RA-18-0079, Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

ML18227A535
Person / Time
Site:	Brunswick
Issue date:	08/14/2018
From:	Gideon W R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-18-0079
Download: ML18227A535 (89)

Text

Completion Times 1.3 Brunswick Unit 1 1.3-3 Amendment No. 281 1.3 Completion Times 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 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 CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated

Completion

Time not met. B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

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

AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-5 Amendment No. 282 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE status. ---------NOTE----------

Until DG 4 is

returned to

OPERABLE status, not to exceed 0745

EST on December 13, 2017, the 14 day and

17 day Completion

Times are extended

to 30 days and

33 days, respectively.

---

7 days from discovery of

unavailability of

SUPP-DG AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of

Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure

to meet LCO 3.8.1.a

or b (continued)

AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-7 Amendment No. 282 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.2 -------------------------------NOTES------------------------------ 1. All DG starts may be preceded by an engine prelube period. 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used

for this SR. When modified start procedures are

not used, the time, voltage, and frequency

tolerances of SR 3.8.1.7 must be met. 3. A single test at the specified Frequency will satisfy this Surveillance for both units. 4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3

may be suspended. Past due surveillances will

be completed within 7 days of restoration of

EDG 4 operability or December 20, 2017, whichever occurs first.

---

Verify each DG starts from standby conditions and achieves steady state voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance

Frequency Control

Program (continued)

AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-8 Amendment No. 282 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------------------NOTES------------------------------ 1. DG loadings may include gradual loading. 2. Momentary transients outside the load range do not invalidate this test. 3. This Surveillance shall be conducted on only one DG at a time. 4. This SR shall be preceded by and immediately follow, without shutdown, a successful

performance of SR 3.8.1.2 or SR 3.8.1.7. 5. A single test at the specified Frequency will satisfy this Surveillance for both units. 6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3

may be suspended. Past due surveillances will

be completed within 7 days of restoration of

EDG 4 operability or December 20, 2017, whichever occurs first.

---

Verify each DG is synchronized and loaded and operates for 60 minutes at a load 2800 kW and 3500 kW.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of fuel oil.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.5 Check for and remove accumulated water from each engine mounted tank.

In accordance with the Surveillance

Frequency Control

Program (continued)

AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-9 Amendment No. 282 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------

Until DG 4 is returned to OPERABLE status, not to

exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may

be suspended. Past due surveillances will be

completed within 7 days of restoration of EDG 4

operability or December 20, 2017, whichever occurs

first.

---

Verify the fuel oil transfer system operates to transfer fuel oil from the day fuel oil storage tank to the engine

mounted tank.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.7 -------------------------------NOTES------------------------------ 1. All DG starts may be preceded by an engine prelube period. 2. A single test at the specified Frequency will satisfy this Surveillance for both units.

---

Verify each DG starts from standby condition and achieves, in 10 seconds, voltage 3750 V and frequency 58.8 Hz, and after steady state conditions are reached, maintains voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance

Frequency Control

Program (continued)

Distribution Systems-Operating 3.8.7 Brunswick Unit 1 3.8-36 Amendment No. 280 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIMED. One or more DC electrical power distribution

subsystems inoperable for

reasons other than

Condition C. D.1 Restore DC electrical power distribution

subsystems to OPERABLE

status. 7 days AND 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> from discovery of failure

to meet LCO E. Required Action and associated Completion Time

of Condition A, B, C, or D

not met. 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 /> F. Two or more electrical power distribution

subsystems inoperable that

result in a loss of function. F.1 Enter LCO 3.0.3. Immediately

Completion Times 1.3 Brunswick Unit 2 1.3-3 Amendment No. 309 1.3 Completion Times 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 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 CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met. B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

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

AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-5 Amendment No. 310 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE status. ---------NOTE----------

Until DG 4 is

returned to

OPERABLE status, not to exceed 0745

EST on December 13, 2017, the 14 day and

17 day Completion

Times are extended

to 30 days and

33 days, respectively.

