BSEP 16-0082, Transmittal of Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules.

Transmittal of Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules.

ML16319A128
Person / Time
Site:	Brunswick
Issue date:	10/27/2016
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 16-0082, TSC-2016-08
Download: ML16319A128 (37)

Text

£~DUKE William R. Gideon Vice President

~

Brunswick Nuclear Plant ENERGY P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 10 CFR 50.90 October 27, 2016 Serial: BSEP 16-0082 TSC-2016-08 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Application to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules."

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

The proposed amendment would modify TS requirements in Section 1.3 and Section 3.0 regarding Limiting Condition for Operation (LCO) usage and Surveillance Requirement (SR) usage. These changes are consistent with NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules."

Enclosure 1 provides a description and assessment of the proposed TS changes. Enclosure 2 provides the existing TS pages marked-up to show the proposed changes. Enclosure 3 provides revised (i.e., typed) TS pages. Enclosure 4 provides, for information only, existing TS Bases pages marked-up to show the proposed changes.

Approval of the proposed amendment is requested by May 1, 2017. Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated North Carolina Official.

U.S. Nuclear Regulatory Commission Page 2 of 3 If you should have any questions regarding this submittal, please contact Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on M-:Z7 - ,2016.

William R. Gideon SWR/swr

Enclosures:

1. Description and Assessment of Technical Specifications Changes

2. Proposed Technical Specifications Changes (Mark-Up)

3. Revised Technical Specifications Pages

4. Proposed Technical Specifications Bases Changes - Information Only (Mark-Up)

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with attachments):

U. S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

BSEP 16-0082 Enclosure 1 Description and Assessment of Technical Specifications Changes

Enclosure 1 DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATIONS CHANGES

1.0 DESCRIPTION

The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" and "SR Applicability of the Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

• Section 1.3 is revised to clarify "discovery."

• Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

• Limiting Condition for Operation (LCO) 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.

• Surveillance Requirement (SR) 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Duke Energy Progress, LLC (Duke Energy), has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force in a letter dated April 21, 2016 (ADAMS Accession Number M.L 16060A455). This review included a review of the NRG staff's evaluation, as well as the information provided in TSTF-529. As described in the subsequent paragraphs, Duke Energy has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRG staff are applicable to Brunswick Steam Electric Plant (BSEP) Unit 1 and Unit 2 and justify this amendment for the incorporation of the changes to the BSEP Unit 1 and Unit 2 TSs.

2.2 Variations Duke Energy is proposing the following variations from the TS changes described in the TSTF-529.

1. In the Generic BWR-4 TS on page 1.3-1, the insertion mentions "LCO 3.8.1, 'AC Sources - Operating,' Required Action B.2," and a Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In BSEP Unit 1 and Unit 2 TS, this is Required Action B.1, and the Completion Time is immediately.

2. Changes shown on Generic BWR-4 TS page number 1.3-2 actually appear in BSEP Unit 1 and Unit 2 TS page number 1.3-1.

3,. Changes addressing Generic BWR-4 TS Surveillance Requirement (SR) 3.0.3 appear i on an unnumbered page. The corresponding change in the BSEP Unit 1 and Unit 2 TS appears on page 3.0-4.

These variations do not affect the applicability of TSTF-529 to the BSEP Unit 1 and Unit 2 TS or the NRG staff's safety evaluation to the proposed license amendment.

Page 1

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Duke Energy requests adoption of TSTF-529, "Clarify Use and Application Rules," that is an approved change to the standard technical specifications (STS), into the BSEP Unit 1 and Unit 2 TSs. The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (LCO) is not met and to describe existing exceptions to the start of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.

Duke Energy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes to Section 1.3 and LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes do not significantly affect system Operability, the proposed changes will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions takelj1 when plant systems are not operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 2

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change clarifies the application of Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

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

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

Page 3

BSEP 16-0082 Enclosure 2 Proposed Technical Specifications Changes (Mark-Up)

I I

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s) .

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action . It is referenced to the ~discovery of a situation Unless otherwise specified , (e .g., inoperable equipment or variable ~ n limits) that requires the Completion Time begins entering an ACTIONS Condition unless otherwise specified , providing the when a senior licensed unit is in a MODE or specified condition stated in the Applicability of the operator on the operating LCO .* Required Actions must be completed prior to the expiration of the shift crew with responsibility specified Completion Time . An ACTIONS Condition remains in effect and for plant operations makes the Required Actions apply until the Condition no longer exists or the unit the determination that an is not within the LCO Applicability.

