RA-18-0079, Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO
| ML18227A535 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/14/2018 |
| From: | William Gideon Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-18-0079 | |
| Download: ML18227A535 (89) | |
Text
Completion Times 1.3 Brunswick Unit 1 1.3-3 Amendment No. 281 1.3 Completion Times DESCRIPTION The above Completion Time extension does not apply to those (continued) Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or
variable expressed in the Condition) and separate tracking of Completion
Times based on this re-entry. These exceptions are stated in individual
Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be
expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the
Completion Time is referenced from a previous completion of the
Required Action versus the time of Condition entry) or as a time modified
by the phrase "from discovery . . ." Example 1.3-3 illustrates one use of
this type of Completion Time. The 10 day Completion Time specified for
Condition A and B in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions. EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated
Completion
Time not met. B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the
time that Condition B is entered.
(continued)
AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-5 Amendment No. 282 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE status. ---------NOTE----------
Until DG 4 is
returned to
OPERABLE status, not to exceed 0745
EST on December 13, 2017, the 14 day and
17 day Completion
Times are extended
to 30 days and
33 days, respectively.
7 days from discovery of
unavailability of
SUPP-DG AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of
Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure
to meet LCO 3.8.1.a
or b (continued)
AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-7 Amendment No. 282 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.2 -------------------------------NOTES------------------------------ 1. All DG starts may be preceded by an engine prelube period. 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used
for this SR. When modified start procedures are
not used, the time, voltage, and frequency
tolerances of SR 3.8.1.7 must be met. 3. A single test at the specified Frequency will satisfy this Surveillance for both units. 4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3
may be suspended. Past due surveillances will
be completed within 7 days of restoration of
EDG 4 operability or December 20, 2017, whichever occurs first.
Verify each DG starts from standby conditions and achieves steady state voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance
Frequency Control
Program (continued)
AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-8 Amendment No. 282 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 -------------------------------NOTES------------------------------ 1. DG loadings may include gradual loading. 2. Momentary transients outside the load range do not invalidate this test. 3. This Surveillance shall be conducted on only one DG at a time. 4. This SR shall be preceded by and immediately follow, without shutdown, a successful
performance of SR 3.8.1.2 or SR 3.8.1.7. 5. A single test at the specified Frequency will satisfy this Surveillance for both units. 6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3
may be suspended. Past due surveillances will
be completed within 7 days of restoration of
EDG 4 operability or December 20, 2017, whichever occurs first.
Verify each DG is synchronized and loaded and operates for 60 minutes at a load 2800 kW and 3500 kW.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of fuel oil.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.5 Check for and remove accumulated water from each engine mounted tank.
In accordance with the Surveillance
Frequency Control
Program (continued)
AC Sources-Operating 3.8.1 Brunswick Unit 1 3.8-9 Amendment No. 282 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------
Until DG 4 is returned to OPERABLE status, not to
exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may
be suspended. Past due surveillances will be
completed within 7 days of restoration of EDG 4
operability or December 20, 2017, whichever occurs
first.
Verify the fuel oil transfer system operates to transfer fuel oil from the day fuel oil storage tank to the engine
mounted tank.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.7 -------------------------------NOTES------------------------------ 1. All DG starts may be preceded by an engine prelube period. 2. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG starts from standby condition and achieves, in 10 seconds, voltage 3750 V and frequency 58.8 Hz, and after steady state conditions are reached, maintains voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance
Frequency Control
Program (continued)
Distribution Systems-Operating 3.8.7 Brunswick Unit 1 3.8-36 Amendment No. 280 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIMED. One or more DC electrical power distribution
subsystems inoperable for
reasons other than
Condition C. D.1 Restore DC electrical power distribution
subsystems to OPERABLE
status. 7 days AND 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> from discovery of failure
to meet LCO E. Required Action and associated Completion Time
of Condition A, B, C, or D
not met. E.1 -------------NOTE--------------
LCO 3.0.4.a is not
applicable when entering
MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Two or more electrical power distribution
subsystems inoperable that
result in a loss of function. F.1 Enter LCO 3.0.3. Immediately
Completion Times 1.3 Brunswick Unit 2 1.3-3 Amendment No. 309 1.3 Completion Times DESCRIPTION The above Completion Time extension does not apply to those (continued) Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the
Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ." Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions. EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met. B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
(continued)
AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-5 Amendment No. 310 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.5 Restore DG to OPERABLE status. ---------NOTE----------
Until DG 4 is
returned to
OPERABLE status, not to exceed 0745
EST on December 13, 2017, the 14 day and
17 day Completion
Times are extended
to 30 days and
33 days, respectively.
