 3.5 would be revised from "Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System" to "Emergency Core Cooling Systems (ECCS), RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC) System." The title of BSEP TS Section 3.5.2 would be revised from "ECCS -Shutdown" to "Reactor Pressure Vessel (RPV) Water Inventory Control," and TS 3.5.2 would be revised as follows: LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. One low pressure ECCS injection/spray subsystem shall be OPERABLE.

---

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY:

MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> injection/spray subsystem injection/spray subsystem to inoperable.

OPERABLE status. B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection capable Time of Condition A not of operating without offsite met. electrical power. C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C.1 Verify secondary containment 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. boundary is capable of being established in less than the DRAIN TIME. AND C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME. AND C.3 Verify one standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment subsystem is capable of being placed in operation in less than the DRAIN TIME. 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--------------N()TE------------

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 Immediately 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 Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be manually isolated from the control room. AND D.4 Initiate action to verify one Immediately standby gas treatment subsystem is capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. 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 />. The proposed TS 3.5.2 SRs are shown below: SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR3.5.2.1 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 SR3.5.2.2 Verify, for a required low pressure coolant injection In accordance with the (LPCI) subsystem, the suppression pool water level Surveillance Frequency is -31 inches. Control Program SR3.5.2.3 Verify, for a required core spray (CS) subsystem, the: In accordance with the Surveillance Frequency

a. Suppression pool water level is Control Program -31 inches; or b. Condensate storage tank water volume is 228,200 gallons. SR3.5.2.4 Verify, for the required ECCS injection/spray In accordance with the subsystem, locations susceptible to gas accumulation Surveillance Frequency are sufficiently filled with water. Control Program SURVEILLANCE FREQUENCY SR3.5.2.5

---

N()l"E-----------------------------

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

Verify for the required ECCS injection/spray In accordance with the subsystem each manual, power operated, and Surveillance Frequency automatic valve in the flow path, that is not locked, Control Program sealed, or otherwise secured in position, is in the correct position.

SR3.5.2.6 Operate the required ECCS injection/spray In accordance with the subsystem through the recirculation line for Surveillance Frequency 10 minutes. Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a In accordance with the penetration flow path actuates to the isolation position Surveillance Frequency on an actual or simulated isolation signal. Control Program SR 3.5.2.8 ---------------------N()l"E--------------------------------

Vessel injection/spray may be excluded.

---

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

Surveillance Frequency Control Program 2.2.4 Deletion of References to ()PDRVs In Reference 1, the licensee proposed to revise existing l"S requirements related to "operations with a potential for draining the reactor vessel" or "OPDRVs," with new requirements on RPV WIC that will protect Safety Limit 2.1.1.3. l"o remain consistent with l"Sl"S-542, all references to the term ()PDRVs in the BSEP l"Ss would be deleted. l"he l"S locations of these references are summarized as follows: BSEP l"S Limiting Condition for Operation Location of ()PDRV Reference (LC()) 3.3.6.2, Secondary Containment Isolation l"able 3.3.6.2-1 Footnote (a) Instrumentation 3.3.7.1, Control Room Emergency "fable 3.3.7.1-1 Footnote (b) Ventilation (CREV) System Instrumentation 3.6.1.3, Primary Containment Isolation Required Action F.1 Valves (PCIVs) 3.6.4.1, Secondary Containment Applicability, and Condition C 3.6.4.2, Secondary Containment Isolation Applicability, and Condition D Dampers (SCIDs) BSEP TS Limiting Condition for Operation Location of OPDRV Reference (LCO) 3.6.4.3, Standby Gas Treatment (SGT) Applicability, and Conditions C, D, and E System 3.7.3, Control Room Emergency Applicability, and Conditions D and E Ventilation (CREV) System For Conditions D and E, an "or is added. This proposed change states " ... secondary containment or during CORE ALTERATIONS." 3.7.4, Control Room Air Conditioning Applicability, and Conditions D and F (AC) System For Conditions D and F, an "or is added. This proposed change states " ... secondary containment or during CORE ALTERATIONS." 3.8.2, AC Sources -Shutdown Conditions A, B, and C 3.8.5, DC Sources -Shutdown Condition A 3.8.8, Distribution Systems -Shutdown Condition A 2.2.5 BSEP Plant-Specific TSTF-542 TS Variations In Section 2.2 of Reference 1, the licensee identified several BSEP plant-specific TS variations from TSTF-542, Revision 2 (Reference 4), or the NRG-approved TSTF-542 SE (Reference 5). The licensee states these variations do not affect the applicability of TSTF-542 or the NRC staff's SE to the proposed license amendment.

Section 3.5 of this SE includes the staff's evaluation of each of these technical variations.

2.2.5.1 Variation 1, SR 3.5.1.2 Note The BSEP TSs contain a Note in Surveillance Requirement (SR) 3.5.1.2 regarding realignment to the Low Pressure Coolant Injection mode, which is similar to the Note in the Standard Technical Specifications (STSs) Limiting Condition for Operation (LCO) 3.5.2. The licensee requests relocation of the Note from the SR to the LCO section. 2.2.5.2 Variation 2, RPV Water Inventory Control Instrumentation numbering The licensee has chosen to implement the Reactor Pressure Vessel Water Inventory Control (WIC) Instrumentation specification as TS 3.3.5.3 and to not renumber the existing TS 3.3.5.2. 2.2.5.3 Variation 3, Reactor Vessel Water Level STS Reactor Vessel Water Level -Low Low Low, Level 1 is referred to as Reactor Vessel Water Level -Low Level 3 in the BSEP TSs. STS Reactor Vessel Water Level -Low, Level 3 is referred to as Reactor Vessel Water Level -Low Level 1 in the BSEP TSs. 2.2.5.4 Variation 4, ECCS discharge flow STS Table 3.3.5.1-1, Function 1.d, "Core Spray Pump Discharge Flow -Low (Bypass)," and Function 2.g, "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)," are not included in the BSEP TSs. Also, STS Table 3.3.5.1-1, Functions 1.e, and 2.h, "Manual Initiation," for the Core Spray (CS) System and Low Pressure Coolant Injection (LPCI) System are not included in the BSEP TSs. Therefore, they are not being included in TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation," Table 3.3.5.3-1.

As a result of this design, BSEP TS 3.3.5.3 does not contain a Condition equivalent to STS 3.3.5.3, Condition D. 2.2.5.5 Variation 5, Core spray pump start time delay BSEP Table 3.3.5.1-1 includes Function 1.d, "Core Spray Pump Start-Time Delay Relay," which is not included in STS Table 3.3.5.1-1.

The purpose of the time delay relays is to stagger the automatic start of the Core Spray pumps, limiting starting transients on their associated 4.16 kV emergency buses. This staggering is unnecessary for manual operation.

