Text

Brunswick, Units 1 and 2 - License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A.
	ML16287A415
Person / Time
Site:	Brunswick
Issue date:	09/28/2016
From:	Gideon W R; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 16-0087, TSC-2016-07
	Download: ML16287A415 (133)
	v • d • e

ef-..DUKE William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 September 28, 2016 Serial: BSEP 16-0087 TSC-2016-07 U.S. Nuclear Regulatory Commission ATIN: 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 10 CFR 50.90 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A" Ladies and Gentlemen:

In accordance with the provisions of Title 1 O of the Code of Federal Regulations (1 O CFR) Section 50.90, Duke Energy Progress, LLC (Duke Energy), is submitting a request for an amendment to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Technical Specifications (TS) to incorporate the NRG-approved TSTF-423, Revision 1. The proposed amendment would modify TS to risk-inform requirements regarding selected Required Action end states by incorporating the Boiling Water Reactor (BWR) Owners' Group (BWROG) approved Topical Report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants." Additionally, the proposed amendment would modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (i.e., Mode 3) on reactor startup. Enclosure 1 provides a description and assessment of the proposed change, the requested confirmation of applicability, and plant-specific verifications.

Enclosures 2 and 3 provide marked-up pages of existing Unit 1 and Unit 2 TS, respectively, to show the proposed changes. Enclosure 4 and 5 provide revised (i.e., typed) TS pages for Unit 1 and 2, respectively.

Enclosure 6 provides marked-up pages of existing Unit 1 TS Bases, for information only. Enclosure 7 summarizes the regulatory commitments made in this submittal.

Duke Energy requests approval of the proposed license amendment by September 28, 2017, with the amendment being implemented within 120 days. In accordance with 1 O CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager -Regulatory D \ Affairs, at (910) 457-2487. 0 U.S. Nuclear Regulatory Commission Page 2 of 3 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September 28, 2016. Sincerely, William R. Gideon MAT/mat

Enclosures:

1. Description and Assessment of the Proposed Change 2. Marked-up Technical Specifications Pages -Unit 1 3. Marked-up Technical Specifications Pages -Unit 2 4. Revised Technical Specifications Pages -Unit 1 5. Revised Technical Specifications Pages -Unit 2 6. Marked-up Technical Specifications Bases Pages -Unit 1 (For Information Only) 7. Regulatory Commitments U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with enclosures):

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: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle 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 Description and Assessment of the Proposed Change BSEP 16-0087 Enclosure 1 Page 1 of 11

Subject:

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A" 1.0 Description The proposed amendment will modify Technical Specifications (TS) to risk-inform requirements regarding selected Required Action end states. Additionally, it will modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (Mode 3) on reactor startup. The changes are consistent with Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," dated December 22, 2009 (i.e., ADAMS Accession Number ML093570241) (Reference 1 ). The Federal Register notice published on February 18, 2011 (76 FR 34) (Reference

2) announced the availability of this TS improvement as part of the consolidated line item improvement process (CLllP). 2.0 Assessment 2.1 Applicability of Topical Report NEDC-32988-A, TSTF-423, and Model Safety Evaluation Duke Energy Progress, LLC, (Duke Energy) has reviewed Boiling Water Reactor (BWR) Owners' Group (BWROG) topical report (TR) NEDC-32988-A (Reference 3), TSTF-423, Revision 1 (Reference 1 ), and the NRG staff's model safety evaluation (SE) (Reference

4) as part of the CLllP. Duke Energy has concluded that the information in TR NEDC-32988-A, TSTF-423, and the NRG staff's model SE are applicable to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, and justify this license amendment request (LAR) for the incorporation of the changes to the BSEP TSs. 2.2 Optional Changes and Variations Duke Energy is proposing variations or deviations from TR NEDC-32988-A, the TS changes described in TSTF-423, Revision 1, or the NRG staff's model SE referenced in the Federal Register on February 18, 2011 (76 FR 34) as part of the CLllP Notice of Availability.

The proposed variations/deviations and their effects are discussed in the following table. No. BSEPTS Title Variation/Deviation Comments 1. 3.3.8.2 Reactor No changes to BSEP The existing BSEP TS 3.3.8.2 Protection TS 3.3.8.2 are proposed.

does not include a Required System (RPS) Action to be in Mode 4. Electrical Power Therefore, no change is Monitoring necessary.

No. BSEPTS Title Variation/Deviation

2. 3.4.3 Safety/Relief No changes to BSEP Valves (SRVs) TS 3.4.3 are proposed.

3. 3.5.1 ECCS-Condition C of BSEP TS 3.5.1 Operating is proposed to be revised per TSTF-423; however, it applies when Conditions A or B are not met. Conditions in BSEP TS 3.5.1 are numbered differently from the Standard TS Conditions.

4. N/A Low-Low Set No changes corresponding to (LLS) Valves Standard TS 3.6.1 .6 are proposed.

5. 3.6.1.5 Reactor Building-BSEP TS 3.6.1.5 corresponds to-Suppression to Standard TS 3.6.1.7. New Chamber Condition F, applicable to Vacuum Condition E is added. Breakers BSEP TS 3.6.1.5 Conditions for which Mode 4 shutdown remains applicable are included in renumbered Condition G. BSEP 16-0087 Enclosure 1 Page 2 of 11 Comments The Standard TS, Condition A is not applicable to BSEP. BSEP TS 3.4.3, Condition A, corresponds to the proposed Condition C in TSTF-423; which includes the Mode 4 requirement.

Therefore, no changes are proposed to BSEP TS 3.4.3. Condition A of the Standard TS and Condition A of the BSEP TS 3.5.1 are equivalent.

BSEP TS 3.5.1 includes Condition B for one Low Pressure Coolant Injection (LPCI) pump and one Core Spray (CS) subsystem inoperable concurrently.

The justification provided in the topical report and model Safety Evaluation for this change is also applicable to Condition B of the BSEP TS 3.5.1. The BSEP TSs do not include a specification for LLS Valves. BSEP TS 3.6.1.5 includes Conditions C and D, which address the Nitrogen Backup System. Similar Conditions are not included in the Standard TS 3.6.1 . 7. The proposed BSEP change is equivalent to the change to Standard TS 3.6.1.7 in TSTF-423, in that it applies to one line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening. BSEP TS 3.6.1 .5 Conditions for which Mode 4 shutdown remains applicable are included in renumbered

... _No. BSEP TS ,. '>, : .Title .. . * * .. ' .. 6. 3.6.1.6 Suppression BSEP TS 3.6.1.6 corresponds Chamber-to-to Standard TS 3.6.1.8. Drywall Vacuum Breakers 7. N(A Main Steam No changes corresponding to Isolation Valve Standard TS 3.6.1 .9 are * (MSIV) Leakage proposed.

Control System (LCS) 8. N/A Residual Heat No changes corresponding to Removal (AHR) Standard TS 3.6.2.4 are Suppression Pool proposed.

Spray 9. 3.6.4.3 Standby Gas The changes associated with Treatment (SGT) Standard TS 3.6.4.3, System Required Action D.1 are reflected in the Required Actions for BSEP TS 3.6.4.3 Condition B. BSEP 16-0087 Enclosure 1 Page 3 of 11 *'* o . . _con, merits* . Condition G. This is equivalent to the intent of the change to renumbered Condition F TSTF-423 for Standard TS 3.6.1.7. The changes proposed to BSEP TS 3.6.1.6 are equivalent to the change to the Standard TS 3.6.1.8 in TSTF-423.

Only the TS number differs. The BSEP TSs do not include a specification for an MSIV LCS. The BSEP TSs do not include a specification for an AHR Suppression Pool Spray. Standard TS 3.6.4.3 Condition A applies to inoperability of one SGT subsystem.

Standard TS 3.6.4.3 Condition D applies to inoperability of two SGT subsystems.

The changes to the Standard TS 3.6.4.3 in TSTF-423 allows the unit to remain in Mode 3 under these conditions.

BSEP TS 3.6.4.3 addresses inoperability of one SGT subsystem in Condition A. BSEP TS 3.6.4.3 Condition B provides the shutdown requirements for failure to meet the Completion Time of Condition A and for inoperability of two SGT subsystems.

As such, only BSEP TS 3.6.4.3 Condition B is revised to provide equivalent changes to those in TSTF-423 for Standard TS 3.6.4.3.

No. BSEP TS Title Variation/Deviation

10. 3.7.1 Residual Heat The addition of the new Removal Service Condition D in Standard Water (RHRSW) TS 3.7.1 is proposed as a System new Condition C in BSEP TS3.7.1. Conditions in BSEP TS 3.7.1 are numbered differently from the Standard TS 3.7.1 Conditions.

11. 3.7.2 Service Water No changes to BSEP (SW) System and TS 3.7.2 are proposed.

Ultimate Heat Sink (UHS) BSEP 16-0087 Enclosure 1 Page 4 of 11 Comments Both the BSEP and the Standard TS 3.7.1 Condition A addresses inoperability of one RHRSW pump. Standard TS 3.7.1 Condition B addresses inoperability of one RHRSW pump in each subsystem.

Standard TS 3.7.1 Condition C addresses inoperability of a RHRSW for reasons other than Condition A. BSEP TS 3.7.1 does not have a Condition equivalent to Standard TS 3.7.1 Condition B. Rather, BSEP TS 3.7.1 Condition B addresses inoperability of a RHRSW for reasons other than Condition A (i.e., which would include inoperability of one RHRSW pump in each subsystem).

As such, adding the new BSEP TS 3.7.1 Condition C provides an equivalent change to that in TSTF 423 for Standard TS 3.7.1. The justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.7.2 are based on a typical two subsystem configuration.

The BSEP SW system consists of four site nuclear service water pumps and three conventional service water pumps per plant. Based on the significant differences, no changes to BSEP TS 3.7.2 are proposed.

No. BSEP TS Title Variation/Deviation

12. 3.7.3 Control Room BSEP TS 3.7.3 corresponds Emergency to Standard TS 3.7.4. Ventilation The changes associated with (GREV) System Standard TS 3.7.4, Required Action E.1 and E.2 are reflected in the Required Actions for BSEP TS 3.7.3 Condition C. 13. 3.7.4 Control Room Air BSEP TS 3.7.4 corresponds Conditioning (AC) to Standard TS 3.7.5. System BSEP TS 3.7.4 is revised to allow the units to remain in Mode 3 when three subsystems of the Control Room AC system are inoperable.

Conditions in BSEP TS 3.7.4 are numbered differently from the Standard TS Conditions.

BSEP 16-0087 Enclosure 1 Page 5 of 11 Comments Standard TS 3.7.4 Condition A applies to inoperability of one Main Control Room Environmental Control (MCREC) subsystem.

Standard TS 3.7.4 Condition E applies to inoperability of two MCREC subsystems.

The changes to the Standard TS 3.7.4 in TSTF-423 allow the unit to remain in Mode 3 under these conditions.

BSEP TS 3.7.3 addresses inoperability of one GREV subsystem (i.e., plant specific nomenclature corresponding to MCREC) in Condition A. BSEP TS 3.7.3 Condition C provides the shutdown requirements for failure to meet the Completion Time of Condition A, Condition B, and for inoperability of two GREV subsystems.

As such, only BSEP TS 3.7.3 Condition C is revised to provide equivalent changes to those in TSTF-423 for Standard TS 3.7.4. Standard TS 3.7.5 applies to a typical Control Room AC system which consists of two independent, redundant subsystems.

The BSEP Control Room AC system consists of three 50 percent capacity subsystems and BSEP TS 3.7.4 reflects this design. The justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.7.5 allows a unit to remain in Mode 3 when both subsystems of the Control Room AC system are inoperable.

The proposed changes to BSEP TS 3.7.4 remain consistent with No. BSEP TS Title Variation/Deviation

14. 3.7.5 Main Condenser BSEP TS 3.7.5 corresponds Off gas to Standard TS 3.7.6. 15. 3.8.1 AC Sources -Condition H of BSEP TS 3.8.1 Operating is proposed to be revised per TSTF-423.

As a result, the TSTF-423 changes will be applied to BSEP TS 3.8.1, Conditions A and B, which are plant specific and not included in Standard TS 3.8.1. Conditions in BSEP TS 3.8.1 are numbered differently from the Standard TS Conditions.

I BSEP 16-0087 Enclosure 1 Page 6 of 11 Comments TSTF-423 by allowing the units to remain in Mode 3 under the loss of function condition.

The only variation is associated with the TS number. The changes to the Standard TS 3.7.6 in TSTF-423 were incorporated, as presented, in the proposed change to BSEP TS 3.7.5. Standard TS 3.8.1 applies to typical AC source design. BSEP TS 3.8.1 reflects the unique BSEP AC source design and, as a result, requires two Unit 1 and two Unit 2 qualified circuits and four separate and independent diesel generators to be operable when in Modes 1, 2, or 3. To accommodate maintenance activities, BSEP TS 3.8.1, Conditions A and B, are specific to AC sources primarily associated with the opposite unit (e.g., Conditions A and B of BSEP Unit 1 TS 3.8.1 are applicable to offsite circuits and diesel generators primarily associated with Unit 2). The proposed changes to BSEP TS 3.8.1 remain consistent with TSTF-423 in that an affected unit will be allowed to remain in Mode 3 given similar level degradation of AC sources. The justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.8.1 is applicable to BSEP.

No. BSEPTS Title Variation/Deviation

16. 3.8.4 DC Sources -The changes associated with Operating Standard TS 3.8.4, Required Action D.1 and D.2 are reflected in the Required Actions for BSEP TS 3.8.4 Condition B. The existing BSEP TS 3.8.4 Condition B addresses the failure to complete Condition A within the allowed Completion Time and inoperability of more than one DC electrical power subsystem.

This Condition has been revised to address only the failure to complete Condition A within the allowed Completion Time. A new Condition C addresses inoperability of more than one DC electrical power subsystem.

The changes associated with Standard TS 3.8.4 are not applicable to the new BSEP TS 3.8.4 Condition C. 17. N/A Inverters

-No changes corresponding to Operating Standard TS 3.8.7 are proposed.

BSEP 16-0087 Enclosure 1 Page 7 of 11 Comments Standard TS 3.8.4 includes Conditions associated with battery chargers, discrete batteries, and DC electrical power subsystems.

BSEP TS 3.8.4 is applicable only to the DC electrical power subsystem level. Standard TS 3.8.4 does not address inoperability of multiple DC electrical power subsystems but BSEP TS 3.8.4 does. Also, the Standard TS 3.8.4 reflects a typical configuration consisting of two DC electrical power subsystems.

