BSEP 04-0134, Submittal of Technical Specification Bases Changes

Submittal of Technical Specification Bases Changes

ML042670390
Person / Time
Site:	Brunswick
Issue date:	09/16/2004
From:	O'Neil E Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 04-0134
Download: ML042670390 (14)

Text

a Progress Energy SEP 1 6 2004 SERIAL: BSEP 04-0134 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Brunswick Steam Electric Plant, Unit Nos. I and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Submittal of Technical Specification Bases Changes Ladies and Gentlemen:

In accordance with Technical Specification (TS) 5.5.10 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc., is submitting Revision 37 to the BSEP, Unit 1 TS Bases and Revision 34 to the BSEP, Unit 2 TS Bases.

Please refer any questions regarding this submittal to Mr. Leonard R. Beller, Supervisor -

Licensing/Regulatory Programs, at (910) 457-2073.

Sincerely, Edward T. ONeil Manager - Support Services Brunswick Steam Electric Plant SFT/sft

Enclosures:

1. Summary of Revisions to Technical Specification Bases

2. Page Replacement Instructions

3. Unit 1 Technical Specification Bases Replacement Pages

4. Unit 2 Technical Specification Bases Replacement Pages Progress Energy Carolinas, Inc.

Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461

Document Control Desk Jq BSEP 04-0134 / Page 2 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATIN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATMN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Comn'issivn (Y'iectrenic Copy Only)

ATTN: Ms. Brenda L. Mozafari (Mail Stop OWF1NT 8G9) 11555 Rockville Pike Rockville, MID 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 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

tch. BSEP 04-0134 Enclosure 1

-Summary of Revisions to Technical Specification Bases Revision ffeted Date Implemented Unit -Tiefscito 371 1 July 15, 2004

Title:

Scram Discharge Volume Vent And 341 2 Drain Valves (TSC-2003-08)

Description:

This change to TS Bases 3.1.8 revises the actions associated with inoperability of SDV vent or drain valve/s in one or more SDV vent drain lines consistent with Technical Specifications Task Force (TSTF) change traveler TSTF-404, Revision 0.

XNote: Revision 37 for Unit 1 and Revision 34 for Unit 2 incorporated Bases change package TSC-2003-08.

kI. BSEP 04-0134 Enclosure 2 Page Replacement Instructions Remove Insert Unit I- Bases Book I Title Page, Revision 36 Title Page, Revision 37 LOEP-1, Revision 36 LOEP-1, Revision 37 B 3.1.8-2, Revision 31 B 3.1.8-2, Revision 37 B 3.1.8-3, Revision 31 B 3.1.8-3, Revision 37 Unit 2- -Bases Book 1 -

Title Page, Revision 33 Title Page, Revision 34 LOEP-1, Revision 33 LOEP-1, Revision 34 B 3.1.8-2, Revision 30 B 3.1.8-2, Revision 34 B 3.1.8-3, Revision 30 B 3.1.8-3, Revision 34

BSEP 04-0134 Enclosure 3 Unit 1 Technical Specification Bases Replacement Pages

BASES TO THE FACILITY OPERATING LICENSE DPR-71 TECHNICAL SPECIFICATIONS FOR BRUNSWICK STEAM ELECTRIC PLANT UNIT 1 CAROLINA POWER & LIGHT COMPANY REVISION 37

LIST OF EFFECTIVE PAGES - BASES Page No. Revision No. Page No. Revision No.

Title Page 37 B 3.1.2-1 31 I B 3.1.2-2 31 List of Effective Pages - Book 1 B 3.1.2-3 31 B 3.1.2-4 31 LOEP-1 37 B 3.1.2-5 31 LOEP-2 36 B 3.1.3-1 31 I LOEP-3 36 B 3.1.3-2 31 LOEP-4 36 B 3.1.3-3 31 B 3.1.3-4 31 i 31 B 3.1.3-5 31 ii 31 B 3.1.3-6 31 B 3.1.3-7 31 B 2.1.1-1 31 B 3.1.3-8 31 B 2.1.1-2 31 B 3.1.3-9 31 B 2.1.1-3 31 B 3.1.4-1 31 B 2.1.1-4 31 B 3.1.4-2 31 B 2.1.1-5 31 B 3.1.4-3 31 B 2.1.2-1 31 B 3.1.4-4 31 B 2.1.2-2 31 B 3.1.4-5 31 B 2.1.2-3 31 B 3.1.4-6 31 B 3.1.4-7 31 B 3.0-1 31 B 3.1.5-1 31 B 3.0-2 31 B 3.1.5-2 31 B 3.0-3 31 B 3.1.5-3 31 B 3.0-4 31 B 3.1.5-4 31 B 3.0-5 31 B 3.1.5-5 31 B 3.0-6 31 B 3.1.6-1 31 B 3.0-7 31 B 3.1.6-2 31 B 3.0-8 31 B 3.1.6-3 31 B 3.0-9 31 B 3.1.6-4 31 B 3.0-10 31 B 3.1.6-5 31 B 3.0-11 31 B 3.1.7-1 34 B 3.0-12 31 B 3.1.7-2 31 B 3.0-13 31 B 3.1.7-3 31 B 3.0-14 31 B 3.1.7-4 31 B 3.0-15 31 B 3.1.7-5 31 B 3.0-16 31 B 3.1.7-6 34 B 3.1.8-1 31 B 3.1.1-1 31 B 3.1.8-2 37 B 3.1.1-2 B 3.1.1-3 31 31 B 3.1.8-3 B 3.1.8-4 37 31 I