Therefore, this function is not being included in Table 3.3.5.3-1 of TS 3.3.5.3. The applicability of Function 1.d would be modified to remove MODE 4 and 5. This is consistent with the intent of TSTF-542 and a similar change made to STS Function 2.f, "Low Pressure Coolant Injection Pump Start-Time Delay Relay." 2.2.5.6 Variation 6, Manual initiation logic STS Table 3.3.5.1-1, Functions 1.e, and 2.h, "Manual Initiation," for the Core Spray System and LPCI System are not included in the BSEP TSs. By design BSEP does not include a single manual push button or hand switch that activates a manual ECCS initiation.

Therefore, manual initiation functions for LPCI and CS would not be included in TS 3.3.5.3, Table 3.3.5.3-1. As a result of this design, proposed BSEP SR 3.5.2.8 would be modified from the STS to verify that the required ECCS injection/spray subsystem can be manually operated versus verifying that the subsystem actuates on a manual initiation signal. 2.3 Applicable Regulatory Requirements The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 1 O CFR 50.36. The applicant must also include in the application a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." However, per 10 CFR 50.36(a)(1

), these TS bases "shall not become part of the technical specifications." As required by 10 CFR 50.36(c)(1)(i)(a), TSs will include items in the following categories:

(1) Safety limits, limiting safety system settings, and limiting control settings. (i)(A) Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity.

If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence.

Operation must not be resumed until authorized by the Commission. As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

In accordance with 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The regulation at 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the listed criteria.

Specifically, Criterion 4, "A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety," supports the establishment of LCOs for RPV WIC due to insights gained via operating experience.

The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Pursuant to 10 CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

The technical information to be included in an application for an operating license is governed in particular by 10 CFR 50.34(b).

As described in 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate.

The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs provide reasonable assurance that the health and safety of the public will not be endangered.

Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public. NUREG-1433, Volumes 1 and 2, Revision 4 (References 6 and 7), contains the STSs for BWR/4 plants and is part of the regulatory standardization effort. The NRC staff has prepared STSs for each of the light-water reactor nuclear designs. The NRC staff's guidance for review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), dated March 2010 (Reference 8). 2.3.1 BSEP Applicable Design Requirements The "General Design Criteria for Nuclear Power Plants," listed in 10 CFR Part 50, Appendix A, as amended July 7, 1971, were used as the basis for an audit of the design features of the BSEP. The following criteria from the BSEP Updated Final Safety Analysis Report are related to this LAR. Criterion 13 -Instrumentation and Control. Instrumentation and control shall be provided to monitor variables and systems over their anticipated range for normal operation and accident conditions, and to maintain them within prescribed operating ranges, including those variables and systems which can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary (RCPB), and the containment and its associated systems. Criterion 14 -Reactor Coolant Pressure Boundary.

The reactor coolant pressure boundary (RCPB) shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture. Criterion 30 -Quality of Reactor Coolant Pressure Boundary.

Components which are part of the RCPB shall be designed, fabricated, erected, and tested to the highest quality standards practical.

Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage. Criterion 33 -Reactor Coolant Makeup. A system to supply reactor coolant makeup for protection against small breaks in the RCPB shall be provided.

The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the RCPB and rupture of small piping or other small components which are part of the boundary.

The system shall be designed to assure that for onsite electrical power system operation (assuming offsite power is not available) and for offsite electrical power system operation (assuming onsite power is not available), the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

Criterion 35 -Emergency Core Cooling. A system to provide abundant emergency core cooling shall be provided.

The system safety function shall be to transfer heat from the reactor core following any LOCA at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts. Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electrical power system operation (assuming offsite power is not available) and for offsite electrical power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure. 3.0 TECHNICAL EVALUATION Section 2.2 above lists the licensee's proposed TS changes, as included in the LAR and its supplements (References 1, 2 and 3), to adopt TSTF-542, Revision 2 for BSEP. The following sections summarize the NRG staff's evaluation of each of these proposed changes. 3.1 NRC Staff Evaluation of Proposed DRAIN TIME Definition As discussed in Section 2.2.1 above, the DRAIN TIME is the time it would take the RPV water inventory to drain from the current level to the TAF assuming the most limiting of the RPV penetrations flow paths with the largest flow rate, or a combination of penetration flow paths that could open due to a common mode failure, were to open and the licensee took no mitigating action. The NRC staff reviewed the proposed Drain Time definition from TSTF-542.

For the purpose of NRC staff considerations, the term "break" describes a pathway for water to drain from the RPV that has not been prescribed in the "DRAIN TIME" definition in TSTF-542.

Based on information furnished by the licensee in Reference 1, the NRC staff has determined that the licensee is appropriately adopting the principles of Drain Time as specified in TSTF-542.

The NRC has reasonable assurance that the licensee will include all RPV penetrations below the TAF in the determination of Drain Time as potential pathways.

As part of this evaluation, the staff reviewed requests for additional information used during the development of TSTF-542, Revision 2, which provided examples of bounding drain time calculations for three examples:

(1) water level at or below the RPV flange; (2) water level above the RPV flange with fuel pool gates installed; and (3) water level above the RPV flange with fuel pool gates removed. The drain time is calculated by taking the water inventory above the break and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter depending on the break size and the reduction of elevation head above break location during the drain down event. The discharge point will depend on the lowest potential drain point for each RPV penetration flow path on a plant-specific basis. This calculation provides a conservative approach to determining the drain time of the RPV. The NRC staff concluded that the licensee will use methods resulting in conservative calculations to determine RPV Drain Time, thereby, protecting Safety Limit 2.1.1.3, which meets the requirements of 10 CFR 50.36(c)(3).

Based on these considerations, the NRC staff has determined that the licensee's proposed addition of the DRAIN TIME definition to the BSEP TSs is acceptable.

3.2 NRC Staff Evaluation of Proposed TS 3.3.5.3, "Reactor Pressure Vessel {RPV) Water Inventory Control Instrumentation" The purpose of the proposed new TS 3.3.5.3 regarding RPV WIC Instrumentation is to support the requirements of revised TS LCO 3.5.2, and the proposed new definition of drain time. There are instrumentation and controls and their signal functions that are required for manual pump starts or required as a permissive or operational controls on the equipment of the systems that provide water injection capability, certain start commands, pump protection, and isolation functions.

These instruments are required to be operable if the systems that provide water injection and isolation functions are to be considered operable as described in Section 3.3 of this SE for revised TS 3.5.2. For BSEP, reactor operators have alternate, often more complex means, of starting and injecting water than the preferred simple push button start. Specifically, the proposed new TS 3.3.5.3 regarding RPV WIC Instrumentation supports operation of the CS and LPCI systems including manual alignment when needed as well as the system isolation of the RHR system and the RWCU system. The equipment involved with each of these systems is described in the evaluation of TS 3.5.2 and the Bases for LCO 3.5.2. 3.2.1 Staff Evaluation of Proposed TS 3.3.5.3 LCO and Applicability In Reference 1, the licensee proposed a new TS 3.3.5.3 to provide alternative instrumentation requirements to support manual alignment of the ECCS injection/spray subsystem required in proposed new TS 3.5.2 and automatic isolation of penetration flow paths that may be credited in the determination of drain time. The current TS contain instrumentation requirements related to OPDRVs in TS Table 3.3.5.1-1, TS Table 3.3.6.1-1, TS Table 3.3.6.2-1, and TS Table 3.3.7.1-1.