The BSEP configuration requires both the Unit 1 and Unit 2 DC electrical power subsystems to be operable with a unit in Modes 1, 2, or 3. Consistent with the TSTF-423 changes to Standard TS 3.8.4, the allowance to remain in Mode 3 with one inoperable DC electrical power subsystem is applied to the revised BSEP TS 3.8.4 Condition B. Under both the Standard TS 3.8.4 configuration and the BSEP configuration, loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed.

Therefore, the justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.8.4 is applicable to BSEP. The BSEP TSs do not include a specification for Inverters.

No. BSEP TS Title Variation/Deviation

18. 3.8.7 Distribution BSEP TS 3.8.7 corresponds System -to Standard TS 3.8.9. Operating Condition D of BSEP TS 3.8.7 is proposed to be revised per TSTF-423.

As a result, the TSTF-423 changes will be applied to BSEP TS 3.8.7, Condition A which is plant specific and not included in Standard TS 3.8.9. Conditions in BSEP TS 3.8.7 are numbered differently from the Standard TS 3.8.9 Conditions.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Analysis BSEP 16-0087 Enclosure 1 Page 8 of 11 Comments Standard TS 3.8.9 applies to typical Distribution system design. BSEP TS 3.8.7 reflects the unique BSEP Distribution system design and, as a result, requires emergency bus 1 (i.e., E1 ), E2, E3, and E4 load groups to be operable when the unit is in Modes 1, 2, or 3. Load groups E1 and E2 primarily serve Unit 1 loads and load groups E3 and E4 load groups primarily serve Unit 2 loads. To accommodate maintenance activities, BSEP TS 3.8.7, Condition A, is specific to load groups primarily associated with the opposite unit (e.g., Condition A of BSEP Unit 1 TS 3.8.7 is applicable to Load Groups 3 and 4, primarily associated with Unit 2). The proposed changes to BSEP TS 3.8. 7 remain consistent with TSTF-423 in that an affected unit will be allowed to remain in Mode 3 given similar level degradation.

The justification provided in the topical report and model Safety Evaluation for changes to Standard TS 3.8.9 is applicable to BSEP. Duke Energy has evaluated the proposed changes to the Technical Specifications (TS) using the criteria in 1 O CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Description of Amendment Request: A change is proposed to the TS of the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, consistent with TSTF-423, Revision 1, to allow, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed consistent with the program in place for complying with the BSEP 16-0087 Enclosure 1 Page 9 of 11 requirements of 1 O CFR 50.65(a)(4).

Changes proposed in TSTF-423 will be made to the BSEP TSs for selected Required Action end states. Basis for no significant hazards consideration determination:

As required by 1 O CFR 50.91 (a), Duke Energy analysis of the issue of no significant hazards consideration is presented below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No The proposed change allows a change to certain required end states when the TS Completion Times for remaining in power operation will be exceeded.

Most of the requested TS changes are to permit an end state of hot shutdown (Mode 3) rather than an end state of cold shutdown (Mode 4) contained in the current TS. The request was limited to: (1) those end states where entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical.

Risk insights from both the qualitative and quantitative risk assessments were used in specific TS assessments.

Such assessments are documented in Section 6 of topical report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants." They provide an integrated discussion of deterministic and probabilistic issues, focusing on specific TSs, which are used to support the proposed TS end state and associated restrictions.

The NRC staff finds that the risk insights support the conclusions of the specific TS assessments.

Therefore, the probability of an accident previously evaluated is not significantly increased, if at all. The consequences of an accident after adopting TSTF-423 are no different than the consequences of an accident prior to adopting TSTF-423.

Therefore, the consequences of an accident previously evaluated are not significantly affected by this change. The addition of a requirement to assess and manage the risk introduced by this change will further minimize possible concerns.

Therefore, the proposed 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 does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed).

If risk is assessed and managed, allowing a change to certain required end states when the TS Completion Times for remaining in power operation are exceeded (i.e., entry into hot shutdown rather than cold shutdown to repair equipment) will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated.

The addition of a requirement to assess and manage the risk introduced by this change and the commitment by the BSEP 16-0087 Enclosure 1 Page 10 of 11 licensee to adhere to the guidance in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A,'" will further minimize possible concerns.

Thus, based on the above, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

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

No The proposed change allows, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed. The BWROG's risk assessment approach is comprehensive and follows NRC staff guidance as documented in Regulatory Guides (RG) 1.174 and 1.177. In addition, the analyses show that the criteria of the three-tiered approach for allowing TS changes are met. The risk impact of the proposed TS changes was assessed following the three-tiered approach recommended in RG 1.177. A risk assessment was performed to justify the proposed TS changes. The net change to the margin of safety is insignificant.

Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based upon the reasoning presented above, Duke Energy concludes that the requested change involves no significant hazards consideration, as set forth in 1 O CFR 50.92(c), "Issuance of Amendment." 3.2 Verifications, Commitments, and Additional Information Needed Duke Energy commits to the regulatory commitments in Enclosure

7. In addition, Duke Energy has proposed TS Bases consistent with TSTF-423, Revision 1, which provide guidance and details on how to implement the new requirements.

Implementation of TSTF-423 requires that risk be managed and assessed, and the licensee's configuration risk management program is adequate to satisfy this requirement.

The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more systems are not able to perform their associated function.

Finally, Duke Energy has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS). 4.0 Environmental Evaluation The proposed change would change a requirement with respect to installation or use of a facility c9mponent located \Nithin the restricted area, as defined in 1 O CFR Part 20, and 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 occup2tional radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in i O CFR 51.22(c)(9).

Therefore, pursuant to i O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 References BSEP 16-0087 Enclosure 1 Page 11 of 11 1. TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," dated December 22, 2009 (ADAMS Accession No. ML093570241

). 2. Federal Register, Vol. 76, No. 34, p.9614, "Notice of Availability of the Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A,'

for Boiling Water Reactor Plants Using the Consolidated Line Item Improvement Process," (ADAMS Accession No. ML 102730585).

3. NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants," December 2002 (ADAMS Package Accession No. ML030170090).

4. NRC Model Safety Evaluation of TSTF-423, Revision 1, dated February 18, 2011 (ADAMS Accession No. ML 102730688).

Marked-up Technical Specifications Pages -Unit 1 Enclosure 2 Contains the following Marked-up Unit 1 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36 BSEP 16-0087 Enclosure 2

EC CS-Operating

N 0 TE------------

3.5.1 A LCO 3.0.4.a i s not I\ CTIOt\ applicable whe n e n te rin g MODE 3.

ACTION --------------------------

COMPLETION TIME , C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met. AN9 B e iR MGQE 4. de t:ie1::1Fs D. HPCI System inoperable. D.1 Verify by administrative Immediately means RCIC System is OPERABLE.

AND D.2 Restore HPCI System to 14 days OPERABLE status. E. HPCI System inoperable.

E.1 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status. AND OR One low pressure ECCS injection/spray subsystem is E.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable.

ECCS injection/spray subsystem to OPERABLE status. F. One required ADS valve F.1 *Restore required ADS valve 14 days inoperable. to OPERABLE status. (continued)

Brunswick Un i t 1 3.5-2 Amendment No.

ACTIONS continued CONDITION REQUIRED ACTION G. One required ADS valve G.1 Restore required ADS valve inoperable. to OPERABLE status. AND OR One low pressure ECCS G.2 Restore low pressure injection/spray subsystem ECCS injection/spray inoperable.

subsystem to OPERABLE status. H. One required ADS valve H.1 Restore required ADS valve inoperable. to OPERABLE status. AND OR HPCI System inoperable. H.2 Restore HPCI System to OPERABLE status. Required Aotion and -h4 K-@]Be in MODE 3. assooiated Comp l etion Time of Condition D , E , F , G , or H AND J.1 not met. Reduce reactor steam Two or more required ADS valves inoperable.

I. Required Act i on and 1.1 associated Completion T i me of Condit i on D , E , F , G , o r H not met. Brunswick Unit 1 dome pressure to ::; 150 psig. -----NOTE LCO 3.0.4.a i s not applicable w hen entering MODE 3. Be i n MODE 3. 3.5-3 ECCS-Operating 3.5.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Amendment No.

ACTIONS (continued)

CONDITION Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A or B. HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION J4 Enter LCO 3.0.3. SURVEILLANCE ECCS-Operating 3.5.1 COMPLETION TIME Immediately FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem , the 31 days piping is filled with water from the pump discharge valve to the injection valve. (continued)

Brunswick Unit 1 3.5-4 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS ----------------------------------------------------------NOl"E LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLEl"ION TIME A. RCIC System inoperable. A. 1 Verify by administrative Immediately means High Pressure Coolant Injection System is ------------NOTE------------

OPERABLE. LCO 3.0.4.a is not applicable when AND entering MODE 3. 14 days --------------------------------

A.2 Restore RCIC System to " OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion l"ime not met. ANG Reeluee FeaeteF steam 36 h9UFS eleR'te prnssurn ta 5 psi§. Brunswick U n it 1 3.5-12 Amendment No. 2-33 I Reactor Building-to-Suppression Chamber Vaccum Breakers 3.6.1.5 A CTIONS (continued)

CONDITION REQUIRED ACTION D. Two reactor building-D.1 Restore one vacuum to-suppression chamber breaker to OPERABLE vacuum breakers inoperable status. due to inoperable nitrogen backup subsystems.

E. One line with one or more E.1 Restore the vacuum reactor building-to-breaker(s) to OPERABLE suppression chamber status. vacuum breakers inoperable for opening for reasons other than Condition C. Two lines with one or more F-,.+ Restore all vacuum reactor building-to-in one line to suppression chamber RABLE status. vacuum breakers inoperable for opening for reasons 1 other than Condition D. G. Required Action and G:4 Be in MODE 3. associated Completion Time not met. I I\ Be in MODE 4. \ Lf ot Condition A , B , C , D , F, or G I F. Requ i red Action and F.1 associated Completion Time of Co ndi tion E n ot me t. Brunsw i ck Un i t 1 H.2 ---NOTELCO 3.0.4.a i s not app l i cable w he n en t er i ng MODE 3. Be in MODE 3. 3.6-16 COMPLETION TIME 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 2 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Amendment No.

Suppression Chamber-to-Drywell Vaccum Breakers 3.6.1.6 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening. Ten suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS CONDITION A. One required suppression A.1 chamber-to-drywell vacuum breaker inoperable for e suppression chamber-&.+ to-drywell vacuum breaker not closed. REQUIRED ACTION Restore one vacuum breaker to OPERABLE status. Close the open vacuum breaker. G. Required Action and ciated Completion Time met. &.-1-3. . =======t of Condition C 8. Required Action and 8.1 associated Complet i on Time of Condition A not met. Brunswick Unit 1 ----------

NOTE LCO 3 0.4.a is not app l i cable when enter i ng MOD E 3. Be in MODE 3. 3.6-18 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Amendment No. I 3.6 CONTAINMENT SYSTEMS RHR Suppression Pool Cooling 3.6.2.3 3.6.2.3 Residual Heat Removal (RHR) Suppress i on Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY:

MODES 1 , 2 , and 3. ACTIONS CONDITION A. One RHR suppression pool A.1 cooling subsystem inoperable. &.-Two RHR suppression pool B4 cooling subsystems inoperable. REQUIRED ACTION COMPLETION TIME Restore RHR suppression 7 days pool cooling subsystem to OPERABLE status. Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months suppression pool cooling subsystem to OPERABLE status. G:-Required Action and G:+ Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sociated Completion Time met. . Be in MODE 4 . 8. Required Act i on and 8.1 associated Completion Time of Condition A not met. B r unsw i ck Unit 1 --------NOT E----------

LCO 3.0.4.a is not app l i cable when enter i ng MODE 3. Be in MOOE 3. 3.6-24 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 12 hours Amendment No. 33 I 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment Secondary Containment 3.6.4.1 LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3 , ------------N 0 TE------L CO 3.0.4.a is not applicable when entering MODE 3. During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs). ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment Restore secondary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in MODE 1, 2, containment to OPERABLE or 3. status. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met. ANG Be iR MGQE: 4. a0 l=lel:lFs C. Secondary containment C.1 --------------NOTE-------------

inoperable during movement LCO 3.0.3 is not applicable.

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

assemblies in the secondary containment , or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 1 3.6-28 Amendment No.

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

APPLICABILITY

MODES 1 , 2 , and 3 , ------------N 0

L CO 3.0.4.a is not applicable when entering MODE 3. During movement of recently irradiated fuel assemblies in the secondary containment , During operations with a potential for draining the reactor vessel (OPDRVs). ACTIONS CONDITION A. One SGT subsystem inoperable in MODE 1 , 2 or 3. B. Required Action and associated Complet i on Time of Condition A not met. ANG Two SGT subsystems inoperable in MODE 1 , 2 , or 3. Brunsw i c k U nit 1 REQUIRED ACTION COMPLETION TIME Restore SGT subsystem to 7 days OPERABLE status. Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (con t inued) 3.6-3 3 Am e ndment No.

ACTIONS continued CONDITION B. One RHRSW s u bsystem B.1 inoperable for reasons other than Condition A. &.-Both RHRSW subsystems G4 C. Required Action and C.1 associated Completion Time of Condition A or B not met. Brunsw ic k Un it 1 REQUIRED ACTION --------------

N 0 TE--------------

E nter applicable Conditions and Required Actions of LCO 3.4.7 , "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown ," for RHR shutdown cooling made inoperable by RHRSW System. RHRSW System 3.7.1 COMPLETION TIME Restore RHRSW 7 days subsystem to OPERABLE status. --------------NOTE--------------Enter applicable Condit i ons and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System. Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status. ----NOTELCO 3.0.4.a is not applicab l e when entering MODE 3. Be in MODE 3. 3.7-2 (continued) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Amendm e nt No.

ACTIONS continued CONDITION REQUIRED ACTION Required Action and ociated Completion Time met. Q.:4 Be in MODE 3. . Be in MODE 4. of Condition D SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed , or otherwise secured in position , is in the correct position or can be aligned to the correct position. B r unsw i ck U ni t 1 3.7-3 RHRSW System 3.7.1 COMPLETION TIME 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 36 hours FREQUENCY 31 days Amendmen t No.

