BSEP 02-0159, Application for Technical Specification Change Regarding Elimination of Post Accident Sampling System Requirements

Application for Technical Specification Change Regarding Elimination of Post Accident Sampling System Requirements

ML023250357
Person / Time
Site:	Brunswick
Issue date:	11/13/2002
From:	Keenan J Carolina Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 02-0159, TSC-2002-05
Download: ML023250357 (11)

Text

C0r" CP&L AProgress Energy Company 10 CFR 50.90 NOV 1 3 2002 SERIAL: BSEP 02-0159 TSC-2002-05 PSýNuclear Regulatory Commission

• ,,ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING ELIMINATION OF POST ACCIDENT SAMPLING SYSTEM REQUIREMENTS Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Carolina Power & Light (CP&L)

Company is submitting a request for amendments to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendments eliminate the TS requirements for Post Accident Sampling capability in TS Section 5.5.3. The changes are consistent with NRC approvedTechnical Specification Task Force (TSTF) change TSTF-413, as modified by Federal Register Notice 66 FR 66949, of December 27, 2001, and in response to public comments. The availability of this TS improvement was published in the FederalRegister on March 20, 2002, as part of the Consolidated Line Item Improvement Process (CLIIP).

CP&L has evaluated the proposed changes in accordance with 10 CFR 50.91(a)(1), using the criteria in 10 CFR 50.92(c), and determined that these changes involve no significant hazards considerations.

CP&L requests approval of the proposed license amendments by March 31, 2003, with the amendments being fully implemented within 180 days after approval.

In accordance with 10 CFR 50.91(b)(1), a copy of this application is being provided to the State of North Carolina.

Brunswick Nuclear Plant PO Box 10429 Southport, NC 28451

Document Control Desk BSEP 02-0159 / Page 2' ' * -%

Please refer any questions regarding this submittal to Mr. Edward T. O'Neil, Manager - Regulatory Affairs, at (910) 457-3512.

Sincerely, KMvHkmh

Enclosures:

1. Description and Assessment

2. Marked-Up Technical Specification Changes for Unit 1

3. Marked-Up Technical Specification Changes for Unit 2

4. Revised Technical Specification Pages for Unit 1

5. Revised Technical Specification Pages for Unit 2

6. Regulatory Commitments John S. Keenan, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power & Light Company.

Notary (Seal) -. i N

My commission expires: 0-L, V;-o-Z,01-

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Document Control Desk BSEP 02-0159 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Theodore A. Easlick, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Leonard N. Olshan (Mail Stop OWFN 8H12) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATIN: Allen G. Howe (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-05 10 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 02-0159

,,**-I, Enclosure 1 Page 1 of 3 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendments revise the Technical Specification (TS) Section 5.5.3 to eliminate the requirements for having a Post Accident Sampling Sy stem (PASS).

The changes are consistent with NRC approved Technical Specification Task Force (TSTF) change TSTF-413, as modified by Federal Register Notice 66 FR 66949, of December 27, 2001, and in response to public comments. The availability of this TS improvement was published in the FederalRegister on March 20, 2002, as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation The results of the Boiling Water Reactor Owners' Group (BWROG) Topical Report, NEDO-32991-A, "Regulatory Relaxation for BWR Post-Accident Sampling Stations (PASS),"

dated August 2001, confirmed that the BWRPASS does not provide the benefits expected by the NRC when the requirements were promulgated following the Three Mile Island Unit 2 accident.

BWR emergency and severe accident response strategies can be implemented using in-plant instrumentation, without reliance on the PASS. Moreover, operating experience has demonstrated that in-plant instrumentation and the associated analysis methods will provide the timely information required to assess core damage and mitigate severe accidents. This information is available from in-plant instrumentation early in the accident scenario and the derived information is as good as or better than the information currently provided by the PASS several hours after initiation of the event. The BWROG has, therefore, concluded that thePASS can be removed without significantly affecting plant safety and recommended that all PASS regulatory requirements be eliminated.

Carolina Power & Light (CP&L) Company has reviewed the safety evaluation published on December 27, 2001, as part of the CLIUP. This included a review of the NRC's evaluation, as well as the information provided to support TSTF-413. CP&L has concluded that the justifications presented in the TSTF proposal and the NRC's safety evaluation are applicable to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, and justify these changes for implementation in the BSEP TSs.