These requirements from Tables 3.3.5.1-1 and Table 3.3.6.1-1 would be consolidated into a new TS 3.3.5.3. The proposed LCO 3.3.5.3 would state: "The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE." The proposed Applicability would state: "According to Table 3.3.5.3-1." TSTF-542 selected Table 3.3.5.2-1 to contain those instrumentation Functions needed to support manual alignment of the ECCS injection/spray subsystem required by LCO 3.5.2, and automatic isolation of penetration flow paths that may be credited in a calculation of drain time. As described in Variation 2, the licensee proposed to select Table 3.3.5.3-1 instead of Table 3.3.5.2-1 so that the re-numbering of other TS tables would not need to take place; see Section 3.5.2 of this SE. The Functions in Table 3.3.5.3-1 are moved from existing TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and TS 3.3.6.1, "Primary Containment Isolation Instrumentation" Functions that are required in MODEs 4 or 5 or during OPDRVs. Creation of TS 3.3.5.3 places these Functions in a single location with requirements appropriate to support the safety function for TS 3.5.2. As identified in Section 2.2.5.6 above (Variation 6), the BSEP current design-basis does not include a manual initiation logic for the CS or LPCI systems. Therefore, as an alternative, the licensee proposed to add new SR 3.5.2.8 to TS 3.5.2 to verify that the CS and LPCI systems can be manually operated through the manipulation of subsystem components from the Main Control Room. The NRC staff concluded that the licensee's proposed alternative is acceptable for BSEP since either CS or LPCI (or both) subsystems would be available to perform the intended function to inject water into the RPV, which meets the intent of the NRC-approved TSTF-542.

3.2.2 NRC Staff Evaluation of Proposed TS 3.3.5.3 Actions As discussed in Section 2.2.2.2 above, the NRC staff has determined that the licensee's proposed new TS 3.3.5.3 Actions provide effective remedial measures, because when one or more instrument channels are inoperable, the equipment and function controlled by these instruments cannot complete the required function in the normal manner. The Actions are evaluated as follows. Action A would be applicable when one or more instrument channels are inoperable from Table 3.3.5.3-1 and directs the licensee to immediately enter the Condition referenced in Table 3.3.5.3-1 for that channel. Action B (concerning the RHR system isolation and RWCU system isolation functions) would be applicable when automatic isolation of the associated penetration flow path is credited as a path for potential drainage in calculating drain time. If the instrumentation is inoperable, Required Action 8.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation.

Required Action 8.2 requires an immediate re-calculation of drain time, but automatic isolation of the affected penetration flow paths cannot be credited. Action C ( concerning low reactor steam dome pressure functions necessary for ECCS subsystem manual injection valve opening) would address an event in which the permissive is inoperable.

The function must be placed in the trip condition within one hour. With the permissive function instrument in the trip condition, manual injection valve opening may now be performed using the preferred control board switches.

This one-hour completion time is acceptable, because, despite the preferred start method being prevented, the reactor operator can take manual control of the pump and the injection valve to inject water into the RPV and achieve the safety function in that time. The time of one hour also provides reasonable time for evaluation and placing the channel in trip. Action D would apply, if the Required Action and associated Completion Time of Condition C were not met. If they were not met, then the associated low pressure ECCS injection/spray subsystem might be incapable of performing the intended function, and the CS/LPCI subsystem would be declared inoperable immediately.

These actions direct the licensee to take appropriate actions and enter immediately into the Conditions referenced in Table 3.3.5.3-1.

The NRC staff has determined that these actions satisfy the requirements of 10 CFR 50.36(c)(2)(i) by providing a remedial action permitted by the TSs until the LCO can be met. Therefore, the staff has concluded that there is reasonable assurance that the licensee will take appropriate actions during an unexpected drain event to either prevent or to mitigate RPV water level being lowered to the TAF and, therefore, that the proposed actions are acceptable.

3.2.3 NRC Staff Evaluation of Proposed TS 3.3.5.3 Surveillance Requirements The proposed new TS 3.3.5.3 SRs include Channel Checks and Channel Functional Tests numbered SR 3.3.5.3.1 and SR 3.3.5.3.2, respectively.

The NRC staff finds that these tests are sufficient and adequate, because they will ensure that the Functions of TS 3.3.5.3 are operable (i.e., capable of performing the specified safety function in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in MODEs 4 and 5). The NRC staff finds that the proposed SRs of LCO 3.3.5.3, as described in Section 3.3.3 of TSTF-542, are acceptable and concludes that these SRs satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained.

SR 3.3.5.3.1 would require a Channel Check and applies to system isolation functions in TS Table 3.3.5.3-1 for RHR and RWCU and Reactor Steam Dome Pressure for system permissive.

Performance of the Channel Check would ensure 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 related channels.

A Channel Check is significant in assuring that there is a low probability of an undetected complete channel failure and is a key safety practice to verifying the instrumentation continues to operate properly between each Channel Functional Test. The frequency in accordance with the Surveillance Frequency Control Program, is consistent with the existing requirements and supports operating shift situational awareness.

SR 3.3.5.3.2 would require a Channel Functional Test and applies to all functions in TS Table 3.3.5.3-1.

A Channel Functional Test is the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify operability of all devices in the channel required for channel operability.

It would be performed on each required channel to ensure that the entire channel will perform the intended function.

The frequency would be in accordance with the Surveillance Frequency Control Program. This is acceptable because it is consistent with the existing requirements for these Functions.

In addition, if licensees so desire, this SR could be included as part of a refueling activity, since during refueling outages, periods in MODEs 4 and 5 are often 30 days or less. TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived from the allowable value using a Channel Calibration or a surveillance to calibrate the trip unit. Since a draining event in MODEs 4 or 5 is not an analyzed accident, there is no accident analysis on which to base the calculation of a setpoint.

The purpose of the Functions is to allow ECCS manual initiation or to automatically isolate a penetration flow path, but no specific RPV water level is assumed for those actions. Therefore, the MODE 3 Allowable Value was chosen for use in MODEs 4 and 5 as it will perform the desired function.

Calibrating the Functions in MODEs 4 and 5 is not necessary, as TS 3.3.5.1 and TS 3.3.6.1 continue to require the Functions to be calibrated on an established interval.

Similarly, there are no accident analysis assumptions on response time because a draining event in MODEs 4 or 5 is not an analyzed accident.