LCO is not met and an ACTIONS Condition is If situations are discovered that require entry into more than one entered. The "otherwise Condition at a time within a single LCO (multiple Conditions) , the specified" exceptions are Required Actions for each Condition must be performed within the varied , such as a Required associated Completion Time. When in multiple Conditions, separate Action Note or Surveillance Completion Times are tracked for each Condition starting from the B Requirement Note that B iiscovery of the situation that reauired entrv into the Conditionf.

provides an alternative time I , unless otherwise specified !--------'

to perform specific tasks, Once a Condition nas been entered , subsequent divisions, subsystems ,

such as testing , without components , or variables expressed in the Condition , discovered to be starting the Completion inoperable or not within limits, will not result in separate entry into the Time . While utilizing the Condition unless specifically stated . The Required Actions of the Note, should a Condition be Condition continue to apply to each additional failure , with Completion applicable for any reason Times based on initial entrv into the Condition, not addressed by the Note, I. unless otherwise specified 1 1 the Completion Time 1 ---*:~ -....i\

begins. Should the time allowance in the Note be exceeded , the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources -

Operating ," Required Action B.1 , requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states ,

"Immediately from discovery of Condition B concurrent with inoperability of redundant required feature(s) ." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Brunswick Unit 1 1.3-1 Amendment No. 203

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results ,

determination of the acceptability of entering the MODE or other specified condition in the Applicab~

• and establishment of risk management actions , if appropria1 ~ ( xceptions to this Specification are stated in the indi al Specification§ x

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered . Only the support system LCO ACTIONS are required to be entered . This is an exception to LCO 3.0.2 for the supported system . In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11 , "Safety Function Determination Program (SFDP) ." If a loss of safety function is determined to exist by this program , the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered .

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system , the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Brunswick Unit 1 3.0-2 Amendment No. 233 I

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Appl icability for individual LCOs , unless otherwise stated in the SR.

Failure to meet a Surveillance , whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance , shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ."

basis , the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications .

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed , from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The delay period is or up to the limit of the specified Frequency, whichever is greater. This only applicable delay period is permitted to allow performance of the Surveillance . A risk when there is a e aye grea er than reasonable expectation the surveillance will be If the Surveillance is not performed within the delay period , the LCO must met when immediately be declared not met, and the applicable Condition(s) must be performed . entered .

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Brunswick Unit 1 3.0-4 Amendment No. 224

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action . It is referenced to th~ tiFRs sf ~ iscovery of a situation Unless otherwise specified , (e.g. , inoperable equipment or variable not within limits) that requires the Completion Time begins entering an ACTIONS Condition unless otherwise specified , providing the when a senior licensed unit is in a MODE or specified condition stated in the Applicability of the operator on the operating LCO . Required Actions must be completed prior to the expiration of the shift crew with responsibil ity spec1 ied Completion Time. An ACTIONS Condition remains in effect and for plant operations makes the Required Actions apply until the Condition no longer exists or the unit the determination that an is not within the LCO Applicability.

LCO is not met and an ACTIONS Condition is If situations are discovered that require entry into more than one entered . The "otherwise Condition at a time within a single LCO (multiple Conditions) , the specified " exceptions are Required Actions for each Condition must be performed within the varied , such as a Required associated Completion Time. When in multiple Conditions, separa..,te.....___

Action Note or Surveillance Requirement Note that Completion Times are tracked for each Condition starting from theltiFRs sf I discovery of the situation that re uired ent into the Condition .

provides an alternative time , unless otherwise specified to perform specific tasks, Once a Cond ition as een entere , su sequent divisions, subsystems ,

such as testing , without components , or variables expressed in the Condition , discovered to be starting the Completion inoperable or not within limits, will not result in separate entry into the Time. While utilizing the Condition unless specifically stated . The Required Actions of the Note, should a Condition be Condition continue to apply to each additional failure , with Completion applicable for any reason *

• to the Condition not addressed by the Note, the Completion Time continued begins. Should the time allowance in the Note be exceeded , the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8 .1, "AC Sources -

Operating ," Required Action 8 .1, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant requ ired feature(s) are inoperable. The Completion Time states ,

"Immediately from discovery of Condition B concurrent with inoperability of redundant required feature(s) ."

In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied .

Brunswick Unit 2 1.3- 1 Amendment No. 233

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) systems and components , consideration of the results ,

determination of the acceptability of entering the MODE or other specified condition in the Applicab~

• and establishment of risk management actions , if appropriat ~ (1 xceptions to this Specification are stated in the indi al Specification§ >r

c. When an allowance is stated in the individual value , parameter, or other Specification .