N 0 TE------------

LCO 3.0.4.a i s not CREV System r applicable when 3.7.3 entering MOD E 3. CTIONS (continued)

A , /REQUIRED ACTION COMPLETION CONDITION TIME C. Required Action and C.1 VI' Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time ANG of Condition A or B not met in MODE 1, 2, or 3. Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B. D. Required Action and -------------------N 0 TE---------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A not met ------------------------------------------------

during movement of D.1 Place OPERABLE CREV Immediately irradiated fuel assemblies in the secondary containment , subsystem in radiation/smoke protection during CORE mode. ALTERATIONS, or during OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately AL TERA TIONS. AND D.2.3 Initiate action to suspend Immediately OPDRVs. (continued)

Brunswick Un i t 1 3.7-12 Amendment No. -248 I Control Room AC System 3.7.4 3. 7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 APPLICABILITY:

N 0

L CO 3.0.4.a is not applicable when entering MODE 3. ACTIONS Three control room AC subsystems shall be OPERABLE. MODES 1 , 2 , and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

REQUIRED ACTION COMPLETION TIME A. One control room AC subsystem inoperable.

B. Two control room AC subsystems inoperable. C. Required Action and associated Complet i on Time A.1 of Condition A or B not met ANG in MODE 1 , 2, or 3. Brunswick Unit 1 Restore control room AC 30 days subsystem to OPERABLE status. Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months control room AC subsystem to OPERABLE status. Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued) 3.7-15 Amendment No.

ACTIONS continued CONDITION REQUIRED ACTION Control Room AC System 3.7.4 COMPLETION TIME D. Required Action and --------------------NOTE---------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met -------------------------------------------------

during movement of irradiated fuel assemblies in D.1 the secondary containment, during CORE AL TERA TIONS , or during OPDRVs. OR ------------N 0

L CO 3.0.4.a is not applicable when entering MODE 3. E. Three control room AC subsystems inoperable in MODE 1, 2 , or 3. D.2.1 E.1 Be in MODE 3. Brunswick Unit 1 Place OPERABLE control Immediately room AC subsystem(s) in operation.

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

Suspend CORE ALTERATIONS. Initiate action to suspend OPDRVs. Enter LCO a.a.a. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 3.7-16 Immediately Immediately Immediate l y (continued)

Amendment No. 2-GJ 3.7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas Main Condenser Offgas 3.7.5 LCO 3.7.5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be 243 , 600 µCi/second after decay of 30 minutes. APPLICABILITY:

MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit. B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR ------------

N 0 TE------------

B.2 Isolate SJAE. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.4.a is n o t applicable when --enterin g MODE 3. 7 B.3 4 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months --------------------------------

AN9 Be iR MG9E 4. de 1=191:1FS Brunswick Unit 1 3.7-18 Amendment No.

ACTIONS (continued)

CONDITION F. One offsite circuit inoperable for reasons other than Condition B. AND One DG inoperable for reasons other than Condition B. ------------N 0 TE------------

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

G. Two or more DGs inoperable. H. Required Action and associated Completion Time of Condit i on A , B , C , D , E , F or G not met. I. One or more offs i te circuits and two or more DGs inoperable. OR Two or more offsite circuits and one DG inoperab l e for r easons othe r than Con di t i on B. Brun s w i c k Un i t 1 AC Sources-Operating 3.8.1 REQUIRED ACTION COMPLETION TIME ----------------------N 0 TE-------------------

Enter applicable Conditions and Required Actions of LCO 3.8.7 , "Distribution Systems-Operating

," when Condition F is entered with no AC power source to any 4.16 kV emergency bus. --------------------*-----------------------------F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status. OR -F.2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months \ status. G\, Restore all but one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status. Be in MODE 3. 12 hou r s ANG M+/- Be iA

4. Je 1=1e1o1Fs 1.1 Enter LCO 3.0.3. Immediately 3.8-6 Amendm e nt No. I

..........

/ ------------NOTE---------LCO 3.0.4.a is not applicable when enter i ng MODE 3. ACTIONS continued CONDITION B. Required Action and B.1 associated Completion T ime of Condition A not met. ANG Two or more DC e l ectrica l power subsystems inoperas l e SURVEILLANCE REQUIREMENTS REQUIRED ACTION Be in MODE 3. Be in MODE 4. SURVEILLANCE SR 3.8.4.1 Verify battery terminal voltage is 130 V on float charge. SR 3.8.4.2 Verify no visible corrosion at battery terminals and connectors. OR DC Sources-Operating 3.8.4 COMPLETION TIME 12 hou r s 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY 7 days 92 days Verify battery connection resistance is 23.0 µohms for inter-cell connections and 82.8 µohms for inter-rack connections. SR 3.8.4.3 Verify battery cells , cell plates , and racks show no 18 months visual indication of physical damage or abnormal deterioration that degrades performance. (continued)

C. T w o or mo r e DC electrical C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months po w er subsystems i noperable. AND C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.8-24 Amendment No. I

LCO 3.0.4.a is not applicable when entering MODE 3. Distribution Systems-Operating 3.8.7 ACTIONS (continued)

CONDITION D. One or more DC electrical D.1 E. F. power distribution subsystems inoperable for reasons other than Condition C. Required Action and associated Completion Time of Condition A, B, C, or D not met. Two or more electrical power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 1 E.1 ANQ F.1 'V REQUIRED ACTION COMPLETION TIME Restore DC electrical 7 days power distribution subsystems to OPERABLE AND status. Be in MODE 3. Be in MODE 4. Enter LCO 3.0.3. 3.8-36 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Immediately Amendment No. I Marked-up Technical Specifications Pages -Unit 2 Enclosure 3 Contains the following Marked-up Unit 2 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36 BSEP 16-0087 Enclosure 3

NOTE--------

EC CS-Operating LCO 3.0.4.a is not 3.5.1 A applicable when I\ CTIC entering MODE 3. -\7 EQUIRED ACTION --------------------------------

vVl'OjUI I IVl'\I COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met. ANG Be iA MGQe 4. a0 1=1e1:1Fs D. HPCI System inoperable.

D.1 Verify by administrative Immediately means RCIC System is OPERABLE.

AND D.2 Restore HPCI System to 14 days OPERABLE status. E. HPCI System inoperable.

E.1 Restore HPCI System to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status. AND OR One low pressure ECCS injection/spray subsystem is E.2 Restore low pressure 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. ECCS injection/spray subsystem to OPERABLE status. F. One required ADS valve F.1 Restore required ADS valve 14 days inoperable.

to OPERABLE status. (continued)

Brunswick Unit 2 3.5-2 Amendment No.

ACTIONS (continued)

CONDITION REQUIRED ACTION G. One required ADS valve G.1 Restore required ADS valve inoperable.

to OPERABLE status. AND OR One low pressure ECCS G.2 Restore low pressure injection/spray subsystem ECCS injection/spray inoperable. subsystem to OPERABLE status. H. One required ADS valve H.1 Restore required ADS valve inoperable. to OPERABLE status. AND OR HPCI System inoperable.

H.2 Restore HPCI System to OPERABLE status. h AstieA aAEI 4 assesiateEI GeFfl13letieA

+iFfle AND J.1 ef GeAElitieA D , E , r , G , 9F H Aet met. Reduce reactor steam GR pressure to O psig. Two or more required ADS valves inoperable. 2 L[IJ I. Requ i red Act i on and 1.1 associated Complet i on Time of Cond i tion D , E. F. G , or Hnot ---NOTELCO 3.0.4.a i s not applicable w hen entering MODE 3. met. Be i n MODE 3. Brunswick Unit 2 3.5-3 ECCS-Operating 3.5.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Amendment No.

ACTIONS (continued)

CONDITION Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A or B. HPCI System and two or more required ADS valves inoperable.

REQUIRED ACTION J,.+ Enter LCO 3.0.3. SURVEILLANCE REQUIREMENTS SURVEILLANCE ECCS-Operating 3.5.1 COMPLETION TIME Immediately FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem , the 31 days piping is filled with water from the pump discharge valve to the injection valve. (continued)

Brunswick Unit 2 3.5-4 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1 , MODES 2 and 3 with reactor steam dome pressure > 150 ps i g. ACTIONS LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A. 1 Verify by administrative Immediately means High Pressure Coolant Injection System is ------------N 0 TE------------

OPERABLE. LCO 3.0.4.a is not applicab l e when AND entering MODE 3. K. Restore RCIC System to 14 days --------------------------------

OPERABLE s t a tus. \ B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. ANG Reel1::1ee FeaeteF steam 36 hel::IFS eleme pmss1::1m te Hi9 psi§. Bru n sw ic k Un i t 2 3.5-12 Ame n dment No. I Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION D. Two reactor building-to-D.1 Restore one vacuum suppression chamber breaker to OPERABLE vacuum breakers inoperable status. due to inoperable nitrogen backup subsystems.

E. One line with one or more E.1 Restore the vacuum reactor building-to-breaker(s) to OPERABLE suppression chamber status. vacuum breakers inoperable for opening for reasons other than Condition C. Two lines with one or more Restore all vacuum reactor building-to-in one line to suppression chamber PERABLE status. vacuum breakers inoperable for opening for reasons 1 other than Condition D. (;,.+ Be in MODE 3. Required Action and associated Completion Time ANQ not met. I G+/- Be in MODE 4. . Yot Condition A , B , C , D , F , or G F. Required Action and F.1 associated Completion Time of Condition E not me t. Brunswick Unit 2 H.2 I ---NOTE*LCO 3.0.4.a is not applicable when entering MODE 3. Be in MODE 3. 3.6-16 COMPLETION TIME 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 2 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Amendment No.

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 3.6 CONTAINMENT SYSTEMS 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for open i ng. Ten suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function. APPLICABILITY:

MODES 1 , 2, and 3. ACTIONS A. CONDITION One required suppression A.1 chamber-to-drywell vacuum breaker inoperable for opening. One suppression chamber-to-drywell vacuum breaker not closed. REQUIRED ACTION Restore one vacuum breaker to OPERABLE status. Close the open vacuum breaker. Required Action and G:4-Be in MODE 3. associated Completion Time r:::--:-1 not met. AND. ' of Cond i tion C B. Required Action and B.1 associated Completion Time of Cond i tion A not m e t. Brunswick Unit 2 Be in MODE 4. ----------

NOTE L CO 3.0.4.a is not app l icab l e wh e n entering MODE 3. Be in MODE 3. 3.6-18 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Amendment No. I C. 3.6 CONTAINMENT SYSTEMS RHR Suppression Pool Cooling 3.6.2.3 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY:

MODES 1 , 2, and 3. ACTIONS CONDITION A. One RHR suppression pool A.1 cooling subsystem inoperable.

8-:-Two RHR suppression pool 8:4 cooling subsystems inoperable.

of Condition C B. Requ i red Action and 8.1 associa t ed Completion T i me of Cond i t i on A not met. B r unswick Un i t 2 REQUIRED ACTION COMPLETION TIME Restore RHR suppression 7 days pool cool i ng subsystem to OPERABLE status. Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months suppression pool cooling subsystem to OPERABLE status. Be i n MODE 4. 0.2 ------NOTELCO 3.0.4.a is not applicable w hen enter i ng MODE 3. Be i n M ODE 3. 3.6-24 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 ho u rs 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Am e ndme n t No. I 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment Secondary Containment 3.6.4.1 LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY

MODES 1 , 2 , and 3 , ------------NOTE------------

During movement of recently irradiated fuel assemblies in the secondary LCO 3.0.4.a is not containment , applicable when \Durinig operations with a potential for draining the reactor vessel entering MODE 3. (OPDRVs).

ACTIONS CONDITION\ A. Secondary containment

\ A.1 inoperable in MODE 1 , 2 , \ or3. B. Required Action and B.1 associated Completion Time of Condition A not met. ANG C. Secondary containment C.1 inoperable during movement of recently irradiated fuel assemblies in the secondary containment , or during OPDRVs. Brunswick Un i t 2 REQUIRED ACTION Restore secondary containment to OPERABLE status. Be in MODE 3. Be in MODE 4. --------------NO TE--------------

L CO 3.0.3 is not applicable. COMPLETION TIME 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment. (cont i nued) 3.6-28 Amendment No.

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

APPLICABILITY:

MODES 1 , 2 , and 3 , SGT System 3.6.4.3 ------------NO L CO 3.0.4.a is not applicable when entering MODE 3. During movement of recently irradiated fuel assemblies in the secondary containment , During operations with a potential for draining the reactor vessel (OPDRVs). ACTIONS COND I TION A. One SGT subsystem inoperable in MODE 1 , 2 or 3. B. Required Action and B.1 associated Completion Time of Cond i tion A not met. AND Two SGT subsystems inoperable i n MODE 1 , 2 , or 3. B run s wick U nit 2 REQUIRED ACTION Restore SGT subsystem to OPERABLE status. Be in MODE 3. Be in MODE 4. 3.6-3 3 COMPLETION TIME 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours (continued)

A men d me nt No.

ACTIONS continued CONDITION B. One RHRSW subsystem B.1 inoperable for reasons other than Condition A. &.-Both RHRSW subsystems G4 C. Requ i red Act i on and C.1 associated Complet i on Time of Cond i t i on A or B not met. Brunswick Unit 2 REQUIRED ACTION --------------N 0 TE--------------

E nter applicable Conditions and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System. RHRSW System 3.7.1 COMPLETION TIME Restore RHRSW 7 days subsystem to OPERABLE status. -------------N 0 TE--------------E n t er applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System. Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status. ----NOTELCO 3.0.4.a is not app l i cable w hen enter i ng MODE 3. Be i n MODE 3. 3.7-2 (continued) 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Amendment No.

ACTIONS continued CONDITION REQUIRED ACTION G-:-Required Action and G-:-4 in MODE 3. '-' ....1( associated Co m plet i on Time 1 not met. AND E.1 Be in MODE 4. of Condition D SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.1.1 Verify each RHRSW manua l, power operated , and automatic valve in the flow path , that is not locked , sealed , or otherwise secured in pos i tion , is in the correct pos i tion or can be aligned to the correct position. Brun swick Un it 2 3.7-3 RHRSW System 3.7.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY 31 days A mendme nt No.

N 0 TE------------

GREV System LCO 3.0.4.a is not 3.7.3 A I applicable when CTIONS {continued) entering MODE 3. J --------------------------------

COMPLETION CONDITION REQUIRED ACTION TIME r C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met ANG in MODE 1, 2, or 3. Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B. D. Required Action and -------------------N 0 TE---------------------

associated Completion Time LCO 3.0.3 is not applicable. of Condition A not met ------------------------------------------------

during movement of irradiated fuel assemblies in D.1 Place OPERABLE GREV Immediately the secondary containment, subsystem in during CORE radiation/smoke protection AL TERA TIONS, or during mode. OPDRVs. OR D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND D.2.2 Suspend CORE Immediately A L TERA TIONS. AND D.2.3 Initiate action to suspend Immediately OPDRVs. (continued)

Brunswick Unit 2 3.7-12 Amendment No. I Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 APPLICABILITY:

NO L CO 3.0.4.a is not applicable when entering MODE 3. ACTIONS Three control room AC subsystems shall be OPERABLE.