This is acceptable, because this is adequate to ensure that the channel responds with the required pumping systems to inject water when needed and isolation equipment to perform when commanded.

Based on. the above, the NRC staff concludes that the proposed SRs of LCO 3.3.5.3 satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained and are, therefore, acceptable.

3.2.4 NRC Staff Evaluation of Proposed Table 3.3.5.3-1, "RPV Water Inventory Control Instrumentation" In order to support the requirements of proposed TS 3.5.2, the associated instrumentation requirements would be designated in Table 3.3.5.3-1.

These instruments would be required to be operable if the systems that provide water injection and isolation functions were to be considered operable as described in the NRC staff's evaluation of TS 3.5.2. Proposed Table 3.3.5.3-1 specifies the instrumentation that shall be operable for each function in the table for MODEs 4 and 5 (or other specified conditions), the required number of channels per function, conditions referenced from Required Action A.1, SR for the functions, the allowable value, and footnotes concerning items of the table. Proposed Table TS 3.3.5.3-1, "RPV Water Inventory Control Instrumentation," presents details on the functions required to support the equipment and functions of TS 3.5.2. The NRC staff finds the presentation in this table to be acceptable, because this section sufficiently discusses the purpose of the functions, the applicability, the number of required channels, the references to the Condition to be entered by letter (e.g., A, B, C, or D) if the function is inoperable, the applicable SRs, the selection of the allowable value, and justification of differences between the existing and proposed TS functions.

This RPV WIC instrumentation set is acceptable, because it is adequate to ensure that the channels of instrumentation respond with the required accuracy permitting pump systems to operate to inject water when needed and isolating equipment when commanded to support the prevention of or to mitigate a potential RPV draining event. Each of the ECCS subsystems in MODEs 4 and 5 can be started by manual alignment of a small number of components.

Automatic initiation of an ECCS injection/spray subsystem may be undesirable because it could lead to overflowing the RPV cavity, due to injection rates of thousands of gallons per minute. Thus, there is adequate time to take manual actions (e.g., hours versus minutes).

Considering the action statements as the drain time decreases (the proposed TS 3.5.2, Action E, prohibits plant conditions that could result in drain times less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />), there is sufficient time for the reactor operators to take manual action to stop the draining event, and to manually start an ECCS injection/spray subsystem or additional method of water injection as needed. Consequently, there is no need for automatic initiation of ECCS to respond to an unexpected draining event. This is acceptable, because a draining event is a slow evolution when compared to a design basis LOCA assumed to occur at a significant power level. 3.2.4.1 NRC Staff Evaluation of Proposed Table 3.3.5.3-1 Functions For the Table 3.3.5.3-1 Functions 1.a and 2.a, CS and LPCI Systems, Reactor Steam Dome Pressure -Low, these signals would be used as permissives and protection for these low pressure ECCS injection/spray subsystem manual alignment functions.

This function would ensure that the reactor pressure has fallen to a value below these subsystems' maximum design pressure before permitting the operator to open the injection valves of the low pressure ECCS subsystems.

Even though the reactor steam dome pressure is expected to virtually always be below the ECCS maximum design pumping pressure during MODEs 4 and 5, the Reactor Steam Dome Pressure -Low signals would be required to be operable and capable of permitting initiation of the ECCS. The proposed allowable value would be :s; 425 psig, with four required channels per function, as it is currently in BSEP TS Table 3.3.5.1-1.

In addition, Table 3.3.5.3-1 Footnote (a), which is related to these two functions, requires the association with an ECCS subsystem required to be operable in accordance with TS LCO 3.5.2. For Table 3.3.5.3-1 Function 3.a, RHR System Isolation, Reactor Vessel Water Level -Low Level 1, would only be required to be operable when automatic isolation of the associated penetration flow path is credited in the drain time calculation (Table 3.3.5.3-1, Footnote (b)). The proposed number of required instrument channels is 2 in one trip system. The condition that the RHR system integrity be maintained is a concept related to OPDRVs, so it would not be carried over into TS 3.3.5.3 for RPV WIC instrumentation.

Reactor Vessel Water Low Level 1 signal is 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 allowable value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level -Low Level 1, Allowable Value from LCO 3.3.6.1, which is 153 inches. For Table 3.3.5.3-1 Function 4.a, RWCU System Isolation, Reactor Vessel Water Level -Low Level 2, the function is only required to be operable when automatic isolation of the associated penetration flow path is credited in the drain time calculation (Table 3.3.5.3-1, Footnote (b)). The proposed number of required instrument channels i_s 2 in one trip system. Reactor Vessel Water Level-Low 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 Level-Low Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

This proposed change is a new requirement in MODEs 4 and 5 for the RWCU system. The instrumentation function is the same as TS Table 3.3.6.1, Function 5.g, which contains the requirements for MODEs 1, 2, and 3, with the same allowable value, 101 inches. The NRC staff finds that the proposed new LCO 3.3.5.3 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility.

There is reasonable assurance that the required actions to be taken when the LCO is not met are adequate to protect the health and safety of the public. This meets the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff has determined that the licensee's proposed changes to LCO 3.3.5.2 are acceptable.

3.3 NRC Staff Evaluation of TS 3.5.2 -Reactor Pressure Vessel (RPV) Water Inventory Control The NRC staff reviewed the water sources that would be applicable to the proposed TS 3.5.2. The proposed LCO 3.5.2 would state, in part: "One low pressure ECCS injection/spray subsystem shall be OPERABLE." "One low pressure ECCS injection/spray subsystem" would consist of either one CS subsystem or one LPCI subsystem.

A CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tanks to the RPV. An LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. The ECCS pumps are high-capacity pumps, with flow rates of thousands of gallons per minute (gpm). Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual initiation/start of an ECCS pump would provide the necessary water source to counter these expected drain rates. The LPCI subsystem is to be considered operable during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

Decay heat removal in MODEs 4 and 5 is not affected by the proposed BSEP TS change as these requirements on the number of shutdown cooling subsystems that must be operable and in operation to ensure adequate decay heat removal from the core are unchanged.

These requirements can be found in the BSEP TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System -Cold Shutdown," TS 3.9.7, "Residual Heat Removal (RHR) -High Water Level," and TS 3.9.8, "Residual Heat Removal (RHR) -Low Water Level." These BSEP decay heat removal requirements are similar to the STS and can be found in the NUREG-1433 TS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System -Cold Shutdown," TS 3.9.8, "Residual Heat Removal (RHR) -High Water Level," and TS 3.9.10, "Residual Heat Removal (RHR) -Low Water Level." Based on these considerations, the NRC staff finds that the water sources provide reasonable assurance that the lowest functional capability required for safe operation is maintained and the safety limit is protected.

The proposed TS LCO 3.5.2 contains two parts. The first part states that drain time of RPV water inventory to the TAF shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and the second part states, one low pressure ECCS injection/spray subsystem shall be OPERABLE.