BSEP 02-0159

, .Enclosure I Page 2 of 3 2.2 Optional Changes and Variations CP&L is proposing deviations from the TS changes described in TSTF-413. The TSTF "Affected Technical Specifications" includes a mark-up of Bases 3.3.3.1.D for Post Accident Monitoring Instrumentation. Based on the existing wording of the BSEP Units 1 and 2 TS Bases 3.3.3.1.D for Post Accident Monitoring Instrumentation, this bases change is not required for BSEP.

There is no other variation nor deviation from the NRC Model Safety Evaluation dated December 27, 2001.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration CP&L has reviewed the proposed no significant hazards consideration (NSHC) published in the FederalRegister on December 27, 2001, and has concluded that the proposed NSHC is applicable to BSEP, Units 1 and 2, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on December 27, 2001, for this TS improvement, plant-specific verifications were performed as follows:

1. BSEP will develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, suppression pool, and containment atmosphere. The contingency plans will be contained in applicable radiation control procedures and implementation will be completed within 180 days after the issuance of the license amendment. Establishment and maintenance of the contingency plans are considered to be a regulatory commitment.

2. BSEP will establish the capability of classifying fuel damage events at the Alert level threshold at radioactivity levels of 300 ItCi/ml dose equivalent iodine. This capability will utilize the normal sampling system and/or correlations of radiation readings to radioisotope concentrations in the reactor coolant. The method will be described in applicable emergency preparedness procedures and implementation will be completed within 180 days after the issuance of the license amendment. The capability for classifying fuel damage events is considered to be a regulatory commitment.

3. BSEP has established an 1-131 site survey detection capability including the ability to assess radioactive iodines released to offsite environs, by using effluent monitoring systems or portable sampling equipment. This capability is currently described in applicable radiation control procedures and will be maintained as a regulatory

BSEP 02-0159 Enclosure I Page 3 of 3 commitment within the plant procedures. Annotation of this commitment in applicable procedures will be completed within 180 days after the issuance of the license amendment.

4.0 Environmental Evaluation CP&L has reviewed the environmental evaluation included in the model safety evaluation published December 27, 2001, as part of the CLIIP and concluded that the NRC's findings are applicable to BSEP, Units I and 2. The evaluation is hereby incorporated by reference for this application.

BSEP 02-0159 Enclosure 2 MARKED-UP TECHNICAL SPECIFICATION CHANGES FOR UNIT 1

BSEP 02-0159 Enclosure 3 MARKED-UP TECHNICAL SPECIFICATION CHANGES FOR UNIT 2

BSEP 02-0159 Enclosure 4 REVISED TECHNICAL SPECIFICATION PAGES FOR UNIT 1

BSEP 02-0159 Enclosure 5 REVISED TECHNICAL SPECIFICATION PAGES FOR UNIT 2

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BSEP 02-0159 t÷i*

Enclosure 6

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Page 1 of I REGULATORY COMMITMENTS The table below lists actions committed to by Carolina Power & Light (CP&L) Company in this document. Any other actions discussed in this submittal represent intended or planned actions by CP&L. They are described for the NRC's information and are not regulatory commitments.

Please notify the Manager - Regulatory Affairs at the Brunswick Steam Electric Plant (BSEP) of any questions regarding this document or any associated regulatory commitments.

REGULATORY COMMITMENT DUE DATE/EVENT

1. BSEP will develop contingency plans for obtaining and analyzing To be implemented within highly radioactive samples of reactor coolant, suppression pool, and 180 days of issuance of containment atmosphere. The contingency plans will be contained in the amendments applicable radiation control procedures and implementation will be completed within 180 days after the issuance of the license amendments. Establishment and maintenance of the contingency plans are considered to be a regulatory commitment.

2. BSEP will establish the capability of classifying fuel damage events at To be implemented within the Alert level threshold at radioactivity levels of 300 [iCi/ml dose 180 days of issuance of equivalent iodine. This capability may utilize the normal sampling the amendments system and/or correlations of radiation readings to radioisotope concentrations in the reactor coolant. The method will be described in applicable emergency preparedness procedures and implementation will be completed within 180 days after the issuance of the license amendments. The capability for classifying fuel damage events is considered to be a regulatory commitment.

3. BSEP has established an 1-131 site survey detection capability To be implemented within including the ability to assess radioactive iodines released to offsite 180 days of issuance of environs, by using effluent monitoring systems or portable sampling the amendments equipment. This capability is currently described in applicable radiation control procedures and will be maintained as a regulatory commitment within the plant procedures. Annotation of this commitment in applicable procedures will be completed within 180 days after the issuance of the license amendments.