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system . In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11 , "Safety Function Determination Program (SFDP) ." If a loss of safety function is determined to exist by this program , the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered .

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system , the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Brunswick Unit 2 3.0-2 Amendment No. 260 I

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs , unless otherwise stated in the SR.

Failure to meet a Surveillance , whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once ," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ... "

basis , the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0 .3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the The delay period is LCO not met may be delayed , from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> only applicable or up to the limit of the specified Frequency, whichever is greater. This when there is a delay period is permitted to allow performance of the Surveillance. +A risk reasonable evaluation shall be performed for any Surveillance delayed greater than expectation the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed .

surveillance will be If the Surveillance is not performed within the delay period , the LCO must met when performed . immediately be declared not met, and the applicable Condition(s) must be entered .

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered .

(continued)

Brunswick Unit 2 3.0-4 Amendment No. 249

BSEP 16-0082 Enclosure 3 Revised Technical Specifications Pages

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,

inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.1, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "Immediately from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

(continued)

Brunswick Unit 1 1.3-1 Amendment No.

Completion Times 1.3 1.3 Completion Times DESCRIPTION Required Actions must be completed prior to the expiration of the (continued) specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

(continued)

Brunswick Unit 1 1.3-2 Amendment No.

Completion Times 1.3 1.3 Completion Times (continued)

DESCRIPTION The above Completion Time extension does not apply to those (continued) Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 1O day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. Required Action B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated Completion AND Time not met.

B.2 Be in MODE4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

(continued)

Brunswick Unit 1 1.3-3 Amendment No.

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-1 (continued)

The Required Actions of Condition B are to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

EXAMPLE 1.3-2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status.

B. Required Action B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated Completion AND Time not met.

B.2 Be in MODE4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

Brunswick Unit 1 1.3-4 Amendment No.

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.

LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

(continued)

Brunswick Unit 1 1.3-5 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not reqqired to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Brunswick Unit 1 3.0-2 Amendment No.

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Brunswick Unit 1 3.0-4 Amendment No.

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,

inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.1, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "Immediately from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

(continued)

Brunswick Unit 2 1.3-1 Amendment No.

Completion Times 1.3 1.3 Completion Times DESCRIPTION Required Actions must be completed prior to the expiration of the (continued) specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved .. 7 The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

(continued)

Brunswick Unit 2 1.3-2 Amendment No.

Completion Times 1.3 1.3 Completion Times (continued)

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. Required Action B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated Completion AND Time not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition Bis entered.

(continued)

Brunswick Unit 2 1.3-3 Amendment No.

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-1 (continued)

The Required Actions of Condition B are to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

EXAMPLE 1.3-2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status.

B. Required Action B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated Completion AND Time not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

Brunswick Unit 2 1.3-4 Amendment No.

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.

LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

(continued)

Brunswick Unit 2 1.3-5 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the*

OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Brunswick Unit 2 3.0-2 Amendment No.

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per ... "

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Brunswick Unit 2 3.0-4 Amendment No.

BSEP 16-0082 Enclosure 4 Proposed Technical Specifications Bases Changes (Mark-Up) - Information Only

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LC Os LCO 3.0.1 through LCO 3.0 .8 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.1O and apply at all times, unless otherwise stated .

LCO 3.0.1 LCO 3.0.1 establishes the Applicabil ity statement with in each individual Specification as the requirement for when the LCO is required to be met (i.e ., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification) .

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO ,

the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in unless otherwise time that an ACTIONS Condition is entere The Required Actions specified es a 1s ose reme 1a measures a must be taken within specified Completion Times when the requirements of an LCO are not met. Th is Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification ;

and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time , unless otherwise specified .

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time , a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS .) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the (continued)

Brunswick Unit 1 B 3.0-1 Revision No. 50

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and :

a. An associated Required Action and Completion Time is not met and no other Condition applies; or

b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stabilit and availability of the electrical grid . The time limits specified t ~ enter lower MODES of operation permit the shutdown to proceed in a contra ed and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies . The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times .

(continued)

Brunswick Unit 1 B 3.0-3 Revision No. 31

LCO Applicability B 3.0 BASES LCO 3.0 .3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs :

a. The LCO is now met.

b. The LCO is no longer f-+

&.c A Condition exists for which the Required Actions have now been applicable.

performed .

&. d ACTIONS exist that do not have expired Completion Times.

These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited .

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation . If the unit is in a lower MODE of o eration when a shutdown is re uired the time limit for~ entering the next lower MODE applies . If a lower MODE is ~entered in less time than allowed , however, the total allowable time to 'feeefit enter MODE 4 , or other applicable MODE, is not reduced . For example, if MODE 2 is FeBeAentered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for~ entering MODE 3 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for FessA entering MODE 3 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to

~ enter a lower MODE of operation in less than the total time a owe .