The proposed Applicability for TS 3.5.2 is MODEs 4 and 5. The proposed TS LCO 3.5.2 note states: A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

The addition of this note and the removal of a similar note from existing SR 3.5.2.4 is evaluated in Section 3.5.1 of this SE (Variation 1 ). The NRC staff reviewed the proposed TS 3.5.2, focusing on ensuring that the fuel remains covered with water and on the changes made compared to the current TS. The proposed TS 3.5.2 contains Conditions A through E based on either required ECCS injection/spray subsystem operability or drain time. The current TS LCO states that two low pressure ECCS injection/spray subsystems shall be operable, whereas the proposed LCO 3.5.2 states that only one low pressure ECCS injection/spray subsystem shall be operable.

This change is reflected in Condition A The change from two low pressure ECCS injection/spray subsystems to one low pressure ECCS injection/spray subsystem is because this redundancy is not required.

With one ECCS injection/spray subsystem and non-safety related injection sources, defense-in-depth will be maintained.

The defense-in-depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The drain time controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF. The proposed LCO 3.5.2 note for MODEs 4 and 5, states that the RHR System may operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor and the RHR valves that are required for LPCI subsystem operation may be aligned for decay heat removal. This note allows a required LPCI subsystem of the RHR System to be considered operable for the ECCS function if all the required valves in the LPCI flow path can be manually realigned (remote or local) to allow injection into the RPV, and the system is not otherwise inoperable.

This will ensure adequate core cooling if an inadvertent RPV draindown should occur. The proposed MODEs 4 and 5 Applicability of TS 3.5.2 is appropriate given that the TS requirements on ECCS in MODEs 1, 2, and 3 will be unaffected.

The proposed Condition A states that if the required ECCS injection/spray subsystem is inoperable, it is to be restored to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The proposed Condition B states that if Condition A is not met, a method of water injection capable of operating without offsite electrical power shall be established immediately.

The proposed Condition B provides adequate assurance of an available water source should Condition A not be met within the 4-hour completion time. The proposed Condition C states that for a drain time less than ( <) 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and i?! 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, to (C.1) verify secondary containment boundary is capable of being established in less than the drain time with a completion time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and (C.2) verify each secondary containment penetration flow path is capable of being isolated less than the drain time with a completion time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and (C.3) verify one standby gas treatment subsystem is capable of being placed in operation in less than the drain time with a completion time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The proposed Condition C provides adequate protection should the DRAIN TIME be< 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> because of the ability to establish secondary containment, isolate additional flow paths, and have the standby gas treatment subsystem capable of being placed in operations.

The proposed Condition D states that for a drain time < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to (D.1) immediately 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) immediately initiate action to establish secondary containment boundary, and (D.3) immediately initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room, and (D.4) immediately initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.

Additionally, there is a note stating that required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power, which is similar to proposed Condition B. The current BSEP TS for Condition D (Required Action C.2 and associated Completion Time not met) is similar to proposed Condition D. The proposed Condition D provides adequate protection should the drain time be < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> because of the requirement for the ability to establish an additional method of water injection (without offsite electrical power), establish secondary containment, isolate additional flow paths, and have the standby gas treatment subsystem capable of being placed in operation.

The proposed Condition E states that when the required action and associated completion time of Condition C or D is not met, or the drain time is < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, then immediately 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 />. The proposed Condition E is new, as it is not present in the current BSEP TS. The proposed Condition E is acceptable, as it provides the necessary step 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 /> should the other conditions not be met, or if the drain time is < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The NRC staff evaluated the proposed changes to TS 3.5.2 and finds them acceptable based on the actions taken to mitigate the water level reaching the TAF with the water sources available, and maintaining drain time 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The LCO correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility.

There is reasonable assurance that the Required Actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public and, therefore, they are acceptable.

• 3.3.1 NRC Staff Evaluation of Proposed TS 3.5.2 Surveillance Requirements The proposed TS 3.5.2 SRs (Section 2.2.3 above) include verification of DRAIN TIME, verification of water levels/volumes that support ECCS injection/spray subsystems, verification of water filled pipes to preclude water hammer events, verification of correct valves positions for the required ECCS injection/spray subsystem, operation of the ECCS injection/spray systems through the recirculation line, verification of valves credited for automatic isolation actuated to the isolation position, and verification that the required ECCS injection/spray subsystem can be manually operated.

Each of the eight SRs are described below. SR 3.5.2.1: The DRAIN TIME would be determined or calculated, and required to be verified to be 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. This Surveillance would verify that the LCO for Drain Time is met. Numerous indications of changes in RPV level are available to the operator.

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 (normally 3 operator shifts). Changes in RPV level would necessitate recalculation of the DRAIN TIME. SR 3.5.2.2: The suppression pool water level(~ -31 inches) for a required ECCS injection/spray subsystem (LPCI subsystem) is required to be verified to ensure pump net positive suction head and vortex prevention is available for the LPCI subsystem required to be operable by the LCO. Indications are available either locally or in the control room regarding suppression pool water level and contaminated condensate storage tank level. This Surveillance would be required to be performed in accordance with the Surveillance Frequency Control Program. SR 3.5.2.3: The suppression pool water level(~ -31 inches) or condensate storage tank volume(~ 228,200 gallons) for a required ECCS injection/spray (CS) subsystem is required to be verified to ensure pump net positive suction head and vortex prevention is available for the CS subsystem required to be operable by the LCO. Indications are available either locally or in the control room regarding suppression pool water level and condensate storage tank level. This Surveillance would be required to be performed in accordance with the Surveillance Frequency Control Program. SR 3.5.2.4: The surveillance requirement to verify the ECCS injection/spray subsystem piping is sufficiently filled with water would be retained from the existing TS 3.5.2. The proposed change would update the SR to reflect the change to LCO 3.5.2, which would require, in part, one low pressure ECCS injection/spray subsystem to be operable instead of two. The SR 3.5.2.4 wording would change from "Verify, for each required ECCS ... " to "Verify, for the required ECCS .... " This change clarifies the requirement to maintain consistency with the proposed LCO. This Surveillance would be required to be performed in accordance with the Surveillance Frequency Control Program. SR 3.5.2.5: The SR to verify the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path would be retained from the existing TS 3.5.2. Similar to the change discussed above for proposed SR 3.5.2.4, changes to SR 3.5.2.5 would clarify a proposed requirement for LCO 3.5.2. The proposed SR wording, "Verify for the required ECCS ... " would replace "Verify each required ECCS .... " SR 3.5.2.5 would provide assurance that the proper flow path will be available for ECCS operation to support TS 3.5.2. This SR would not apply to valves that are locked, sealed, or otherwise secured in position, since these valves would be verified to be in the correct position prior to locking, sealing, or securing.

A note is maintained from the existing SR 3.5.2.4, which states that it is not required to be met for system vent flowpaths opened under administrative control. For this note, the administrative control would require a dedicated individual who can rapidly close the system vent flow path if directed.