MODES 1 , 2 , and 3 , During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operat i ons with a potential for draining the reactor vessel (OPDRVs). REQUIRED ACTION COMPLETION TIME A. One control room AC subsystem inoperable.

B. Two control room AC subsystems inoperable. A.1 C. Required Action and C.1 associated Completion Time of Condition A or B not met ANG in MODE 1, 2 , or 3. Brunswick Un i t 2 Restore control room AC 30 days subsystem to OPERABLE status. Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months control room AC subsystem to OPERABLE status. Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B e in MOD E 4. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (continued) 3.7-15 Amendment No.

Control Room AC System 3.7.4 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and ---------------------NOTE--------------------

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met -------------------------------------------------

during movement of irradiated fuel assemblies in D.1 the secondary containment, during CORE Place OPERABLE control Immediately room AC subsystem(s) in operation.

AL TERA TIONS, or during OPDRVs. OR ------------N 0 TE----------L CO 3.0.4.a is not applicable when entering MODE 3. E. Three control room AC subsystems inoperable in MODE 1, 2, or 3. D.2.1 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

D.2.2 Suspend CORE AL TERA TIONS. E.1 Initiate action to suspend OPDRVs. Enter LCO 3.0.3. Immediately Immediately Immediately (continued)

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.7-16 Amendment No.

3.7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas Main Condenser Offgas 3.7.5 LCO 3. 7 .5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be 243,600 µC i/second after decay of 30 minutes. APPLICABILITY:

MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit. B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR ------------N 0 TE------------

B.2 Isolate SJAE. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO 3.0.4.a is not applicable when OR ' entering MODE 3. ,;;;-B.3 A Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ----------------------

ANG Be iR MGb>E 4. ;30 A91: ffS Brunswick Un i t 2 3.7-18 Amendment No.

ACTIONS (continued)

CONDITION F. One offsite circuit inoperable for reasons othe r than Condition B. AND One DG inoperable for reasons other than Condition B. -----------

-N 0 TE------------

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

G. Two or more DGs \ AC Sources-Operating 3.8.1 REQUIRED ACTION COMPLETION TIME ----------------------N 0 TE------------------

Enter applicable Conditions and Required Actions of LCO 3.8.7 , "Distribution Systems-Operating

," when Condition F is entered with no AC power source to any 4.16 kV emergency bus. -------------------------------------------------F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status. OR F.2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status. G.1 Restore all but one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable.

..\I OPERABLE status. ,, H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Comp l etion Time of Condition A , B , C , D , E , F AN9 or G not met. Be iR MGQE 4. 30 R91:1FS I. One or more offs i te circuits 1.1 Enter LCO 3.0.3. Immediately and two or more DGs inoperable. OR Two or more offsite c i rcuits and o n e DG inoperable for reasons other than Cond i ti o n B. B ru n s w i ck Un i t 2 3.8-6 A m e n d me nt N o. I

.........

/ ------------NO TE----------L CO 3.0.4.a is not applicable when entering MODE 3. ACTIONS continued CONDITION B. Required Action and B.1 associated Completion Time of Condition A not met. AN9 Two or more DC electrical power subsystems iAoperable SURVEILLANCE REQUIREMENTS REQUIRED ACTION Be in MODE 3. Be iA MODE 4. SURVEILLANCE SR 3.8.4.1 Verify battery terminal voltage is 130 V on float charge. SR 3.8.4.2 Verify no visible corrosion at battery term i nals and connectors. OR DC Sources-Operating 3.8.4 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY 7 days 92 days Verify battery connection resistance is :s; 23.0 µohms for inter-cell connections and :s; 82.8 µohms for inter-rack connect i ons. SR 3.8.4.3 Verify battery cells , cell plates , and racks show no 18 months visual indication of physical damage or abnormal deterioration that degrades performance. (cont i nued) ' ' I I C. T w o or mo r e DC electrical C.1 Be i n MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months po w er s u bs y stems i noperable. AND C.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.8-24 Amendm e nt No. I

N 0 TE------------

L CO 3.0.4.a is not applicable when entering MODE 3. Distribution Systems-Operating 3.8.7 ACTIONS (continued)

CONDITION D. One or more DC electrical D.1 E. F. power distribution subsystems inoperable for reasons other than Condition C. Required Action and associated Completion Time of Condition A , B , C , or D not met. Two or more electrical power distribution subsystems inoperable that result in a loss of function.

Brunswick Un i t 2 \,/ E.1 AND F.1 REQUIRED ACTION COMPLETION TIME Restore DC electrical 7 days power distribution subsystems to OPERABLE AND status. Be in MODE 3. Be in MODE 4. Enter LCO 3.0.3. 3.8-36 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Immediately Amendment No. I Revised Technical Specifications Pages -Unit 1 Enclosure 4 Contains the following Revised Unit 1 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36 BSEP 16-0087 Enclosure 4

A CTIONS (continued)

CONDITION C. Required Action and C.1 associated Completion Time of Condition A or B not met. D. HPCI System inoperable.

D.1 AND D.2 E. HPCI System inoperable.

E.1 AND OR One low pressure ECCS injection/spray subsystem is E.2 inoperable.

F. One required ADS valve F.1 inoperable.

Brunswick Unit 1 REQUIRED ACTION --------------NOTE--------------

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

Be in MODE 3. Verify by administrative means RCIC System is OPERABLE.

Restore HPCI System to OPERABLE status. Restore HPCI System to OPERABLE status. Restore low pressure ECCS injection/spray subsystem to OPERABLE status. Restore required ADS valve to OPERABLE status. 3.5-2 ECCS-Operating 3.5.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately 14 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 14 days (continued)

Amendment No.

A CTIONS (continued)

CONDITION G. One required ADS valve G.1 inoperable.

AND OR One low pressure ECCS G.2 injection/spray subsystem inoperable.

H. One required ADS valve H.1 inoperable.

AND OR HPCI System inoperable.

H.2 I. Required Action and 1.1 associated Completion Time of Condition D, E, F, G, or H not met. J. Two or more required ADS J.1 valves inoperable.

AND J.2 . Brunswick Unit 1 REQUIRED ACTION Restore required ADS valve to OPERABLE status. Restore low pressure ECCS injection/spray subsystem to OPERABLE status. Restore required ADS valve to OPERABLE status. Restore HPCI System to OPERABLE status. --------------NOTE--------------

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

Be in MODE 3. Be in MODE 3. Reduce reactor steam dome pressure to :.::; 150 psig. 3.5-3 ECCS-Operating 3.5.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Amendment No .

ACTIONS (continued)

CONDITION K. Two or more low pressure K.1 ECCS injection/spray subsystems inoperable for reasons other than Condition A or B. HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION Enter LCO 3.0.3. SURVEILLANCE ECCS-Operating 3.5.1 COMPLETION TIME Immediately FREQUENCY

SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, the 31 days piping is filled with water from the pump discharge valve to the injection valve. (continued)

Brunswick Unit 1 3.5-4 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

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

N 0 TE-----------------------------------------------------------

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

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

AND A.2 Restore RCIC System to 14 days OPERABLE status. B. Required Action and B.1 --------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.5-12 Amendment No.

A CTIONS (continued)

CONDITION D. Two reactor building-to-suppression chamber vacuum breakers inoperable due to inoperable nitrogen backup subsystems.

E. One line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening for reasons other than Condition C. F. Required Action and associated Completion Time of Condition E not met. G. Two lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening for reasons other than Condition D. H. Required Action and associated Completion Time of Condition A, B, C, D, F, or G not met. Brunswick Unit 1 Reactor Building-to-Suppression Chamber Vaccum Breakers 3.6.1.5 COMPLETION REQUIRED ACTION TIME D.1 Restore one vacuum 7 days breaker to OPERABLE status. E.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months breaker(s) to OPERABLE status. F.1 -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G.1 Restore all vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months breakers in one line to OPERABLE status. H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 3.6-16 Amendment No.

3.6 CONTAINMENT SYSTEMS Suppression Chamber-to-Drywell Vaccum Breakers 3.6.1.6 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening. Ten suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One required suppression A. 1 Restore one vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months chamber-to-drywell vacuum breaker to OPERABLE breaker inoperable for status. opening. B. Required Action and B.1 -------------NO TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. One suppression chamber-C. 1 Close the open vacuum 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to-drywell vacuum breaker breaker. not closed. D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.6-18 Amendment No.

3.6 CONTAINMENT SYSTEMS RHR Suppression Pool Cooling 3.6.2.3 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

A PPLICABILITY:

MODES 1, 2, and 3. A CTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One RHR suppression pool A.1 Restore RHR suppression 7 days cooling subsystem pool cooling subsystem to inoperable.

OPERABLE status. B. Required Action and B.1 -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two RHR suppression pool C.1 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months cooling subsystems suppression pool cooling inoperable.

subsystem to OPERABLE status. D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 1 3.6-24 Amendment No. I 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment Secondary Containment 3.6.4.1 LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Secondary containment A.1 Restore secondary 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in MODE 1, 2, containment to OPERABLE or 3. status. B. Required Action and B.1 -------------N 0 TE--------------

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

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

inoperable during movement LCO 3.0.3 is not applicable.

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

assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 1 3.6-28 Amendment No.

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

APPLICABILITY:

MODES 1, 2, and 3, SGT System 3.6.4.3 During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

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

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

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

Brunswick Unit 1 3.6-33 Amendment No.

A CTIONS (continued)

CONDITION B. One RHRSW subsystem B.1 inoperable for reasons other than Condition A. C. Required Action and C.1 associated Completion Time of Condition A or B not met. D. Both RHRSW subsystems D.1 inoperable.

} l Brunswick Unit 1 REQUIRED ACTION -------------NOTE--------------

Enter applicable Conditions and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System. -----------------------------------

Restore RHRSW subsystem to OPERABLE status. -------------N 0 TE--------------

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

Be in MODE 3. -------------N 0 TE--------------

Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System. -----------------------------------

Restore one RHRSW subsystem to OPERABLE status. 3.7-2 RHRSW System 3.7.1 COMPLETION TIME 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 8 hours (continued)

Amendment No.

ACTIONS (continued)

CONDITION REQUIRED ACTION E. Required Action and E.1 Be in MODE 3. associated Completion Time of Condition D not met. AND E.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Brunswick Unit 1 3.7-3 RHRSW System 3.7.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY 31 days Amendment No. l A CTIONS (continued)

CONDITION C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, or 3. OR Two CREV subsystems inoperable in MODE 1, 2, or 3 for reasons other than Condition B. D. Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs. Brunswick Unit 1 REQUIRED ACTION C.1 -------------N 0 TE--------------

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

Be in MODE 3. -------------------N 0 TE---------------------

LCO 3.0.3 is not applicable.

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

AND D.2.2 Suspend CORE ALTERATIONS.

AND D.2.3 Initiate action to suspend OPDRVs. 3.7-12 CREV System 3.7.3 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately Immediately Immediately Immediately (continued)

Amendment No.

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable.

subsystem to OPERABLE status. B. Two control room AC B.1 Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystems inoperable.

control room AC subsystem to OPERABLE status. C. Required Action and C. 1 -------------NOTE--------------

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

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

Brunswick Unit 1 3.7-15 Amendment No.

A CTIONS (continued)

CONDITION D. Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs. E. Three control room AC subsystems inoperable in MODE 1, 2, or 3. Brunswick Unit 1 Control Room AC System 3.7.4 COMPLETION REQUIRED ACTION TIME -------------------N 0 TE---------------------

LCO 3.0.3 is not applicable.

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

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

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs. E.1 -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued) 3.7-16 Amendment No.

3.7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas Main Condenser Offgas 3.7.5 LCO 3.7.5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be ::;; 243,600 µCi/second after decay of 30 minutes. APPLICABILITY:

MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit. B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR B.2 Isolate SJAE. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR B.3 -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 1 3.7-18 Amendment No.

A CTIONS (continued)

CONDITION F. One offsite Gircuit inoperable for reasons other than Condition B. AND One DG inoperable for reasons other than Condition B. G. Two or more DGs inoperable.

H. Required Action and associated Completion Time of Condition A, B, C, D, E, F or G not met. I. One or more offsite circuits and two or more DGs inoperable.

OR Two or more offsite circuits and one DG inoperable for reasons other than Condition B. Brunswick Unit 1 AC Sources-Operating 3.8.1 REQUIRED ACTION COMPLETION TIME ----------------------N 0 TE-------------------

Enter applicable Conditions and Required Actions of LCO 3.8.7, "Distribution Systems-Operating," when Condition F is entered with no AC power source to any 4.16 kV emergency bus. -------------------------------------------------

F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status. OR F.2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status. G.1 Restore all but one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status. H.1 -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 1.1 Enter LCO 3.0.3. Immediately 3.8-6 Amendment No.

DC Sources-Operating 3.8.4 A CTIONS (continued)

CONDITION REQUIRED ACTION B. Required Action and B.1 -------------NOTE--------------

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

Be in MODE 3. C. Two or more DC electrical C.1 Be in MODE 3. power subsystems inoperable.

AND C.2 Be in MODE4. SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 Brunswick Unit 1 SURVEILLANCE Verify battery terminal voltage is 130 V on float charge. Verify no visible corrosion at battery terminals and connectors.

Verify battery connection resistance is 23.0 µohms for inter-cell connections and 82.8 µohms for rack connections.

Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that degrades performance.

3.8-24 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY 7 days 92 days 18 months (continued)

Amendment No.

A CTIONS (continued)

CONDITION D. One or more DC electrical D.1 power distribution subsystems inoperable for reasons other than Condition C. E. Required Action and E.1 associated Completion Time of Condition A, B, C, or D not met. F. Two or more electrical F.1 power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 1 Distribution Systems-Operating 3.8.7 REQUIRED ACTION COMPLETION TIME Restore DC electrical 7 days power distribution subsystems to OPERABLE AND status. 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Enter LCO 3.0.3. Immediately 3.8-36 Amendment No.

Revised Technical Specifications Pages -Unit 2 Enclosure 5 Contains the following Revised Unit 2 TS Pages 3.5-2 3.7-2 3.5-3 3.7-3 3.5-4 3.7-12 3.5-12 3.7-15 3.6-16 3.7-16 3.6-18 3.7-18 3.6-24 3.8-6 3.6-28 3.8-24 3.6-33 3.8-36 BSEP 16-0087 Enclosure 5

A CTIONS (continued)

CONDITION C. Required Action and C.1 associated Completion Time of Condition A or B not met. D. HPCI System inoperable.