7 days from discovery of
unavailability of
SUPP-DG AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of
Condition D entry 6 days concurrent with unavailability of SUPP-DG AND 14 days AND 17 days from discovery of failure
to meet LCO 3.8.1.a
or b (continued)
AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-7 Amendment No. 310 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.2 ----------------------------NOTES---------------------------------- 1. All DG starts may be preceded by an engine prelube period. 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used
for this SR. When modified start procedures are
not used, the time, voltage, and frequency
tolerances of SR 3.8.1.7 must be met. 3. A single test at the specified Frequency will satisfy this Surveillance for both units. 4. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.2 for EDGs 1, 2, and 3
may be suspended. Past due surveillances will
be completed within 7 days of restoration of
EDG 4 operability or December 20, 2017, whichever occurs first.
Verify each DG starts from standby conditions and achieves steady state voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance
Frequency Control
Program (continued)
AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-8 Amendment No. 310 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 ----------------------------NOTES---------------------------------- 1. DG loadings may include gradual loading. 2. Momentary transients outside the load range do not invalidate this test. 3. This Surveillance shall be conducted on only one DG at a time. 4. This SR shall be preceded by and immediately follow, without shutdown, a successful
performance of SR 3.8.1.2 or SR 3.8.1.7. 5. A single test at the specified Frequency will satisfy this Surveillance for both units. 6. Until DG 4 is returned to OPERABLE status, not to exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.3 for EDGs 1, 2, and 3
may be suspended. Past due surveillances will
be completed within 7 days of restoration of
EDG 4 operability or December 20, 2017, whichever occurs first.
Verify each DG is synchronized and loaded and operates for 60 minutes at a load 2800 kW and 3500 kW.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.4 Verify each engine mounted tank contains 150 gal of fuel oil.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.5 Check for and remove accumulated water from each engine mounted tank.
In accordance with the Surveillance
Frequency Control
Program (continued)
AC Sources-Operating 3.8.1 Brunswick Unit 2 3.8-9 Amendment No. 310 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.6 -------------------------------NOTE-------------------------------
Until DG 4 is returned to OPERABLE status, not to
exceed 0745 EST on December 13, 2017, performance of SR 3.8.1.6 for EDGs 1, 2, and 3 may
be suspended. Past due surveillances will be
completed within 7 days of restoration of EDG 4
operability or December 20, 2017, whichever occurs
first.
Verify the fuel oil transfer system operates to transfer fuel oil from the day fuel oil storage tank to the engine
mounted tank.
In accordance with the Surveillance
Frequency Control
Program SR 3.8.1.7 ----------------------------NOTES---------------------------------- 1. All DG starts may be preceded by an engine prelube period. 2. A single test at the specified Frequency will satisfy this Surveillance for both units.
Verify each DG starts from standby condition and achieves, in 10 seconds, voltage 3750 V and frequency 58.8 Hz, and after steady state conditions are reached, maintains voltage 3750 V and 4300 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance
Frequency Control
Program (continued)
Distribution Systems-Operating 3.8.7 Brunswick Unit 2 3.8-36 Amendment No. 308 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DC electrical power distribution
subsystems inoperable for
reasons other than
Condition C. D.1 Restore DC electrical power distribution
subsystems to OPERABLE
status. 7 days AND 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> from discovery of failure
to meet LCO E. Required Action and associated Completion Time
of Condition A, B, C, or D
not met. E.1 -------------NOTE--------------
LCO 3.0.4.a is not
applicable when entering
MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Two or more electrical power distribution
subsystems inoperable that
result in a loss of function. F.1 Enter LCO 3.0.3. Immediately
Distribution Systems-Operating B 3.8.7 Brunswick Unit 1 B 3.8.7-13 Revision No. 97 BASES ACTIONS D.1 (continued) distribution system. At this time, an AC bus could again become inoperable, and the DC electrical power distribution system could be
restored OPERABLE. This could continue indefinitely.
This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in
establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition D was entered. The 176 hour0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> Completion
Time is an acceptable limitation on this potential of failing to meet the
LCO indefinitely.
E.1 If the inoperable electrical power distribution subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which overall plant risk is
minimized. To achieve this status, the plant must be brought to at least
MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and
because the time spent in MODE 3 to perform the necessary repairs to
restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable
low-risk state.
Required Action E.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of
LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.
However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment
addressing inoperable systems and components, consideration of the
results, determination of the acceptability of entering MODE 3, and
establishment of risk management actions, if appropriate. LCO 3.0.4 is
not applicable to, and the Note does not preclude, changes in MODES or
other specified conditions in the Applicability that are required to comply
with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power
conditions in an orderly manner and without challenging plant systems.
F.1 Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost.
(continued)