This Surveillance would be required to be performed in accordance with the Surveillance Frequency Control Program. SR 3.5.2.6: The required ECCS injection/spray subsystem would be required to be operated through its recirculation line for~ 10 minutes in accordance with the Surveillance Frequency Control Program. This would demonstrate that the subsystem is capable for operation to support TS 3.5.2. Testing the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes is based on engineering judgement. SR 3.5.2. 7: Verification 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 would be required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. This Surveillance would be required to be performed in accordance with the Surveillance Frequency Control Program. SR 3.5.2.8: This SR would state, "Verify the required ECCS injection/spray subsystem can be manually operated." It would demonstrate that the required CS or LPCI subsystem could be manually initiated, using the associated pump and valve switches, to provide additional RPV water inventory, if needed. Vessel injection/spray may be excluded from the SR, per the existing Note. This surveillance would be required to be performed in accordance with the Surveillance Frequency Control Program. The NRC staff evaluated each of these proposed SRs associated with the proposed LCO 3.5.2 and concluded that they are appropriate for ensuring the operability of the equipment and instrumentation specified in LCO 3.5.2. The staff concluded that each of the proposed SRs are acceptable since they meet the requirements of 10 CFR 50.36(c)(2)(ii) regarding insights gained via operating experience and 10 CFR 50.36(c)(3) for surveillance requirements by ensuring that the necessary quali.ty of systems and components are maintained.

3.4 NRC Staff Evaluation of TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation" LCO 3.3.5.1 currently states that, "The ECCS instrumentation for each Function in Table 3.3.5.1-1, shall be OPERABLE," with the applicability as stated in the table. Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," currently contains requirements for function operability during MODEs 4 and 5 when the associated ECCS subsystem(s) are required to be operable.

Conforming changes were proposed for the Actions table of LCO 3.3.5.1 as well. For the following Functions in Table 3.3.5.1-1, MODEs 4 and 5 requirements would be deleted: 1. Core Spray System (a) Reactor Vessel Water Level -Low Level 3 (c) Reactor Steam Dome Pressure -Low (d) Core Spray Pump Start -Time Delay Relay 2. Low Pressure Core Injection (LPCI) System (a) Reactor Vessel Water Level -Low Level 3 (c) Reactor Steam Dome Pressure -Low (f) RHR Pump Start -Time Delay Relay The six Functions above would be deleted to support the consolidation of RPV WIC Instrumentation requirements into proposed new TS 3.3.5.3. The requirements for Functions 1.c and 2.c would be moved to proposed TS Table 3.3.5.3-1 as discussed in Section 3.2.4.1 of this SE. For the other TS Table 3.3.5.1-1 Functions, 1.a, 1.d, 2.a, and 2.f, the MODEs 4 and 5 requirements would not be retained.

The BSEP TSs currently require automatic initiation of ECCS pumps on low Reactor Vessel water level. However, in MODEs 4 and 5, automatic initiation of ECCS pumps could result in overfilling the refueling cavity or water flowing into the main steam lines, potentially damaging plant equipment.

The NRC staff finds the deletion of TS Table 3.3.5.1-1 Functions 1.a, 1.d, 2.a, and 2.f acceptable, because manual ECCS initiation is preferred over automatic initiation during MODEs 4 and 5, and the operator would be able to use other, more appropriately sized pumps if needed to mitigate a draining event. 3.5 NRC Staff Evaluation of Proposed Technical Variations The licensee proposed the following technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staff's SE for TSTF-542.

The licensee stated in the LAR (Reference

1) that these variations do not affect the applicability of TSTF-542 or the NRC staff's SE for TSTF-542 to the proposed license amendment.

The NRC staff evaluated each variation below. 3.5.1 Variation 1, SR 3.5.1.2 Note The current BSEP TSs contain a Note in SR 3.5.1.2 regarding realignment to the Low Pressure Coolant Injection mode, which is similar to the Note in the STS LCO 3.5.2. The licensee requests relocation of the Note from the SR to the LCO section. The note states: A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

The NRC staff finds that the relocation of the note to TS LCO 3.5.2 is consistent with TSTF-542 and that this difference does not alter the conclusion that the proposed change is applicable to BSEP. 3.5.2 Variation 2, RPV Water Inventory Control Instrumentation numbering The licensee has proposed to implement the RPV WIC Instrumentation specification as new TS 3.3.5.3 and not as new TS 3.3.5.2 accompanied by a renumbering of the existing TS 3.3.5.2 to TS 3.3.5.3. The NRC staff finds that it is acceptable to not follow TSTF-542 with respect to the renumbering of subsections.

This is a non-technical change and the renumbering of existing BSEP TS 3.3.5.2 pages is not needed; however, this is important to identify since a new section is added to the BSEP TS. 3.5.3 Variation 3, Reactor Vessel Water Level STS Reactor Vessel Water Level -Low Low Low, Level 1 is referred to as Reactor Vessel Water Level -Low Level 3 in the BSEP TSs. STS Reactor Vessel Water Level -Low, Level 3 is referred to as Reactor Vessel Water Level -Low Level 1 in the BSEP TSs. The NRC staff finds that this difference in reactor water level instrumentation terminology is administrative in nature and does not affect the applicability of TSTF-542 to the BSEP TS. 3.5.4 Variation 4, ECCS discharge flow STS Table 3.3.5.1-1, Function 1.d, "Core Spray Pump Discharge Flow -Low (Bypass)," and Function 2.g, "Low Pressure Coolant Injection Pump Discharge Flow -Low (Bypass)," are not included in the BSEP TSs. Also, STS Table 3.3.5.1-1, Function 1.e, and 2.h, "Manual Initiation," for the CS System and LPCI System, respectively, are not included in the BSEP TSs. Therefore, they are not being included in proposed new TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation," Table 3.3.5.3-1.

As a result of this design, BSEP TS 3.3.5.3 does not contain a Condition equivalent to STS 3.3.5.3, Condition D. The licensee stated that BSEP does not have a function for ECCS low flow for CS or LPCI or manual initiation logic for CS or LPCI as found in TSTF-542.

To account for no manual logic, these components that provide water supply and injection into the RPV can be started from the main control room as required to support MODEs 4 and 5 operations.

The manipulation of subsystem components from the main control room is verified in accordance with new SR 3.5.2.8. This Surveillance verifies that the required CS or LPCI subsystem (including the associated pump switches and valve(s))

can be manually operated to provide additional RPV water inventory, if needed. To account for no CS or LPCI coolant pump injection low flow (pump protection for low flows), the current BSEP TSs do not have these as TS instruments; therefore, the NRC staff finds that this variation is acceptable since manual initiation of these functions is not available, but manual alignment can be performed from the control room. 3.5.5 Variation 5, Core spray pump start time delay BSEP Table 3.3.5.1-1 includes Function 1.d, "Core Spray Pump Start -Time Delay Relay," which is not included in STS Table 3.3.5.1-1.