D.1 AND D.2 E. HPCI System inoperable.

E.1 AND OR One low pressure ECCS injection/spray subsystem is E.2 inoperable.

F. One required ADS valve F.1 inoperable.

Brunswick Unit 2 REQUIRED ACTION --------------NOTE--------------

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

Be in MODE 3. Verify by administrative means RCIC System is OPERABLE.

Restore HPCI System to OPERABLE status. Restore HPCI System to OPERABLE status. Restore low pressure ECCS injection/spray subsystem to OPERABLE status. Restore required ADS valve to OPERABLE status. 3.5-2 EGGS-Operating 3.5.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately 14 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 14 days (continued)

Amendment No.

A CTIONS (continued)

CONDITION G. One required ADS valve G.1 inoperable.

AND OR One low pressure ECCS G.2 injection/spray subsystem inoperable.

H. One required ADS valve H.1 inoperable.

AND OR HPCI System inoperable.

H.2 I. Required Action and 1.1 associated Completion Time of Condition D, E, F, G, or H not met. J. Two or more required ADS J.1 valves inoperable.

AND J.2 Brunswick Unit 2 REQUIRED ACTION Restore required ADS valve to OPERABLE status. Restore low pressure ECCS injection/spray subsystem to OPERABLE status. Restore required ADS valve to OPERABLE status. Restore HPCI System to OPERABLE status. --------------N 0 TE--------------

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

Be in MODE 3. Be in MODE 3. Reduce reactor steam dome pressure to ::;; 150 psig. 3.5-3 EGGS-Operating 3.5.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Amendment No.

ACTIONS (continued)

CONDITION K. Two or more low pressure K.1 EGGS injection/spray subsystems inoperable for reasons other than Condition A or B. HPCI System and two or more required ADS valves inoperable.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION Enter LCO 3.0.3. SURVEILLANCE EGGS-Operating 3.5.1 COMPLETION TIME Immediately FREQUENCY SR 3.5.1.1 Verify, for each EGGS injection/spray subsystem, the 31 days piping is filled with water from the pump discharge valve to the injection valve. (continued)

Brunswick Unit 2 3.5-4 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

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

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

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

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

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.5-12 Amendment No.

A CTIONS (continued)

CONDITION D. Two reactor building-to-suppression chamber vacuum breakers inoperable due to inoperable nitrogen backup subsystems.

E. One line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening for reasons other than Condition C. F. Required Action and associated Completion Time of Condition E not met. G. Two lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening for reasons other than Condition D. H. Required Action and associated Completion Time of Condition A, B, C, D, F, or G not met. Brunswick Unit 2 Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.5 COMPLETION REQUIRED ACTION TIME D.1 Restore one vacuum 7 days breaker to OPERABLE status. E.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months breaker(s) to OPERABLE status. F.1 -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G.1 Restore all vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months breakers in one line to OPERABLE status. H.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 3.6-16 Amendment No.

3.6 CONTAINMENT SYSTEMS Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.6 Eight suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening. Ten suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One required suppression A.1 Restore one vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months chamber-to-drywell vacuum breaker to OPERABLE breaker inoperable for status. opening. B. Required Action and B.1 -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. One suppression chamber-C.1 Close the open vacuum 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to-drywell vacuum breaker breaker. not closed. D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.6-18 Amendment No.

3.6 CONTAINMENT SYSTEMS RHR Suppression Pool Cooling 3.6.2.3 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One RHR suppression pool A.1 Restore RHR suppression 7 days cooling subsystem pool cooling subsystem to inoperable.

OPERABLE status. B. Required Action and B.1 -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two RHR suppression pool C.1 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months cooling subsystems suppression pool cooling inoperable.

subsystem to OPERABLE status. D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met. AND D.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.6-24 Amendment No.

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

APPLICABILITY:

MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

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

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

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

inoperable during movement LCO 3.0.3 is not applicable.

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

assemblies in the secondary containment, or during Suspend movement of Immediately OPDRVs. recently irradiated fuel assemblies in the secondary containment.

AND (continued)

Brunswick Unit 2 3.6-28 Amendment No.

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

APPLICABILITY:

MODES 1, 2, and 3, SGT System 3.6.4.3 During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One SGT subsystem A.1 Restore SGT subsystem 7 days inoperable in MODE 1, 2 or to OPERABLE status. 3. B. Required Action and B.1 -------------N 0 TE--------------

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

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

Brunswick Unit 2 3.6-33 Amendment No. 280 RHRSW System . 3.7.1 A CT IONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. One RHRSW subsystem B.1 -------------NOTE--------------

inoperable for reasons other Enter applicable Conditions than Condition A. and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System. -----------------------------------

Restore RHRSW 7 days subsystem to OPERABLE status. C. Required Action and C. 1 -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. Both RHRSW subsystems D.1 -------------NOTE--------------

inoperable.

Enter applicable Conditions and Required Actions of LCO 3.4. 7 for RHR shutdown cooling made inoperable by RHRSW System. -----------------------------------

Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status. (continued)

Brunswick Unit 2 3.7-2 Amendment No.

ACTIONS (continued)

CONDITION REQUIRED ACTION E. Required Action and E.1 Be in MODE 3. associated Completion Time of Condition D not met. AND E.2 Be in MODE 4. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic.

valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Brunswick Unit 2 3. 7-3 RHRSW System 3.7.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FREQUENCY 31 days Amendment No.

A CTIONS (continued)

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

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

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

LCO 3.0.3 is not applicable.

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

AND D.2.2 Suspend CORE ALTERATIONS.

AND D.2.3 Initiate action to suspend OPDRVs. 3.7-12 CREV System 3.7.3 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately Immediately Immediately Immediately (continued)

Amendment No.

Control Room AC System 3.7.4 3. 7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE AL TERA TIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A One control room AC A.1 Restore control room AC 30 days subsystem inoperable.

subsystem to OPERABLE status. B. Two control room AC B.1 Restore one inoperable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystems inoperable.

control room AC subsystem to OPERABLE status. C. Required Action and C.1 -------------NOTE--------------

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

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

Brunswick Unit 2 3.7-15 Amendment No.

A CTIONS (continued)

CONDITION D. Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs. E. Three control room AC subsystems inoperable in MODE 1, 2, or 3. Brunswick Unit 2 Control Room AC System 3.7.4 COMPLETION REQUIRED ACTION TIME --------------------N 0 TE--------------------

LCO 3.0.3 is not applicable.

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

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

AND D.2.2 Suspend CORE Immediately ALTERATIONS.

AND D.2.3 Initiate action to suspend Immediately OPDRVs. E.1 -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued) 3.7-16 Amendment No.

3. 7 PLANT SYSTEMS 3.7.5 Main Condenser Offgas Main Condenser Offgas 3.7.5 LCO 3.7.5 The gross gamma activity rate of the noble gases measured at the main condenser air ejector shall be 243,600 µCi/second after decay of 30 minutes. APPLICABILITY:

MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Gross gamma activity rate of A.1 Restore gross gamma 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the noble gases not within activity rate of the noble limit. gases to within limit. B. Required Action and B.1 Isolate all main steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. OR B.2 Isolate SJAE. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR B.3 -------------NOTE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Brunswick Unit 2 3.7-18 Amendment No.

A CTIONS (continued)

CONDITION F. One offsite circuit inoperable for reasons other than Condition B. AND One DG inoperable for reasons other than Condition B. G. Two or more DGs inoperable.

H. Required Action and associated Completion Time of Condition A, B, C, D, E, F or G not met. I. One or more offsite circuits and two or more DGs inoperable.

OR Two or more offsite circuits and one DG inoperable for reasons other than Condition B. Brunswick Unit 2 AC Sources-Operating 3.8.1 REQUIRED ACTION COMPLETION TIME ----------------------NOTE------------------

Enter applicable Conditions and Required Actions of LCO 3.8.7, "Distribution Systems-Operating," when Condition F is entered with no AC power source to any 4.16 kV emergency bus. -------------------------------------------------

F.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status. OR F.2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status. G.1 Restore all but one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status. H.1 -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 1.1 Enter LCO 3.0.3. Immediately 3.8-6 Amendment No.

DC Sources-Operating 3.8.4 A CTIONS (continued)

CONDITION REQUIRED ACTION 8. Required Action and 8.1 -------------N 0 TE--------------

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

Be in MODE 3. C. Two or more DC electrical C.1 Be in MODE 3. power subsystems inoperable.

AND C.2 Be in MODE4. SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 Brunswick Unit 2 SURVEILLANCE Verify battery terminal voltage is 130 V on float charge. Verify no visible corrosion at battery terminals and connectors.

Verify battery connection resistance is :-:::; 23.0 µohms for inter-cell connections and :-:::; 82.8 µohms for rack connections.

Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that degrades performance.

3.8-24 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FREQUENCY 7 days 92 days 18 months (continued)

Amendment No.

ACTIONS (continued)

CONDITION D. One or more DC electrical D.1 power distribution subsystems inoperable for reasons other than Condition C. E. Required Action and E.1 associated Completion Time of Condition A, B, C, or D not met. F. Two or more electrical F.1 power distribution subsystems inoperable that result in a loss of function.

Brunswick Unit 2 Distribution Systems-Operating 3.8.7 REQUIRED ACTION COMPLETION TIME Restore DC electrical 7 days power distribution subsystems to OPERABLE AND status. 176 hours0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months from discovery of failure to meet LCO -------------N 0 TE--------------

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

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Enter LCO 3.0.3. Immediately 3.8-36 Amendment No.

Marked-up Technical Specifications Bases Pages -Unit 1 (For Information Only) BSEP 16-0087 Enclosure 6

BASES ACTIONS (continued)

Brun swic k U ni t 1 C.1 and C.2 ECCS-Operating B 3.5.1 If any Required Action and associated Completion Time of Condit i on A or B are not met , the plant must be brought to a MODE in which the LCO does not apply 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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. 15) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short However. voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state. Required Action C , 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. the r e i s no restrict ion 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 allo w ed Comp l et i o n Time s--afe is._r easonable , based on ope r ating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. D.1 and D.2 If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE , the HPCI System must be restored to OPERABLE status within 14 days. In this cond i tion , adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS. Also , the RCIC System w i ll automat i cally prov i de makeup water at most reactor operat i ng pressures. Immediate verificati on of RCIC O PERABI LITY i s th e ref ore required when HPCI is inoperable. This may be perf o rmed a s a n administrative check by examining logs or other information to determine if RCIC is out of service for maintenance or other reason s. I t does not mean to perform the Surveillances needed to demonstr ate th e OPERABILITY of the RCIC System. However, if the OPERABILIT Y of the RCI C S ystem cannot be immediatel y v e rified , Conditi on I must be immediat e l y en tere d. If a s i ng l e acti ve compo nent fails concu rrent with a des i gn basis LOCA , t here is a po t ential , depend i ng on the spec ifi c fa i lu r e , that th e mi n im um requ ir ed E CCS eq u ip me nt wi ll no t be availa b l e. A 14 day Comp l et i on Ti m e is b a sed on a r e li a b ili ty study ci ted in B 3.5.1-7 Revis i on No. 31 BASES ACTIONS Brunswick Un i t 1 G.1 and G.2 (continued)

ECCS-Operating B 3.5.1 Since both a h i gh p r essure system (ADS) and a low pressure subsys t em are inoperable , a more restrict i ve Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the low pressure ECCS subsystem or the required ADS valve to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.

H.1 and H.2 If the HPCI System is inoperable in addition to one required ADS valve inoperable, adequate core cooling is ensured by the OPERABILITY of the remaining ADS valves and the low pressure ECCS subsystems.

However , overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA may result in the minimum required ECCS equipment not being available. Since a high pressure system is inoperable (HPCI) and the ADS cannot withstand a single active component failure , a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the HPCI System or the required ADS valve to OPERABLE status. The Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience. 1.1 and1.2 If any Required Action and associated Completion Time of Condition D , E , F , G , or H is not met , or if two or more required ADS *1alves are inoperable , the plant must be brought to a condition MODE in which--tRe LCO does not apply 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ...aM reactor steam dome pressure reduced to < 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Remaining in the Applicab i lity of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 15) and because the time spent in MODE 3 to perform the necessarv repa i rs to restore the system to OPERABLE status will be short. However. voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state. Requ i red Action 1.1 i s mod ifi ed by a Note that states that LCO 3.0.4.a is not app l i c a bl e when enter in g MOD E 3. T his No te pr o h ibi t s the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not me t. However. _there is no rest[iction on the use of L CO .0 .. b i *c b ecause LCO 3.0.4.b requ i res p erformance of a risk assessme nt a ddressing inoperable systems and components , considerati on of th e results, det ermination of th e acceptabili ty of entering MODE 3 , an d establis hm e nt o f risk m ana gement acti ons. if a ppropr iate. L CO 3.0.4 is n o t app licab le to and the No t e do e s not p r e cl ud e changes in MODES or othe r specifie d co n d iti ons i n the A pp licabilit y that a r e requ ir ed to com p ly with A CTIO NS or tha t are part o f a sh utdo wn of the unit. B 3.5.1-9 Revis i on No. 31 I Brunswick Unit 1 ECCS-Operating B 3.5.1 The allowed Completion reasonable , based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued)

B 3.5.1-10 Revision No. 31 I BASES ACTIONS (continued) SURVEILLANCE REQUIREMENTS B r u nsw i ck Unit 1 J.1 and J.2 ECCS-Operating B 3.5.1 If two or more required ADS valves are inope r able. there is a reduction in the depressurization capabil i ty. The plant must be brought to a condition in which the LCO does not apply. To achieve this status. the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to ::> 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable. based on operating experience. to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. K1 When multiple ECCS subsystems are inoperable , as stated in Condit i on J!S , the plant is in a condition outside of the accident analyses.