In MODES 1, 2, and 3 , LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2 , or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken .

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown , in accordance with LCO 3.0 .3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7. 7 , "Spent Fuel Storage Pool Water Level."

(continued)

Brunswick Unit 1 B 3.0-4 Revision No . 31

LCO Applicability B 3.0 BASES LCO 3.0.3 LCO 3.7.7 has an Applicability of "During movement of irradiated fuel (continued) assemblies in the spent fuel storage pool. " Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of For example , LCO 3.0.4.a LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit may be used when the Required Action to be to be gained by placing the unit in a shutdown condition . The Required entered states that an Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies inoperable instrument in the spent fuel storage pool" is the appropriate Required Action to channel must be placed in the complete in lieu of the actions of LCO 3.0.3. These exceptions are trip condition within the addressed in the individual Specifications.

Completion Time. Transition into a MODE LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other ' placing or other specified the unit in a MODE or other specified condition stated in that Applicability condition in the (e.g., the Applicability desired to be entered) when unit conditions are Applicability may be made sue~ requirements of the LCO would not be met, in accordance in accordance with LCO wit~ CO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

3.0.4 and the channel is LCO 3.0.4.a allows entry into a MODE or other specified condition in the subsequently placed in the . .. . .

tripped condition within the entered following entry into ~erA'lit eeF1tiF1l!leB e~eretieFI iFI the MODE or Completion Time, which other specified condition in the Applicability will permit continued begins when the operation within the MODE or other specified condition for an Applicability is entered . If unlimited period of time. Compliance with ACTIONS Re~l!lires i'\etieF1e the instrument channel that permit continued operation of the unit for an unlimited period of time cannot be placed in the in a MODE or other specified condition provides an acceptable level of tripped condition and the safety for continued operation . This is without regard to the status of the subsequent default unit before or after the MODE change. Therefore , in such cases, entry ACTION ("Required Action into a MODE or other specified condition in the Applicability may be mad and associated

• * * * . and the Completion Time not met") Required Actions followed after entry into the Applicability.

allows the OPERABLE train to be placed in LCO 3.0.4.b allows entry into a MODE or other specified condition in the operation , use of LCO Applicability with the LCO not met after performance of a risk assessment 3.0.4.a is acceptable addressing inoperable systems and components , consideration of the because the subsequent results, determination of the acceptability of entering the MODE or other ACTIONS to be entered specified condition in the Applicability, and establishment of risk following entry into the management actions, if appropriate.

MODE include ACTIONS (place the OPERABLE The risk assessment may use quantitative, qualitative , or blended train in operation) that approaches, and the risk assessment will be conducted using the plant permit safe plant operation program , procedures, and criteria in place to implement for an unlimited period of 10 CFR 50 .65(a)(4) , which requires that risk impacts of maintenance time in the MODE or other activities to be assessed and managed . The risk assessment, for the specified condition to be purposes of LCO 3.0.4.b, must take into account all inoperable Technical entered. Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope . The (continued)

Brunswick Unit 1 B 3.0-5 Revision No. 41

LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with LCO Applicabil ity Required Actions and that do not require changing the MODE or other specified conditions in B 3.0 the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

BASES LCO 3.0.5 The administrative controls ensure the time the equipment is returned to (continued) service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance.+

AFl 8118Fl'lf!!l8 Bf B8Fl'l8Fl8tF8tiFl~ U;ie OPli!RiA:l!llLITY Bf U;ie 8~~if!!Fl'l8Flt BBiFl~

ret~FFleel ts eervise is FBBf!!BFliFl~ s ssF1tsiF1Fl'IBF1t isslstisFl ¥81¥e H;ist R8B 13eeR slseeel ts BBFl'lf!!IY witR Re~~ireel AstiBFlB 8Flel Fl'l~Bt 13e FSBf!!SFleel ts J!!8FfBFFl'I tRe eRB .

~ Examples of demonstrating the OPERABILITY of other equipment -t& are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of~

I required testing!_ _ _ _ ., ~ on another channel in the other trip system , or 2) . >°< 3i111iler e>Ee1 iil'le Bf B8Fl'l8Fl8tF8tiFl~ tRe OPli!RAl!llLITY sf etRBF 8~~if!!Fl'l8Flt ie tsltiFl~ 8Fl iFlBf!!8F8Bl8 8R8FlFl81 BF tFif!! syeteFl'I B~t Bf tRS tFif!!f!!8el 88FlelitiBFl to permit the logic to function and indicate the appropriate response during the performance of ~ f on another channel in the same trip system .