The purpose of the time delay relays is to stagger the automatic start of the CS pumps, limiting starting transients on their associated 4.16 kV emergency buses. This staggering is unnecessary for manual operation.

Therefore, this function is not being included in proposed new Table 3.3.5.3-1 of TS 3.3.5.3. The applicability of Function 1.d would be modified to remove MODEs 4 and 5. This is consistent with the intent of TSTF-542 and a similar change made to STS Function 2.f, "Low Pressure Coolant Injection Pump Start-Time Delay Relay." The NRC staff finds that electrical emergency bus staggering is unnecessary for manual operation; therefore, these functions do not need to be included in the TSs because the required ECCS subsystem is proposed to be started by manual operation.

3.5.6 Variation

6, Manual initiation logic STS Table 3.3.5.1-1, Function 1.e, and 2.h, "Manual Initiation," for the CS System and LPCI System, respectively, are not included in the BSEP TSs. Therefore, manual initiation functions for LPCI and CS are not being included in proposed new TS 3.3.5.3, Table 3.3.5.3-1.

As a result of this design, proposed BSEP SR 3.5.2.8 is modified from the STS SR 3.5.2.8 to verify that the required ECCS injection/spray subsystem can be manually operated versus verifying that the subsystem actuates on a manual initiation signal. The manual operations of the LPCI and CS subsystems for the control of reactor cavity or RPV inventory are relatively simple evolutions and involve the manipulation of a small number of components.

These subsystem alignments can be performed by licensed operators from the Main Control Room. Guidance is provided in plant procedures 1(2) OP-18, Core Spray Operating Procedure, and 1(2) OP-17, Residual Heat Removal System Operating Procedures. This alternative is justified by the fact that a draining event is a slow evolution when compared to a design-basis LOCA, which is assumed to occur at full power, and thus there is adequate time to take manual actions (i.e., hours versus minutes).

Adequate time to take action is assured since the proposed TS 3.5.2, Condition E, prohibits plant conditions that result in drain times that are less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Therefore, there is sufficient time for the licensed operators to take manual action to stop an unanticipated draining event, and to manually start an ECCS injection/spray subsystem or the additional method of water injection.

Consequently, there is no need for manual initiation logic to actuate the required subsystem components.

Since the LPCI and CS subsystems can be placed in service using manual means in a short period of time (i.e., within the timeframes assumed in the development of TSTF-542) (in approximately 20 minutes), using controls and indications that are readily available in the Main Control Room, manual operation of the required subsystem would be an equivalent alternative to system initiation via manual initiation logic. Additionally, since the manual initiation functions are not included in Table 3.3.5.3-1, the associated Logic System Functional Test would likewise not be required for TS 3.3.5.3; therefore, TS 3.3.5.3 as proposed for BSEP does not include a Logic System Functional Test SR. The NRC staff finds that BSEP does not have a function for manual initiation logic for CS or LPCI as found in TSTF-542, which would start an ECCS subsystem via a single button push. However, these components, which provide water supply and injection into the RPV, can be started from the main control room as required to support MODEs 4 and 5 operations.

The manipulation of subsystem components from the main control room would be verified in accordance with new SR 3.5.2.8. This Surveillance would verify that the required CS or LPCI subsystem (including the associated pump switches and valve(s))

can be manually operated to provide additional RPV water inventory, if needed. Therefore, the NRC staff finds that Variation 6 is acceptable.

3.6 NRC Staff Evaluation of Proposed Deletion of References to OPDRVs Sections 2.2.2.3 and 2.2.4 of this SE state the BSEP TSs where the licensee proposed deletion of phrases used for controls during OPDRVs from Applicability descriptions, Conditions, Required Actions, and Table footnotes.

The proposed changes would remove the following from the current BSEP TSs: the term "operations with a potential for draining the reactor vessel," the acronym "OPDRVs," and related concepts such as "RHR Shutdown Cooling System integrity maintained," "Initiate action to isolate the Residual Heat Removal (RHR) Shutdown Cooling (SOC) System," Required Actions to "suspend OPDRVs" and the term, "When associated subsystem(s) are required to be OPERABLE." TS OPDRV requirements have existed for many years, but there is no clearly stated description of the event that is being prevented or mitigated.

However, from the existing TS requirements, one can infer the postulated event that forms the basis of the existing TS. The current BSEP TSs contain instrumentation requirements related to OPDRVs in four TSs: TSs 3.3.5.1, 3.3.6.1, 3.3.6.2, and 3.3.7.1, which contain the OPDRVs phrases described above. The proposed TS 3.3.5.3 consolidates the instrumentation requirements into a single location to simplify the presentation and provides requirements consistent with TS 3.5.2. The remaining TSs with OPDRVs requirements are for Secondary Containment Isolation Instrumentation, Control Room Emergency Ventilation (CREV) System Instrumentation, Primary Containment Isolation Valves (PC IVs), Secondary Containment, Secondary Containment Isolation Dampers (SCIDs), Standby Gas Treatment (SGT) System, Control Room Emergency Ventilation (CREV) System, Control Room Air Conditioning (AC) System, AC Sources -Shutdown, DC Sources -Shutdown, and Distribution Systems -Shutdown.

The licensee proposed to consolidate each of these system's requirements during OPDRVs into the new TS 3.5.2 for RPV WIC, based on the appropriate plant conditions and calculated Drain Time. The NRC staff determined that the deletion of OPDRV references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.3, respectively, are a clarified and simplified alternative set of controls for ensuring water level is maintained above the TAF and, therefore, that these changes are acceptable.

3.7 NRC Staff Evaluation of TS 3.10, Special Operations and TSTF-484 The current BSEP TS LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operation," allows performance of an inservice leak or hydrostatic test with the average reactor coolant temperature greater than 212 °F, while considering operational conditions to still be in MODE 4, provided that certain secondary containment LCOs are met. TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities," revised LCO 3.10.1 to expand its scope to include operations where temperature exceeds 200 °F: (1) as a consequence of maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a consequence of maintaining adequate reactor pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test. By Amendment Nos. 277 and 249 (for BSEP Units 1 and 2, respectively) dated December 9, 2008, the NRC approved changes to BSEP TS LCO 3.10.1 in accordance with TSTF-484 (Reference 9). The NRC staff's SE for these amendments stated, in part, that, "two low-pressure emergency core cooling systems (ECCS) injected/spray subsystems are required to be operable in MODE 4 by TS 3.5.2, ECCS-Shutdown." However, per the proposed new LCO 3.5.2, which would replace the requirements of LCO 3.5.2, for the TSTF-542 LAR, only one low pressure ECCS injection/spray subsystem would be required to be operable in MODE 4. The NRG staff determined that changing from two ECCS injection/spray subsystems to one ECCS injection/spray subsystem is acceptable because, as stated previously in Section 3.3 of this SE, this level of redundancy is not required, even during application of LCO 3.10.1. When the licensee applies LCO 3.10.1 at the end of a refueling outage, an exceptionally large volume of water is present in the reactor vessel since the vessel is nearly water solid. There is much more water in the reactor vessel than is present during power operation and more than is present during most of an outage. Small leaks from the reactor coolant system would be detected by inspections before a significant loss of inventory occurred.