Therefore , LCO 3.0.3 must be entered immediately. SR 3.5.1.1 The flow path piping of each ECCS has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System , CS subsystems , and LPCI subsystems full of water ensures that the ECCS w i ll perform properly , injecting its full capacity into the RCS upon demand. This SR also prevents water hammer in the piping following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The 31 day Frequency is based on the gradual nature of void buildup in the ECCS p i p i ng , the procedural controls go v erning system operat i on , and operat i ng experience. SR 3.5.1.2 Verifying the correct alignment for manual , power operated , and automatic valves in the ECCS flow paths provides assurance that the proper flow paths exist for ECCS operat i on. This SR does not apply to valves that a r e locked , sealed , o r otherwise secu r ed in pos i tion since these are verified to be in the correct position prior to locking , sealing , or securing. A valve that receives an initiation signal is allowed to be in a nonaccident pos i t i on prov i ded the valve w i ll automatically reposition to the accident positio n in t h e p roper stroke time. T h is S R doe s not r e quire any testing or valve manipulation

rather , it involves verific a tion th at t hose valve s cap abl e o f potenti ally bein g mispos i tioned a re i n the c o rr ect posit i on. This SR does not apply to valves that c annot be inadv erten tl y misaligned , such as check valve s. For the HPCI System, this SR al s o i ncludes the steam flow path for the tu r bine and the flow contro ll er positi o n. (continued) B 3.5. 1-11 Rev i sion No. 31 I BASES SURVEILLANCE REQUIREMENTS REFERENCES Brunswick Un it 1 SR 3.5.1.12 (continued)

ECCS-Operating B 3.5.1 TIME testing. This exception is allowed since the ECCS instrumentation response time is a small part of the ECCS RESPONSE TIME (e.g., sufficient margin exists in the emergency diesel generator start time when compared to the instrumentation response time) (Ref. 14). ECCS RESPONSE TIME tests are conducted every 24 months. The 24 month Frequency is consistent with the Brunswick refueling cycle. 1. UFSAR , Section 6.3.2.2.3. 2. UFSAR , Section 6.3.2.2.4. 3. UFSAR , Section 6.3.2.2.1. 4. UFSAR , Section 6.3.2.2.2. 5. UFSAR, Section 15.2. 6. UFSAR , Section 15.6. 7. 10 CFR 50 , Appendix K. 8. UFSAR , Section 6.3.3. 9. 10 CFR 50.46. 10. (Deleted.)

11. 10 CFR 50.36(c)(2)(ii).

12. Memorandum from R.L. Baer (NRC) to V. Stello , Jr. (NRC), Recommended Interim Revisions to LCOs for ECCS Components , December 1 , 1975. 13. UFSAR , Section 6.3.3.7. 14. NED0-32291-A , System Analyses for the Elimination of Selected Response Time Testing Requirements , October 1995. 15. NEDC-32988-A.

Revision 2, Technical Justification to Support Risk-Informed Mod i fication to Selected Required End States fo r BWR Plants , December 2002. B3.5.1-17 Revision No. 58 I BASES ACTIONS Brunswick Unit 1 A.1 and A.2 (continued)

RCIC System B 3.5.3 OPERABLE status within 14 days. In this condition , loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is available to function during a loss of coolant accident (LOCA). OPERABILITY of the HPCI System is therefore verified immediately when the RCIC System is inoperable.

This may be performed as an administrative check, by examining logs or other information, to determine if the HPCI System is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be immediately verified , however , Condition B must be immediately entered. For transients and certain abnormal events with no LOCA , RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity , which allows easier control of the RPV water level. Therefore , a limited time is allowed to restore the inoperable RCIC to OPERABLE status. The 14 day Completion Time is based on the availability of the HPCI System and the low probability of the occurrence of an event that would require the RCIC System. B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time , or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to < 150 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 necessarv repairs to restore the system to OPERABLE status will be short. However, voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state. Required Action B.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 e nt e r MODE 3 d u rin g st a rt up w it h the LCO not met. Howe v e r, there i s no r estriction o n th e u se o f LCO 3.0.4.b , if applicable , because LCO 3.0.4.b requires performance of a risk assessm ent a ddres sing ino p era b l e syste ms and c ompo nents , co ns ideration of the results , deter m i nation of the acceptab ility of entering MODE 3 , and establ i shment of risk man ag ement 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. B 3.5.3-3 Revision No. 31 I B r unswick Un i t 1 RCIC System B 3.5.3 The allowed Completion reasonable , based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challeng i ng plant systems. (continued) B 3.5.3-4 Rev i s i on No. 31 I BASES SURVEILLANCE REQUIREMENTS REFERENCES Brunswick Unit 1 ----------------------------SR 3.5.3.5 (continued)

RCIC System B 3.5.3 This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line , coolant injection into the RPV is not required during the Surveillance. 1. 2. 3. UFSAR , Section 3.1.2.4.4. UFSAR , Section 5.4.6. 10 CFR 50.36(c)(2)(ii).

4. NEDC-32988-A.

Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States fo r BWR Plants. December 2002. B 3.5.3-8 Revision No. 31 I BASES ACTIONS Brunswick Un i t 1 Reactor Bu i ld i ng-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 E.1 (continued) threaten the ability to m i tigate an event that causes a conta i nment depressurization. Therefore , the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Completion Time for Condition A and the fact that the leak tight primary containment boundary is being mainta i ned. E.1 If one line has one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition E. the remaining breakers in the remaining lines can provide the opening function. The plant must be brought to a condition 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . 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. voluntarv entrv into MODE 4 may be made as it i s 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 r esults. 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-4G.1 Wit h two lines wit h one or more vacuum breaker s inoperable for openi ng , the primary containment boundary is intact. However, in the even t of a containment depressurization , the function of the vacuum breakers is lost if the vacuum breaker s are inoperable for reasons other than th e Nit rogen Backup S y stem being in o perabl e (C ondition D). There fo r e , all vac u um breakers i n one line mus t b e restored to OPERABLE stat u s withi n 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s. T hi s Completi on Time is consist e nt with th e ACTION S of LCO 3.6.1.1 , w h ich re qui r es that p rim ary co nt a inme n t be restored t o OPERABLE status wi th in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . G.1 and G.2 H.1 and H.2 B 3.6.1.5-6 Revision No. 31 I SURVEILLANCE REQUIREMENTS Brunswick Unit 1 Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 If any Required Action and associated Completion Time of Condition A. B. C. D. F or G cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable , based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3.6.1.5.1 The bank of nitrogen bottles supplying each nitrogen backup subsystem header is required to be verified to be pressurized to 1130 psig to ensure sufficient motive force is available to the pneumatic butterfly valve actuators following a LOCA and subsequent primary containment isolation. A nitrogen bottle pressure 1130 psig assures sufficient capacity to actuate and cycle the pneumatic butterfly valve for 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months including design system leakage. This Surveillance may be satisfied by (continued) B 3.6.1.5-7 Revision No. 31 I BASES SURVEILLANCE REQUIREMENTS REFERENCES B r unswick Unit 1 Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 SR 3.6.1.5.6 (continued) 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has demonstrated that these components will pass this Surveillance when performed at the 24 month Frequency. Therefore, the Frequency is concluded to be acceptable from a reliability standpoint.

1. NRG Generic Letter GL 84-09 , Recombiner Capability Requirements of 10 CFR 50.44(c)(3)(ii). 2. UFSAR, Section 6.2. 3. 10 CFR 50.36(c)(2)(ii).

4. NEDC-32988-A.

Revision 2 , T echnical Justification to Support Risk-Informed Mod i fication to Selected Required End States for BWR Plants , December 2002. B 3.6.1.5-9

Revision No. 31 I BASES ACTIONS Brunswick Unit 1 A.1 (continued)

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 with those assumed for the design basis analysis. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered acceptable due to the low probability of an event in which the remaining vacuum breaker capability would not be adequate . .B...1 If a required suppression chamber-to-drvwell vacuum breaker is inoperable for opening and is not restored to OPERABLE status within the required Completion Time. the plant must be brought to a condition in which overall plant risk is minimized. To ach i eve this status. the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicabilitv of the LCO i s acceptable because the plant risk i n MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However. voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state. Required Action B.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 O 4 b requires performance of a risk assessment addressing inoperable systems and components. consideration of the results. determination of the acceptabilitv 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 Applicabilitv 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. g,+C.1 With one vacuum breaker not closed , communication between the drywell and suppression chamber airspace could occur , and , as a result , there is the potential for primary containment overpressurization due to this bypass leakage if a LOCA were to occur. Therefore, the open vacuum breaker must be closed. A short time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment.

If vacuum breaker position indication is not available , an alternate method of verifying that the vacuum breakers are closed is to verify that the differential pressure between the suppression chamber and drywell is maintained

> 0.5 times the initial differential pressure for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without nitrogen makeup. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is considered adequate to perform this test. B 3.6.1.6-4 Revision No. 31 I SURVEILLANCE REQUIREMENTS Brunswick Un i t 1 Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 C.1 and C.2D.1 and D.2 If any Required Action and associated the open suppression drywell vacuum breaker cannot be closed w i th i n the required Completion Time can not be met , the plant must be brought to a MODE in which the LCO does not apply. To achieve this status , the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3.6.1.6.1 Each vacuum breaker is verified closed (except when the vacuum breaker is performing its intended design function) to ensure that this potential large bypass leakage path is not present. This Surveillance is performed by observing the vacuum breaker position indication or by verifying that the differential pressure between the suppression chamber (continued)

B 3.6.1.6-5 Revision No. 31 I BASES SURVEILLANCE REQUIREMENTS RE F ERENCE S Brunswick Un i t 1 Suppress i on Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 SR 3.6.1.6.1 (continued) a n d d rywe ll is main t ained > 0.5 t i mes the initial differential pressure for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without nitrogen makeup. The 14 day Frequency is based on engineering judgment , is considered adequate in view of other indications of vacuum breaker status available to operations personnel and procedural controls to ensure the drywell is normally maintained at a higher pressure than the suppression chamber , and has been shown to be acceptable through operating experience. This verification is also required within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after any discharge of steam to the suppression chamber from any source , and within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after an operat i on that causes any of the vacuum breakers to open. A Note is added to this SR which allows suppression chamber-to-drywell vacuum breakers opened in conjunction w i th the performance of a Surveillance to not be considered as failing this SR. These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers. SR 3.6.1.6.2 Each required vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position.

This is accomplished by verifying each required vacuum breaker operates through at least one complete cycle of full travel. This SR ensures that the safety analysis assumpt i ons are valid. The 92 day Frequency of this SR was developed , based on lnservice Testing Program requirements to perform valve testing at least once every 92 days. In addition , this functional test is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after a discha r ge of steam t o the suppression chambe r fro m the SRVs. SR 3.6.1.6.3 Verification of the vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 24 month Frequency has been demonstrated to be acceptable , based on operating e x perie n ce , and is further just i fied because of other surveillances performed more frequ e ntly that c o nvey the proper functioning status o f each va c uum b rea ker. 1. U FSAR , Sectio n 6.2. 2. 1 O C FR 50.36 (c)(2)(ii). 3. NEDC-32988-A. Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants December 2002. B 3.6.1.6-5 Rev i sion No. 65 BASES ACTIONS (continued)

Brunsw i ck Un i t 1 RHR Suppression Pool Cooling B 3.6.2.3 If one RHR suppression pool cooling subsystem is inoperable and is not restored to OPERABLE status within the required Completion Time. the plant must be brought to a condition 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . 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. 5) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However. voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state. Required Action B.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 address i ng inoperable systems and components. consideration of the results. determ i nation 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 Applicabi l ity 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 . .G...1 With two RHR suppression pool cooling subsystems inoperable , one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition , there is a substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability o f a OBA and because alternative methods to remove heat from primary containment are ava i lable. C.1 and C.20.1 and D.2 If aAy-the Required Action and associated Completion Time of Condition C cannot be met, the plant must be brought to a M O D E in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to M ODE 4 withi n 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonabl e , based o n operating experience, to rea ch the required pl ant condi tions f rom fu ll power conditions in an order ly manner and without challen g i n g pl ant sys tem s. B 3.6.2.3-3 Rev i s i on No. 41 BASES SURVEILLANCE REQUIREMENTS (continued) REFERENCES Brunswick Un i t 1 SR 3.6.2.3.2 RHR Suppression Pool Cooling B 3.6.2.3 Verifying that each RHR pump develops a flow rate :2:: 77 00 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment pressure and temperature can be maintained below the design limits during a OBA (Ref. 2). The normal test of centrifugal pump performance required by ASME OM Code (Ref. 4) is covered by the requirements of LCO 3.5.1 , "ECCS-Operating

." This test confirms one point on the pump design curve , and the results are indicative of overall performance. Such tests confirm component OPERABILITY , and detect incipient failures by indicating abnormal performance. The Frequency of this SR is 92 days. 1. UFSAR , Section 6.2.1.1.3.2. 2. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 , September 1995. 3. 10 CFR 50.36(c)(2)(ii). 4. ASME Code for Operation and Maintenance of Nuclear Power Plants. 5. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002 B 3.6.2.3-4 Revision No. 59 BASES ACTIONS Brun swi ck U ni t 1 A.1 (continued)

Secondary Containment B 3.6.4.1 and 3. This time pe r iod also ensures that the probabil i ty of an accident (requiring secondary containment OPERABILI T Y) occurring during periods where secondary containment is inoperable is minimal. B.1 and B.2 If secondary containment cannot be restored to OPERABLE status within the required Completion Time , the plant must be brought to a MODE in which the LCO does not apply 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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. 7), 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 B.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 establ i shment 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 s afe--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. C.1 and C.2 Movement of recently irradiated fuel assemblies in the secondary containment and OPDRVs can be postulated to cause significant fission product release to the secondary containment.

In such cases , the secondary containment is the only barrie r to release of fission products to the envi ron me n t. T herefor e , m o vement o f r ecently irradiate d fu el assemblies must be immediately suspended if the secondary containme n t is i nope r ab le. Su spensi on o f th is activi ty shall not p re c l u de comp l et i ng a n action that involves mov i ng a component to a saf e p o sitio n. A lso , ac ti on must be immediately in i t i ated to suspend OPDRV s t o minimize t he probabilit y of a v ess e l draindown and subsequent potential for fissi on p rodu c t r e lease. Action s must cont i n ue u ntil OPDRV s a re suspe n d ed. LCO 3.0.3 is not ap plicable wh il e i n MODE 4 or 5. However , s in ce r ec ently irradiated fuel a ssembly movement can occur in MODE 1 , 2 , or 3 , Required Ac t ion C.1 h a s been mod i fied by a Note s t ating that B 3.6.4.1-3 Revis i on No. 31 BASES (continued)

REFERENCES Brunswick Unit 1 Secondary Containment B 3.6.4.1 1. NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 , September 1995. 2. 3. UFSAR , Section 15.6.4. Not used. 4. 10 CFR 50.36(c)(2)(ii). 5. 10 CFR 50.36(c) (2) (ii). 6. Regulatory Guide 1.52 , Revision 1. 7. NEDC-32988

-A. Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002. B 3.6.4.1-6 Revision No. 31 I BASES APPLICABILITY (continued)

ACTIONS Brunswick Unit 1 SGT System B 3.6.4.3 (OPDRVs) or during movement of recently irradiated fuel assemblies in the secondary containment.