B 3.1.1-4 31 B 3.1.8-5 31 B 3.1.1-5 31 B 3.1.1-6 31 (continued)

Brunswick Unit 1 LOEP-1 Revision 37 l

SDV Vent and Drain Valves B 3.1.8

.i. ,

BASES APPLICABLE capacity to contain the reactor coolant discharge during a full core scram.

SAFETY ANALYSES To automatically ensure this capacity, a reactor scram (LCO 3.3.1.1, (continued) "Reactor Protection System (RPS) Instrumentation") is initiated if the SDV water level in the instrument volume exceeds a specified setpoint. The setpoint is chosen so that all control rods are inserted before the SDV has insufficient volume to accept a full scram.

SDV vent and drain valves satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii)

(Ref. 3).

LCO The OPERABILITY of all SDV vent and drain valves ensures that the SDV vent and drain valves will close during a scram to contain reactor water discharged to the SDV piping. Since the vent and drain lines are provided with two valves in series, the single failure of one valve in the open position will not impair the isolation function of the system. Additionally, the valves are required to open on scram reset to ensure that a path is available for the SDV piping to drain freely at other times.

APPLICABILITY In MODES 1 and 2, scram may be required; therefore, the SDV vent and drain valves must be OPERABLE. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in the shutdown position and a control rod block is applied. This provides adequate controls to ensure that control rods cannot be withdrawn. Also, during MODE 5, only a single control rod can be withdrawn from a core cell containing fuel assemblies. Therefore, the SDV vent and drain valves are not required to be OPERABLE in these MODES since the reactor is subcritical and no more than one rod may be withdrawn and subject to scram.

ACTIONS The ACTIONS Table is modified by Notes indicating that a separate I Condition entry is allowed for each SDV vent and drain line. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable SDV line.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable SDV lines are governed by subsequent Condition entry and application of associated Required Actions.

When a line is isolated, the potential for an inadvertent scram due to high SDV level is increased. During these periods, the line may be unisolated under administrative control. This allows any accumulated water in the line to be drained, to preclude a reactor scram on SDV high level. This is acceptable since the administrative controls ensure the valve can be closed quickly, by a dedicated operator, if a scram occurs with the valve open.

(continued)

Brunswick Unit 1 B 3.1.8-2 Revision No. 37 l

SDV Vent and Drain Valves B 3.1.8 BASES ACTIONS A.1 (continued)

When one SDV vent or drain valve is inoperable in one or more lines, the associated line must be isolated to contain the reactor coolant during a scram. The 7 day Completion Time is reasonable, given the redundant capability afforded by the remaining valves in the affected lines and the low probability of a scram occurring while the valve(s) are inoperable and the line is not isolated. The SDV is still isolable since the redundant valve in the affected line is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

B.1 If both valves in a line are inoperable, the line must be isolated to contain the reactor coolant during a scram. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time to isolate the line is based on the low probability of a scram occurring while the line is not isolated and unlikelihood of significant CRD seal and scram exhaust valve leakage.

C.1 If any Required Action and associated Completion Time is not 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit I B 3.1 .8-3 Revision No. 37 l

BSEP 04-0134 Enclosure 4 Unit 2 Technical Specification Bases Replacement Pages

BASES TO THE FACILITY OPERATING LICENSE DPR-62 TECHNICAL SPECIFICATIONS FOR BRUNSWICK STEAM ELECTRIC PLANT UNIT 2 CAROLINA POWER & LIGHT COMPANY REVISION 34

LIST OF EFFECTIVE PAGES - BASES Page No. Revision No. Page No. Revision No.