---

7 days from discovery of

unavailability of

SUPP-DG AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of

Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure

to meet LCO 3.8.1.a

or b (continued)

AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-7 Amendment No. 310 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.2 ----------------------------NOTES---------------------------------- 1. All DG starts may be preceded by an engine prelube period. 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used

for this SR. When modified start procedures are

not used, the time, voltage, and frequency

tolerances of SR 3.8.1.7 must be met. 3. A single test at the specified Frequency will satisfy this Surveillance for both units. 4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3

may be suspended. Past due surveillances will

be completed within 7 days of restoration of

EDG 4 operability or December 20, 2017, whichever occurs first.

---

Verify each DG starts from standby conditions and achieves steady state voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance

Frequency Control

Program (continued)

AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-8 Amendment No. 310 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 ----------------------------NOTES---------------------------------- 1. DG loadings may include gradual loading. 2. Momentary transients outside the load range do not invalidate this test. 3. This Surveillance shall be conducted on only one DG at a time. 4. This SR shall be preceded by and immediately follow, without shutdown, a successful

performance of SR 3.8.1.2 or SR 3.8.1.7. 5. A single test at the specified Frequency will satisfy this Surveillance for both units. 6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3

may be suspended. Past due surveillances will

be completed within 7 days of restoration of

EDG 4 operability or December 20, 2017, whichever occurs first.

---

Verify each DG is synchronized and loaded and operates for 60 minutes at a load 2800 kW and 3500 kW.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of fuel oil.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.5 Check for and remove accumulated water from each engine mounted tank.

In accordance with the Surveillance

Frequency Control

Program (continued)

AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-9 Amendment No. 310 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------

Until DG 4 is returned to OPERABLE status, not to

exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may

be suspended. Past due surveillances will be

completed within 7 days of restoration of EDG 4

operability or December 20, 2017, whichever occurs

first.

---

Verify the fuel oil transfer system operates to transfer fuel oil from the day fuel oil storage tank to the engine

mounted tank.

In accordance with the Surveillance

Frequency Control

Program SR 3.8.1.7 ----------------------------NOTES---------------------------------- 1. All DG starts may be preceded by an engine prelube period. 2. A single test at the specified Frequency will satisfy this Surveillance for both units.

---

Verify each DG starts from standby condition and achieves, in 10 seconds, voltage 3750 V and frequency 58.8 Hz, and after steady state conditions are reached, maintains voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance

Frequency Control

Program (continued)

Distribution Systems-Operating 3.8.7 Brunswick Unit 2 3.8-36 Amendment No. 308 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC electrical power distribution

subsystems inoperable for

reasons other than

Condition C. D.1 Restore DC electrical power distribution

subsystems to OPERABLE

status. 7 days AND 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> from discovery of failure

to meet LCO E. Required Action and associated Completion Time

of Condition A, B, C, or D

not met. 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 /> F. Two or more electrical power distribution

subsystems inoperable that

result in a loss of function. F.1 Enter LCO 3.0.3. Immediately

Distribution Systems-Operating B 3.8.7 Brunswick Unit 1 B 3.8.7-13 Revision No. 97 BASES ACTIONS D.1 (continued) distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be

restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in

establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition D was entered. The 176 hour0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> Completion

Time is an acceptable limitation on this potential of failing to meet the

LCO indefinitely.

E.1 If the inoperable electrical power distribution subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which overall plant risk is

minimized. To achieve this status, the plant must be brought to at least

MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and

because the time spent in MODE 3 to perform the necessary repairs to

restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable

low-risk state.

Required Action E.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of

LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment

addressing inoperable systems and components, consideration of the

results, determination of the acceptability of entering MODE 3, and

establishment of risk management actions, if appropriate. LCO 3.0.4 is

not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power

conditions in an orderly manner and without challenging plant systems.

F.1 Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost.

(continued)