Due to radioactive decay, the SGT System is only required to be OPERABLE during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). A.1 With one SGT subsystem inoperable in MODE 1 , 2, or 3 , the inoperable subsystem must be restored to OPERABLE status in 7 days. In this condition , the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function.

However , the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed.

The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT subsystem and the low probability of a OBA occurring during this period. B.1 and B.2 In MODE 1, 2, or 3 , if one SGT subsystem cannot be restored to OPERABLE status within the required Completion Time or both SGT subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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. 8) 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 B.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 requ i res perfo r mance of a risk assessment addressing i noperable systems and components , considerati o n of the results. determination of the acceptability of entering M O DE 3. and es tablishment of risk man ageme nt act i ons if ap propriate. LCO 3.0.4 is not appli ca b l e to. an d the Note doe s not preclude chan g es i n MODES or other specifi ed con d i tions in t he App licabil i t y tha t are requ ired to comply wit h ACTIONS o r that are part of a shutdown of the unit. The allowed Completion Time s are-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. B 3.6.4.3-3 Revision No. 31 BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES Brunswick Unit 1 SR 3.6.4.3.2 SGT System B 3.6.4.3 T his SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 6), except as specified in Specification 5.5.7 , "Ventilation Filter Testing Program (VFTP)". The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency , minimum system flow rate , and the physical properties of the activated charcoal (general use and following specific operations).

It is noted that , per the basis provided by ESR 99-00055 (Ref. 7), system flow rate is determined using installed calibrated flow orifice plates. Specific test frequencies and additional information are discussed in detail in the VFTP. SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal. While this Surveillance can be performed with the reactor at power , operating experience has demonstrated that these components will usually pass the Surveillance when performed at the 24 month Frequency.

The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2 , "Secondary Containment Isolation Instrumentation

," overlaps this SR to provide complete testing of the safety function. Therefore , the Frequency was found to be acceptable from a reliability standpoint.

1. UFSAR , Section 6.5.1. 2. NEDC-32466P , Powe r Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 , September 1995. 3. UFSAR Section 15.6.4. 4. Not used. 5. 10 CFR 50.36(c)(2)(ii). 6. Regulatory Guide 1.52 , Revision 1. 7. ESR 99-00055 , SBGT and CBEAF Technical Specification Surveillance Flow Measurement.

8. NE D C-32988-A Revision 2. Technical Justification to Supp ort Risk-Informed Modification to Selected Required End Stat es fo r BWR Plants. December 20 02. B 3.6.4.3-7 Revision No. 31 I BASES ACTIONS (continued)

Brunswick Unit 1 RHRSW System B 3.7.1 Required Action B.1 is intended to handle the inoperability of one RHRSW subsystem for reasons other than Condition A. The Completion Time of 7 days is allowed to restore the RHRSW subsystem to OPERABLE status. With the unit in this condition , the remaining OPERABLE RHRSW subsystem is adequate to perform the RHRSW heat removal function.

However , the overall reliability is reduced because a single failure in the OPERABLE RHRSW subsystem could result in loss of RHRSW function. The 7 day Completion Time is based on the Completion Time provided for the RHR suppression pool cooling function , the redundant RHRSW capabilities afforded by the OPERABLE subsystem, and the low probability of an event occurring requiring RHRSW during this period. A Note to the Required Action indicates that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. C.1 If one RHRSW subsystem is inoperable or one RHRSW pump in one or one subsystem is inoperable and not restored within the provided Completion Times. the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status. the plant must be brought to at least MODE 3 with i n 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Rema i ning in the Applicabilitv of the LCO is acceptable because the plant r i sk in MODE 3 is similar to or lower than the risk in MODE 4 <Ref. 7) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However. voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state. Required Action C.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. the r e is no restriction on the use of LCO 3.0.4.b. if applicable. bec ause LCO 3.0.4.b re q u ir es pe rformance of a risk assessment addressing inoperable systems and components.

consideration of th e results. determination of the acceptability of entering MODE 3. a nd establishment of risk man a gement actions, if appropriate. LCO 3.0.4 is no t appl i cable to. and the Note d oe s not preclud e. c hanges i n M ODES or ot h er specified cond itions in the A pplicability th at are require d to com ply wi th A CT I ONS or th a t a re part of a s hutdown of the u n it G,..+D.1 With both RHRSW subsystems inoperable (e.g., one or two RHRSW pumps inoperable in each subsystem), the RHRSW System is not B 3.7.1-4 Revision No. 41 Brunswick Unit 1 RHRSW System B 3.7.1 capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for restoring one RHRSW subsystem to OPERABLE status , is based on the Completion Time provided for the RHR suppression pool cooling function. The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7 , be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. D.1 and D.2E.1 and E.2 If the RHRSW subsystems cannot be not restored to OPERABLE status within the associated Completion Times, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status , the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable , based on operating experience , to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. (continued)

B 3.7.1-5 Revision No. 41 BASES (continued)

SURVEILLANCE REQUIREMENTS REFERENCES Brunswick Unit 1 SR 3.7.1.1 RHRSW System B 3.7.1 Verifying the correct alignment for each manual , power operated , and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths exist for RHRSW operation. This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since these valves are verified to be in the correct position prior to locking , sealing , or securing. A valve is also allowed to be in the nonaccident position , and yet considered in the correct position , provided it can be realigned to its accident position.

This is acceptable because the RHRSW System is a manually initiated system. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned , such as check valves. The 31 day Frequency is based on engineering judgment , is consistent with the procedural controls governing valve operation , and ensures correct valve positions.

1. 2. UFSAR , Section 9.2.1.2. UFSAR , Chapter 6.2. 3. NEDC-32466P , Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 , September 1995; and Supplement 1 , March 1996. 4. Letter BR5-96-074 , Long Term Suppression Pool Suppression Pool Cooling Mode for Long Term Containment Cooling , from M. E. Ball (GE) to R. E. Helme (CP&L), September 19 , 1996. 5. 10 CFR 50.36(c)(2)(ii). 6. GENE-B2100565-09 , Technical Specification Improvements to the Emergency Core Cooling System for the Carolina Power and Light Brunswick Steam Electric Plant Units 1 and 2 , Revision 1 , October 1996. 7. NEDC-32988-A. Revision 2. Technical Justification to Support Risk-Informed Mod i fication to Selected Required End States for BWR P l ants. December 2002. B 3.7.1-6 Revision No. 41 BASES ACTIONS (continued)

B r u nswi ck Unit 1 C.1 and C.2 CREV System B 3.7.3 In MO DE 1 , 2, or 3 , if any Required Action and r equ ir ed Completion T im e of Condition A or B cannot be met or two CREV subsystems are inoperable for reasons other than Cond i tion B , the unit must be placed in a MODE that minimizes accident overall plant risk. To achieve this status , the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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. 9) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However. voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state , Required Action C.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 acceptabilitv 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 s afe-is_reasonable, based on operating experience , to rea c h the re qu ir ed un i t cond i t i ons from full power conditions in an orderly manner and without challenging unit systems. D.1. D.2.1. D.2.2. and D.2.3 The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while i n MODE 1 , 2 , or 3 , the fuel movement is independent of reactor operations. T herefore , inabil it y to suspend movement of irradiated fuel assembl i es is not sufficient reason to require a reactor shutdown. During movement of irradiated fuel assemblies in the secondary containment, during CORE A L TERAT IONS , or durin g OPDRVs , i f the i noperable CREV subsystem cannot be restored t o OPER A B LE st atus within the required Completion Time , the OPE R ABLE CR EV subsy s t e m may be placed in the radiation/smoke protection mod e. Thi s a ct i on ensures that the remaining subsystem is OPERAB LE , tha t no f ail ures that would prevent automatic actuation will occur, and th a t any active fai lu re will be readily detecte d. An a lt e rn at i ve to Req ui red Act i o n D.1 is to imme di ate l y suspend activ iti es that p r esent a potent i a l for r eleas i ng rad i oactiv i ty that might requ i re B 3.7.3-5 Rev i s i on No. 64 BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES Brunsw i ck Unit 1 SR 3.7.3.4 CREV System B 3.7.3 This SR verifies that on an actual or simulated initiation signal , each CREV subsystem starts and operates. This SR includes ensuring outside air flow is diverted to the HEPA filter and charcoal adsorber bank of each CREV subsystem.

The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.7.1 overlaps this SR to provide complete testing of the safety function.

Operating experience has demonstrated that the components will usually pass the SR when performed at the 24 month Frequency. Therefore , the Frequency was found to be acceptable from a reliability standpoint.

1. UFSAR , Section 6.4. 2. UFSAR , Section 9.4. 3. UFSAR , Section 6.4.4.1. 4. 10 CFR 50.36(c)(2)(ii). 5. ESR 99-00055 , SBGT and CBEAF Technical Specification Surveillance Flow Measurement.

6. Regulatory Guide 1.196 7. NEI 99-03 , "Control Room Habitability Assessment

," June 2001. 8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30 , 2004 , "NEI Draft White Paper , Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability

." (ADAMS Accession No. ML040300694). 9. NEDC-32988-A.

Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002 B 3.7.3-8 Revision No. 64 I BASES (continued)

ACTIONS Brunsw ic k Unit 1 A.1 Control Room AC System B 3.7.4 With one control room AC subsystem inoperable , the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition , the remaining OPERABLE control room AC subsystems are adequate to perform the control room air conditioning function.

However , the overall reliability is reduced because a single failure in the OPERABLE subsystems could result in loss of the control room air conditioning function.

The 30 day Completion Time is based on the low probability of an event occurring requiring control room i solation , the consideration that the remaining subsystems can provide the required protection , and the availability of alternate safety and nonsafety cooling methods. B.1 With two control room AC subsystems inoperable , the Control Room AC System may not be capable of performing the intended function. However, since the BNP control room is common to both Units 1 and 2 , the risk associated with continued operation for a relatively short time could be less than that associated with an immediate controlled shutdown of both units. Therefore , additional time is allowed to restore one of the inoperable control room AC subsystems to OPERABLE status. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time provides a period of time to correct the problem commensurate with the importance of ma i ntaining the Control Room AC System OPERABLE. This time period also ensures that the probability of an accident (requiring Control Room AC System OPERABILITY) occurring during periods when two control room AC subsystems are inoperable is minimal. C.1 and C.2 In MODE 1 , 2 , or 3 , if Required Action A.1 or B.1 cannot be completed within the associated Completion Time , the unit must be placed in a MODE that minimizes overall plant risk. To achieve this status , the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and i n MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Remaining in the Applicability ofthe LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk i n MODE 4 (Ref. 3) and b ecause the time spent in MODE 3 to p erform t he necessary repairs to restore the system to OPERABLE status will be short. Howeve r. voluntarv entry into MODE 4 may be made as it is also an acceptable lo w-risk state. Requir ed Action C.1 is modified by a Note that states that LCO 3.0.4.a is not app licable when e ntering MODE 3. This Note pr ohibits the us e of LC O 3.0.4.a to enter MODE 3 during s tartup w i th 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 ri sk assessment addr essing inoperable systems an d components. consideration of the results. determination of the acceptability of entering M ODE 3. a nd B 3.7.4-3 Revision No. 31 Brunswick Unit 1 Control Room AC System B 3.7.4 establ i shment of risk management actions if appropriate. LCO 3.0.4 is not applicab l e 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 s ai:e-is_reasonable , based on operating experience , to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. (continued)

B 3.7.4-4 Revision No. 31 I BASES ACTIONS (continued)

Brunswick Unit 1 D.1, D.2.1, D.2.2 , and D.2.3 Control Room AC System B 3.7.4 LCO 3.0.3 is not applicable while in MODE 4 or 5. However , since irradiated fuel assembly movement can occur in MODE 1 , 2 , or 3 , the Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2 , or 3, the fuel movement is independent of reactor operations.

Therefore , inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment , during CORE ALTERATIONS , or during OPDRVs , if Required Action A.1 or B.1 cannot be completed within the associated Completion Time , the OPERABLE control room AC subsystem or subsystems may be placed immediately in operation. This action ensures that the remaining subsystem(s) is OPERABLE , that no failures that would prevent actuation will occur , and that any active failure will be readily detected. An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. If applicable , CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position.

Also , if applicable , action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fiss i on product release. Action must continue until the OPDRVs are suspended. E.1 If three control room AC subsystems are inoperable in MODE 1 , 2 , or 3 , the Control Room AC System may not be capable of performing the intended function. Theref.ore , LCO 3.0.3 must be entered immediately. Therefore. the plant must be brought to a MODE in which overall plant risk is min i mized. To achieve this status. the plant must be brought to at least MODE 3 w i thin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaini n g i n the Applicability of the LC O is acceptable because the pla nt risk in MODE 3 is similar to or lower than th e risk in MODE 4 (Ref. 3) a nd the time s p ent in MOD E 3 to p erform the necessary r epair s t o restore the system to O PERABLE status will be short. Howev e r. volu ntarv entry into M O DE 4 may be m ade as it is als o an accept able low-r i sk s tat e Req uired Act ion E.1 is m od ified b y a N ote t hat sta tes t h at LCO 3.0.4.a is not app li cable w hen en t ering MODE 3. T hi s Note pro hibi ts the use of LCO 3.0.4.a t o en ter MOD E 3 dur ing startup wit h the LCO not met. However. there is no restriction on the use of LC O 3 , 0.4 , b. if app l ic a ble. B 3.7.4-5 Rev i sion No. 31 Brunswick Unit 1 Control Room AC System 8 3.7.4 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. (continued) 8 3.7.4-6 Revision No. 31 I BASES ACTIONS (continued)

SURVEILLANCE REQUIREMENTS REFERENCES Bruns wi c k Un i t 1 F.1 , F.2 , and F.3 Control Room AC System B 3.7.4 LC O 3.0.3 is not applicable while in MODE 4 o r 5. Ho w e v er , s i nce irrad i ated fuel assembly movement can occur in MODE 1 , 2 , or 3 , the Requ i red Act i ons of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1 , 2 , or 3 , the fuel movement is independent of reactor operations. Therefore , inability to suspend movement of irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown. Dur i ng movement of irradiated fuel assemblies in the secondary conta i nment , during CORE ALTERATIONS , or during OPDRVs , with three control room AC subsystems inoperable , action must be taken i mmediately to suspend activities that present a potential for releas i ng radioactiv i ty that might requ i re isolation of the control room. This places the unit in a cond i tion that minimizes risk. If applicable , CORE AL TERA TIONS and handling of irradiated fuel in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also , if applicable , action must be initiated i mmediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended. SR 3.7.4.1 This SR verifies that the heat removal capability of the system is suff i c i ent to remove the control room heat load assumed in the safety analyses. The SR consists of a combinat i on of testing and calculation. The 24 month Frequency is appropriate since significant degradation of the Control Room AC System is not expected over th i s time per i od. 1. 2. UFSAR , Section 6.4.2. 10 CFR 50.36(c)(2)(ii). 3 , NEDC-32988-A.