Title Page 34 B 3.1.2-1 30 I B 3.1.2-2 30 List of Effective Pages - Book 1 B 3.1.2-3 30 B 3.1.2-4 30 LOEP-1 34 B 3.1.2-5 30 I LOEP-2 33 B 3.1.3-1 30 LOEP-3 33 B 3.1.3-2 30 LOEP-4 33 B 3.1.3-3 30 B 3.1.3-4 30 i 30 B 3.1.3-5 30 30 B 3.1.3-6 30 B 3.1.3-7 30 B 2.1.1-1 30 B 3.1.3-8 30 B 2.1.1-2 30 B 3.1.3-9 30 B 2.1.1-3 30 B 3.1.4-1 30 B 2.1.1-4 30 B 3.1.4-2 30 B 2.1.1-5 30 B 3.1.4-3 30 B 2.1.2-1 30 B 3.1.4-4 30 B 2.1.2-2 30 B 3.1.4-5 30 B 2.1.2-3 30 B 3.1.4-6 30 B 3.1.4-7 30 B 3.0-1 30 B 3.1.5-1 30 B 3.0-2 30 B 3.1.5-2 30 B 3.0-3 30 B 3.1.5-3 30 B 3.0-4 30 B 3.1.5-4 30 B 3.0-5 30 B 3.1.5-5 30 B 3.0-6 30 B 3.1.6-1 30 B 3.0-7 30 B 3.1.6-2 30 B 3.0-8 30 B 3.1.6-3 30 B 3.0-9 30 B 3.1.6-4 30 B 3.0-10 30 B 3.1.6-5 30 B 3.0-11 30 B 3.1.7-1 30 B 3.0-12 30 B 3.1.7-2 30 B 3.0-13 30 B 3.1.7-3 30 B 3.0-14 30 B 3.1.7-4 30 B 3.0-15 30 B 3.1.7-5 30 B 3.0-16 30 B 3.1.7-6 30 B 3.1.8-1 30 B 3.1.1-1 30 B 3.1.8-2 34 B 3.1.1-2 B 3.1.1-3 30 30 B 3.1.8-3 B 3.1.8-4 34 30 I

B 3.1.1-4 30 B 3.1.8-5 30 B 3.1.1-5 30 B 3.1.1-6 30 (continued)

Brunswick Unit 2 LOEP-1 Revision 34 l

Is SDV Vent and Drain Valves B 3.1.8 BASES APPLICABLE capacity to contain the reactor coolant discharge during a full core scram.

SAFETY ANALYSES To automatically ensure this capacity, a reactor scram (LCO 3.3.1.1, (continued) "Reactor Protection System (RPS) Instrumentation") is initiated if the SDV water level in the instrument volume exceeds a specified setpoint. The setpoint is chbsen so that all control rods are inserted before the SDV has insufficient volume to accept a full scram.

SDV vent and drain valves satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii)

(Ref. 3).

LCO The OPERABILITY of all SDV vent and drain valves ensures that the SDV vent and drain valves will close during a scram to contain reactor water discharged to the SDV piping. Since the vent and drain lines are provided with two valves in series, the single failure of one valve in the open position will not impair the isolation function of the system. Additionally, the valves are required to open on scram reset to ensure that a path is available for the SDV piping to drain freely at other times.

APPLICABILITY In MODES 1 and 2, scram may be required; therefore, the SDV vent and drain valves must be OPERABLE. In MODES 3 and 4, control rods are not able to be withdrawn since the reactor mode switch is in the shutdown position and a control rod block is applied. This provides adequate controls to ensure that control rods cannot be withdrawn. Also, during MODE 5, only a single control rod can be withdrawn from a core cell containing fuel assemblies. Therefore, the SDV vent and drain valves are not required to be OPERABLE in these MODES since the reactor is subcritical and no more than one rod may be withdrawn and subject to scram.

ACTIONS The ACTIONS Table is modified by Notes indicating that a separate I Condition entry is allowed for each SDV vent and drain line. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable SDV line.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable SDV lines are governed by subsequent Condition entry and application of associated Required Actions.

When a line is isolated, the potential for an inadvertent scram due to high SDV level is increased. During these periods, the line may be unisolated under administrative control. This allows any accumulated water in the line to be drained, to preclude a reactor scram on SDV high level. This is acceptable since the administrative controls ensure the valve can be closed quickly, by a dedicated operator, if a scram occurs with the valve open.

(continued)

Brunswick Unit 2 B 3.1.8-2 Revision No. 34 l

SDV Vent and Drain Valves B 3.1.8 BASES ACTIONS A.1 (continued)

When one SDV vent or drain valve is inoperable in one or more lines, the associated line must be isolated to contain the reactor coolant during a scram. The 7 day Completion Time is reasonable, given the redundant capability afforded by the remaining valves in the affected lines and the low probability of a scram occurring while the valve(s) are inoperable and the line is not isolated. The SDV is still isolable since the redundant valve in the affected line is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

Bj1 If both valves in a line are inoperable, the line must be isolated to contain the reactor coolant during a scram. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time to isolate the line is based on the low probability of a scram occurring while the line is not isolated and unlikelihood of significant CRD seal and scram exhaust valve leakage.

C.1 If any Required Action and associated Completion Time is not 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Brunswick Unit 2 B 3.1 .8-3 Revision No. 34 l