~---------::: I required testing!

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that r - - -.....- - - - - - - - - have an LCO specified in the Technical Specifications (TS) . This The administrative controls in exception is provided because LCO 3.0.2 would require that the LCO 3.0.5 apply in all cases to Conditions and Required Actions of the associated inoperable supported systems or components in Chapter 3 of the Technical system's LCO be entered solely due to the in operability of the support Specifications, as long as the system . This exception is justified because the actions that are required testing could not be conducted to ensure the plant is maintained in a safe condition are specified in the while complying with the support system's LCO's Required Actions . These Required Actions may Required Actions. This includes include entering the supported system's Conditions and Required Actions the realignment or repositioning or may specify other Required Actions.

of redundant or alternate equipment or trains previously When a support system is inoperable and there is an LCO specified for it manipulated to comply with in the TS, the supported system(s) are required to be declared inoperable ACTIONS, as well as if determined to be inoperable as a result of the support system equipment removed from inoperability.

service or declared inoperable

<continued) to comply with ACTIONS.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel.

Brunswick Unit 1 B 3.0-8 Revision No . 41

SR Applicability B 3.0 BASES SR 3.0.2 SR 3.0.2 permits a 25% extension of the interval specified in the (continued) Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities) .

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs . The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of "in accordance with 10 CFR 50 , Appendix J, as modified by approved exemptions." The requirements of regulations take precedence over the TS . The TS cannot in and of themselves extend a test interval specified in the regulations .

As stated in SR 3.0 .2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per. .. " basis . The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action ,

whether it is a particular Surveillance or some other remedial action , is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly FRsrsly 88 BR s~sratiBRBI 88R'l8Ri8R88 to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified .

(continued)

Brunswick Unit 1 B 3.0-14 Revision No. 50

SR Applicability B 3.0 BASES (continued)

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a SR 3.0.3 is only applicable if Surveillance has not been 88"318ts8 performed within the specified there is a reasonable Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the expectation the associated specified Frequency, whichever is greater, applies from the point in time equipment is OPERABLE or that it is discovered that the Surveillance has not been performed in that variables are within accordance with SR 3.0 .2, and not at the time that the specified limits, and it is expected that the Surveillance will be met Frequency was not met.

when performed. Many This delay period provides adequate time to 88"'!!!1ete perform factors should be considered , Surveillances that have been missed . This delay period permits the such as the period of time 88"318tiei;i performance of a Surveillance before complying with since the Surveillance was Required Actions or other remedial measures that might preclude last performed , or whether 88"'!!!1etiei;i performance of the Surveillance .

the Surveillance, or a portion thereof, has ever been The basis for this delay period includes consideration of unit conditions ,

performed , and any other adequate planning , availability of personnel , the time required to perform indications, tests, or activities the Surveillance, the safety significance of the delay in completing the that might support the required Surveillance, and the recognition that the most probable result of expectation that the any particular Surveillance being performed is the verification of Surveillance will be met when conformance with the requirements.

performed . An example of the use of SR 3.0 .3 would be When a Surveillance with a Frequency based not on time intervals, but a relay contact that was not upon specified unit conditions , operating situations, or requirements of tested as required in regulations (e.g ., prior to entering MODE 1 after each fuel loading , or in accordance with a particular accordance with 10 CFR 50, Appendix J, as modified by approved SR, but previous successful exemptions , etc.) is discovered not to have been performed when performances of the SR specified , SR 3.0.3 allows for the full delay period of up to the specified included the relay contact; Frequency to perform the Surveillance. However, since there is not a the adjacent, physically time interval specified , the missed Surveillance should be performed at connected relay contacts the first reasonable opportunity.

were tested during the SR performance; the subject SR 3.0.3 also provides a time limit for , and allowances for the relay contact has been tested performance of, Surveillances that become applicable as a consequence by another SR ; or historical of MODE changes imposed by Required Actions .

operation of the subject relay Failure to comply with specified Frequencies for SRs is expected to be an contact has been successful.

infrequent occurrence. Use of the delay period established by SR 3.0.3 is It is not sufficient to infer the a flexibility which is not intended to be used repeatedly e~ e!'ll 8'38Fetisl'llel behavior of the associated equipment from the 88Fl'w'8Fli8Fl88 to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the performance of similar <continued) equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed . For Surveillances that have not been performed for a long period or that have never been performed , a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE.

The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

Brunswick Unit 1 B 3.0-15 Revision No. 50