Revision 2 Technical Justification to Support Risk-Informed Mod i fication to Selected Requ i red End States for B WR Pl a nts , D ece mb er 2002 , B 3.7.4-7 Rev i s i on No. 3 1 I BASES (continued)

LCO APPLICABILITY ACTIONS Brunsw i ck Unit 1 Main Condenser Offgas B 3.7.5 To ensure compliance with the assumptions of the Main Condenser Offgas System failure event (Ref. 1), the fission product release rate should be consistent with a noble gas release to the reactor coolant of 100 µCi/MWt-second after decay of 30 minutes. The LCO is established consistent with this requirement (2436 MWt x 100 µCi/MWt-second

= 243 , 600 µCi/second) and is based on the original licensed RATED THERMAL POWER. The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System. This occurs during MODE 1 , and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation.

In MODES 4 and 5 , main steam is not being exhausted to the main condenser and the requirements are not applicable.

A.1 If the offgas radioactivity rate limit is exceeded , 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the gross gamma activity rate to within the limit. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable , based on engineering judgment , the time required to complete the Required Action , the large margins associated with permissible dose and exposure limits , and the low probability of a Main Condenser Offgas System failure. B.1. B.2.

and B.3.1. and B.3.2 If the gross gamma activity rate is not restored to within the limits in the associated Completion Time , all main steam lines or the SJAE must be isolated. This isolates the Main Condenser Offgas System from significant sources of radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed , and at least one main steam line drain valve in each drain line is closed. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable , based on operating experience , to perform the actions from full power conditions in an orderly manner and without challenging unit systems. (continued)

B 3.7.5-2 Revision No. 31 I BASES ACTIONS SURVEILLANCE REQUIREMENTS Brunswick Unit 1 B.1. B.2. B.3.1. and B.3.2 (continued)

Main Condenser Offgas B 3.7.5 An alternative to Required Actions B.1 and B.2 is to place the unit in a MODE in which the LCO does not apply overall plant risk is minimized. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MOPE 3 is similar to or lower than the risk in MODE 4 <Ref. 4) and because the time spent in MODE 3 to pertorm the necessary repairs to restore the system to OPERABLE status will be short. However. voluntarv entry into MODE 4 may be made as it is also an acceptable low-risk state. Required Action B.3 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 Appl i cability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Time s af&-i.s_reasonable, based on operating experience , to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SR 3.7.5.1 This SR , on a 31 day Frequency , requires an isotopic analysis of an offgas sample (taken at the discharge of the main condenser air ejector prior to dilution or discharge) to ensure that the required limits are satisfied. The noble gases to be sampled are Xe-133, Xe-135 , Xe-138 , Kr-85m , Kr-87 , and Kr-88. If the measured rate of radioactivity increases significantly 50% after correcting for expected increases due to changes in THERMAL POWER), an isotopic analysis is also performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the increase is indicated (by the condenser air ejector noble gas activity monitor), to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas , and is acceptable , based on operating experience. This SR is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation.

Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates. B 3.7.5-3 Revision No. 31 REFERENCES Brunsw i ck Un i t 1 1. 2. 3. UFSAR , Section 11.3. 10 CFR 50.67. 10 CFR 50.36(c)(2)(ii). Main Condenser Offgas B 3.7.5 4. NEDC-32988-A.

Revision 2 , Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002 , B 3.7.5-4 Rev i s i on No. 31 I BASES ACTIONS SURVEILLANCE Brunsw i ck U n it 1 G.1 (continued)

AC Sources-Operating B 3.8.1 According to Regulatory Guide 1.93 (Ref. 9), with two or more DGs inoperable , operation may continue for a per i od that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . While this Action allows more than two DGs to be inoperable , Regulatory Guide 1.93 (Ref. 9) assumes only two DGs are required by the LCO , and a loss of those two DGs results in a total loss of on site power to the Class 1 E Electrical Power Distribution System. Thus , with the BNP electrical design , a loss of the four DGs results in the same condition assumed in Regulatory Guide 1.93 (Ref. 9). H.1 and H.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply overall plant r i sk is m i nimized. To achieve this status , the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Remaining in the Appl i cab i lity of the LCO is acceptable because the plant r i sk i n MODE 3 is simila r to or lower than the risk in MODE 4 (Ref. 14) and because the time spent in MODE 3 to perform the necessarv repai r s to restore the system to OPERABLE status will be short. However. voluntarv entry into MODE 4 may be made as it is also an acceptable low-r i sk state. Required Action H 1 is modified by a Note that states that LCO 3 , 0.4 , a is not applicable when entering MODE 3. This Note prohibi t s 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 r i sk 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 Applicabil i ty that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Time s afe-is_reasonable , based on operating experience , to reach the required plant conditions from full power conditions in an orderly manner and w i thout challeng i ng plant systems. L1 Condition I corresponds to a level of degradation in whic h all redundan cy in the AC electrical power supplies has been lost. At thi s s eve r e l y d eg raded leve l , any further losses in the A C e lectrical pow er system m ay cau se a loss of f un c tion. Ther e fore, no additi o na l time is justifie d for conti n ued opera t i on. The uni t is r e q ui r ed by LCO 3.0.3 t o c om me n ce a controlle d shut do w n. The AC sources are des i gned to permit inspection and test i ng of all B 3.8.1-19 Revision No. 31 BASES REFERENCES (continued)

Brunswick Unit 1 AC Sources-Operating B 3.8.1 11. Regulatory Guide 1.9 , July 1993 , Revision 3. 12. Regulatory Guide 1.137 , January 1978. 13. IEEE Standard 308. 14. NEDC-32988-A Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002, B 3.8.1-34 Revision No. 31 I BASES ACTIONS Brunswick Un i t 1 A.1 (continued)

DC Sources-Operating B 3.8.4 Therefore.the Required Actions of Condition A are modified by a Note to indicate that when Condition A results in de-energization of an AC electrical power distribution subsystem or a DC electrical power distribution subsystem , Actions of LCO 3.8. 7 must be immediately entered. This allows Condition A to provide requirements for the loss of a DC electrical power subsystem without regard to whether a distribution subsystem is de-energized.

LCO 3.8.7 provides the appropriate restriction for a de-energized distribution subsystem.

Condition A represents one division with a loss of ability to completely respond to an event , and a potential loss of ability to remain energized during normal operation.

It is therefore imperative that the operator's attention focus on stabilizing the unit , minimizing the potential for complete loss of DC power to the affected division. If one of the required DC electrical power subsystems is inoperable (e.g., inoperable battery , inoperable battery charger(s), or inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition.

Since a subsequent worst case single failure could , however , result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident , continued power operation should not exceed 7 days. The Completion time is based on the capacity and capability of the remaining DC Sources , including the enhanced reliability afforded by the capability to manually transfer DC loads to the opposite unit's DC electrical power distribution subsystems. B.1 and B.2 If the DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time or if two or more DC electrical power subsystems are inoperable , the unit must be brought to a MODE in which the LCO does not apply overall plant risk is m i nim i zed. To achieve this status , the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Rema i ning in the Appl i cabilit y of the LCO i s acceptable because the p l ant risk in MODE 3 is sim i lar to or lower than the risk in MODE 4 (Ref. 12) and because the time s p ent in MODE 3 to p erform the necessarv repairs to r estore t he system to O PERABLE status will be short. Howev er, voluntarv entry into MODE 4 may be made as it is also an accepta ble low-risk state, Required Action B.1 is mod i fied by a Note that states that LCO 3.0.4.a is no t appl icable when e ntering M ODE 3. This Not e prohibits th e use of LC O 3.0.4.a to ent er MOD E 3 dur ing st artup wit h the LCO not m et. H oweve r , th ere is no restr ic tio n on the u se o f LCO 3.0.4.b , i f ap plicable b ecau se LCO 3.0.4.b req u ir es p erfor m ance o f a risk as sess m ent ad dre ssing i nop erab le systems and component s , c onsidera t i on of the results , determination of the accep t ability of enter i ng MOD E 3, and B 3.8.4-4 Revision No. 31 Brunsw i ck Unit 1 DC Sources-Operating 8 3.8.4 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 Applicabil i ty that are required to comp l y with ACTIONS or that are part of a shutdown of the unit. (continued) 8 3.8.4-5 Revision No. 31 I BASES ACTIONS SURVEILLANCE REQUIREMENTS Brun swick Unit 1 B.1 and B.2 (continued)

DC Sources-Operating B 3.8.4 The allowed Comp l etion Time s are-is_reasonable , based on operating exper i ence , to reach the required plant condit i ons from f ull power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7). C 1andC2 If two or more DC electrical power subsystem are inoperable , the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status , the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable. based on operating experience. to reach the required plant conditions from full power cond i tions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatorv Guide 1.93 <Ref. 7). SR 3.8.4.1 Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and ma i ntain the battery in a fu ll y charged state. The voltage requirements are based on the nominal design voltage of the battery. The 7 day Frequency is conservative when compared with manufacturer recommendations and IEEE-450 (Ref. 8). SR 3.8.4.2 Visual inspection to detect corros i on of the battery cells and connections , or measurement of the resistance of each inter-cell and inter-rack connection , provides an i ndication of physical damage or abnormal deterioration that could potentially degrade battery performance. T h e connection resistanc e limits ar e ::; 1.2 times t he establishe d benchmark resistance values for the connections or::; 5µohms abov e t he established benchmark resistance values for the connections , which e v er is higher. These connection r e sistance acceptan ce criteri a wer e deri ved from IEEE-450 (Ref. 8) and IEEE-484 (R e f. 9), respectiv ely. The Frequency for these inspections, which can detec t conditions tha t can cause power losse s due to resistance h eating, is 92 d a y s. Thi s Fre qu ency is cons i s t e nt w i th man uf a c ture r s r eco mm enda t ions. (co nt in ue d) B 3.8.4-6 Re vi s i on No. 31 I_ BASES REFERENCES (continued)

Brunswick Unit 1 6. 10 CFR 50.36(c)(2)(ii).

7. Regulatory Guide 1.93 , December 197 4. 8. IEEE Standard 450, 1987. 9. IEEE Standard 484, 1996. 10. UFSAR, Section 8.3.2. 11. IEEE Standard 485, 1983. DC Sources-Operating B 3.8.4 12. NEDC-32988-A.

Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants. December 2002. B 3.8.4-12 Revision No. 31 I BASES ACTIONS B run sw i ck Un i t 1 D.1 (cont i nued) Distribution Systems-Operating B 3.8.7 d i stribution system. At this time , an AC bus could again become inoperable , and the DC electrical power distribut i on 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 Cond i tion D was entered. The 176 hour0.00204 days 0.0489 hours 2.910053e-4 weeks 6.6968e-5 months Complet i on Time is an acceptable lim i tat i on on this potential of failing to meet the LCO indefinitely.

E.1 and E.2 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 the LCO does not apply 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hou r s. Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the r i sk in MODE 4 <Ref. 4) and because the time spent in MODE 3 to perform the necessarv repairs to restore the system to OPERABLE status will be short. However. voluntarv entrv into MODE 4 may be made as it is also an acceptable low-risk state. Requ i red 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 applicab l e. 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 cond i tions i n the Appl i cabil i ty that are required to com ply with ACTIONS or that are part of a shutdown of the unit. The allo w ed Comple ti on Time s afe-i.s_r easonab l e , based on opera t ing experience , to reach the required plant conditions from full powe r conditions in an orderly manner and without challenging plant sy s tem s. F.1 C o ndition F corresp o nds to a level of degradati on in th e el e c t r i cal po w e r distri b ution syste m tha t causes a required safety function to be l o st. When more than one AC or DC electrical power distribut i on subsyst e m is l ost , and this re s u lts i n the lo s s of a re q uir e d func tio n , t he p lant is in a con dit ion outs i de th e accide nt a nal y s i s. The r e f o r e, n o ad d itiona l t im e is B 3.8.7-13 Revision No. 3 1 BASES (continued) SURVEILLANCE REQUIREMENTS REFERENCES Br unsw i ck U nit 1 SR 3.8.7.1 Distribution Systems-Operating B 3.8.7 Th i s Surveillance ver i fies that the AC and DC electrica l po w er distrib u tion systems are functioning properly , with the correct circuit breaker alignment.

This includes verifying that distribution bus tie breakers are open and control power transfer switches associated with the 4.16 kV and 480 V emergency buses and transfer switches associated with the ESS and DG panels are aligned to their normal DC sources. The correct breaker alignment ensures the appropriate separation and independence of the electrical buses are maintained , and power is available to each required bus. The verification of energization of the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. This may be performed by verification of absence of low voltage alarms or by verifying a load powered from the bus is operating. The 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems , and other indications available in the control room that alert the operator to subsystem malfunctions. SR 3.8.7.2 This Surveillance verifies that no combination of more than two power conversion modules (consisting of either two lighting inverters or one light i ng inverter and one plant uninterruptible power supply unit) are aligned to Division II (bus B). Two power conversion modules aligned to Divis i on II (bus B) was an initial assumption in the DC battery load study. Limiting two power conversion modules to be aligned to Divis i on II ensures the associated batteries will supply DC power to safety related equipment during a design basis event. The 7 day Frequency takes into account the r edundant capab ili ty of t he DC elect ri cal powe r distribution subsystems and indications ava i lable in the control room to alert the operator of power conversion module misalignment.

1. UFSAR , Chapter 6. 2. UFSAR , C hapte r 15. 3. 10 CFR 50.36 (c)(2)(ii). 4. N EDC-32988-A. Rev i sion 2 , Tech ni cal J u s tifi ca ti on to Su pp ort Risk-Informed Modification to Selected Required End States fo r BWR Plants December 2002. B 3.8.7-15 Re vi s i on No. 3 1 I Regulatory Commitments BSEP 16-0087 Enclosure 7 Page 1 of 1 The following table identifies those actions committed to by Duke Energy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Please direct questions regarding these commitments to Mr. Lee Grzeck, Manager -Regulatory Affairs , at (910) 457-2487.

Regulatory Commitments Due Date I Event Duke Energy will follow the guidance Ongoing established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council , Revision 3 , July 2000. Duke Energy will follow the guidance Upon implementation of amendment.

established in TSTF-IG-05-02, Revision 2 , "Implementation Guidance for TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A."'

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