In the event of a large reactor coolant system leak, the RPV would rapidly depressurize and allow operation of the low pressure ECCS. At low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Therefore, the reasoning that operators would have time to respond with manual actions to start any ECCS pumps and properly align valves for injection from the control room remains valid. As stated previously in Section 3.3 of this SE, with one ECCS injection/spray subsystem and non-safety related injection sources, defense-in-depth will be maintained.

The defense-in- depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The drain time controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF. After considering the reasoning presented in this SE and reviewing the information in the SE enclosed with the NRC letter dated December 9, 2008 (Reference 9), the NRC staff determined that LCOs 3.3.5.3 and 3.5.2 adopted as part of TSTF-542 are satisfactory and will, therefore, be acceptable even during application of LCO 3.10.1. 3.8 Technical Conclusion BSEP Safety Limit 2.1.1.3 requires that reactor vessel water level shall be greater than the top of active irradiated fuel. Maintaining water level above the T AF ensures that the fuel cladding fission product barrier is protected during shutdown conditions.

The proposed changes to the TSs establish new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.3 during MODEs 4 and 5 operations.

The Reactor Coolant System is at a low operating temperature(<

212 °F) and is depressurized during operation in MODEs 4 and 5. An event involving a loss of inventory while in the shutdown condition does not exceed the capacity of one ECCS subsystem.

The accidents that are postulated to occur during shutdown conditions, the Fuel-Handling Accident in Updated Final Safety Analysis Report (UFSAR) Section 15.3.5 and the Liquid Radwaste Tank Failure in UFSAR Section 15.4.14, do not involve a loss of inventory.

Therefore, the equipment and instrumentation associated with the RPV WIC TSs are not required to provide detection or mitigation related to these design-basis accidents.

The proposed TS LCO 3.5.2 contains requirements for operability of one ECCS subsystem, along with requirements to maintain a sufficiently long drain time so that plant operators would have time to diagnose and mitigate an unplanned draining event. The NRC staff has determined that LCOs 3.5.2 and 3.3.5.3 provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility, and therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, the revised TS LCOs 3.5.2 and 3.3.5.3 provide remedial actions to be taken in the event the LCO is not satisfied, and, therefore, meet the requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed Action statements provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the T AF. The NRC staff evaluated the proposed Drain Time definition, TS 3.5.2, which contains the requirements for RPV WIC, and TS 3.3.5.3, which contains the requirements for instrumentation necessary to support TS 3.5.2. Based on the considerations discussed above, the NRC staff concludes that the proposed revisions are acceptable because they consolidate and clarify the RPV WIC requirements, which meet 10 CFR 50.36(c)(2)(ii)

Criterion 4 to establish LCOs for structures, systems, or components significant to public health and safety as evidenced by operating experience. The licensee proposed to delete OPDRV references from TS Applicability descriptions, Conditions, Required Actions, and Table footnotes.

The NRC staff reviewed the proposed changes and determined that the deletion of OPDRV references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.3, respectively, are a clarified and simplified alternative set of controls for ensuring that water level is maintained above the TAF. The NRC staff reviewed the SRs associated with the new LCOs 3.5.2 and 3.3.5.3. The NRC staff finds that the proposed eight TS SRs found in TS 3.5.2 are acceptable since they support TS 3.5.2 drain time requirements, assure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance, ECCS injection/spray subsystems are adequately filled, the subsystems have verified valve positions to support RPV injection, verified pumps provide adequate flow to support drain time and RPV injection, verification of automatic isolation, and ECCS injection/spray subsystems can be manually operated from the control room to inject. The NRC staff finds that the two SRs proposed for TS 3.3.5.3 are sufficient and adequate, because they ensure that the Functions are capable of performing their specified safety functions in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in MODEs 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed changes against each the applicable design requirements listed in Section 2.3.1 of this SE. The NRC staff finds that the proposed changes for MODEs 4 and 5 operations related to the new DRAIN TIME definition and the removal of OPDRV references are consistent with the General Design Criteria in that the BSEP design requirements are maintained for instrumentation, reactor coolant leakage detection, the RCPB, and reactor coolant makeup. The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. In accordance with this requirement, the licensee provided TS Bases changes in Enclosure 6 of the LAR. The NRC staff concludes that the provided TS Bases changes describe the basis for the affected TSs and follow the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132). Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing BSEP requirements for customary terminology and formatting.

The NRC staff found that the licensee's proposed changes were consistent with TSTF-542 and Chapter 16 of the SRP.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the appropriate official for the State of North Carolina was notified of the NRC's proposed issuance of the amendments on February 23, 2018. The State official had no comments.

5.0 ENVIRONMENTAL

CONSIDERATION The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change SRs. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on September 12, 2017 (82 FR 42846). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1 Letter from Duke Energy to NRC, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"'

dated June 29, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 17180A538).

2 Letter from Duke Energy to NRC, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"'

dated January 4, 2018 (ADAMS Accession No. ML 18004A045).

3 Letter from Duke Energy to NRC, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2, Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"'

dated January 23, 2018 (ADAMS Accession No. ML 18023A432).

4 Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated March 14, 2016 (ADAMS Accession No. ML 16074A448).

5 Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated December 20, 2016 (ADAMS Accession No. ML 163438008).

6 NUREG-1433, Volume 1, "Specifications," Revision 4.0, "Standard Technical Specifications, General Electric BWR [Boiling-Water Reactor]/4 Plants," dated April 2012 (ADAMS Accession No. ML 12104A192).

7 NUREG-1433, Volume 2, "Bases," Revision 4.0, "Standard Technical Specifications, General Electric BWR/4 Plants," dated April 2012 (ADAMS Accession No. ML 12104A193). 8 NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 16, "Technical Specifications," dated March 2010 (ADAMS Accession No. ML 100351425).

9 Letter from NRC to Carolina Power & Light Company, "Brunswick Steam Electric Plant, Units 1 and 2 -Issuance of Amendments Regarding the Adoption of Technical Specification Task Force (TSTF) Standard TS Change Traveler, TSTF-484, Revision 0 (TAC Nos. MD8994, MD8995)," dated December 9, 2008 (ADAMS Accession No. ML083380749).

Principal Contributors:

Larry Wheeler Diana Woodyatt Rossnyev Alvarado Daniel Warner Date: April 13, 2018

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NOS. MF9905 AND MF9906; EPID L-2017-LLA-0242)

DATED APRIL 13, 2018 DISTRIBUTION:

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