Letter Sequence Response to RAI |
---|
|
|
|
|
---|
Category:Letter type:BSEP
MONTHYEARBSEP 19-0012, Submittal of 2018 Sea Turtle Annual Report2019-01-17017 January 2019 Submittal of 2018 Sea Turtle Annual Report BSEP 18-0052, Annual Radiological Environmental Operating Report - 20172018-05-10010 May 2018 Annual Radiological Environmental Operating Report - 2017 BSEP 18-0051, Annual Radioactive Effluent Release Report - 20172018-04-26026 April 2018 Annual Radioactive Effluent Release Report - 2017 BSEP 18-0045, Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time2018-04-25025 April 2018 Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time BSEP 18-0054, Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential.2018-04-24024 April 2018 Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential. BSEP 18-0048, Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations2018-04-11011 April 2018 Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations BSEP 18-0044, Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D2018-04-11011 April 2018 Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D BSEP 18-0046, Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2018-04-10010 April 2018 Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0047, Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test2018-04-0505 April 2018 Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test BSEP 18-0041, Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report2018-04-0404 April 2018 Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report BSEP 18-0043, Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D2018-03-31031 March 2018 Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D BSEP 18-0035, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-29029 March 2018 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0042, Cycle 22 Core Operating Limits Report (COLR)2018-03-27027 March 2018 Cycle 22 Core Operating Limits Report (COLR) BSEP 18-0040, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test2018-03-23023 March 2018 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test BSEP 18-0039, Proposed In-Service Inspection Alternative for Application of Dissimilar Metal Weld Full Structural Overlay - Nozzles N4A and N4D2018-03-19019 March 2018 Proposed In-Service Inspection Alternative for Application of Dissimilar Metal Weld Full Structural Overlay - Nozzles N4A and N4D BSEP 18-0034, Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-16016 March 2018 Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0032, Additional Testing Information Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-14014 March 2018 Additional Testing Information Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0026, Additional Information Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination2018-03-0707 March 2018 Additional Information Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination BSEP 18-0014, Fifth 10-Year Inservice Testing Program Plan2018-02-19019 February 2018 Fifth 10-Year Inservice Testing Program Plan BSEP 18-0021, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865). Without Proprietary Enclosure2018-02-0505 February 2018 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865). Without Proprietary Enclosure BSEP 18-0017, Revision to Radiological Emergency Response Plan and Implementing Procedure2018-01-30030 January 2018 Revision to Radiological Emergency Response Plan and Implementing Procedure BSEP 18-0015, Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations2018-01-23023 January 2018 Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations BSEP 18-0013, Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-01-23023 January 2018 Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control BSEP 18-0001, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2018-01-23023 January 2018 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements BSEP 18-0012, Application to Revise Technical Specifications to Adopt TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.32018-01-23023 January 2018 Application to Revise Technical Specifications to Adopt TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.3 BSEP 18-0009, 2017 Sea Turtle Annual Report2018-01-15015 January 2018 2017 Sea Turtle Annual Report BSEP 17-0098, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2018-01-10010 January 2018 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors BSEP 17-0119, Snubber Program Plan for Fifth 10-Year Interval Inservice Testing Program2018-01-10010 January 2018 Snubber Program Plan for Fifth 10-Year Interval Inservice Testing Program BSEP 17-0115, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-01-0404 January 2018 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control BSEP 17-0110, Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions2017-12-20020 December 2017 Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions BSEP 17-0121, Post-Examination Documentation and Comments for Operator Retake Initial Examination2017-12-14014 December 2017 Post-Examination Documentation and Comments for Operator Retake Initial Examination BSEP 17-0120, Withdrawal of Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension..2017-12-12012 December 2017 Withdrawal of Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension.. BSEP 17-0118, Supplement to Response to Request for Additional Information Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel..2017-12-0707 December 2017 Supplement to Response to Request for Additional Information Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel.. BSEP 17-0117, Response to Request for Additional Information (Probabilistic Risk Assessment and Human Performance Branches) Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1 AC Sources..2017-12-0606 December 2017 Response to Request for Additional Information (Probabilistic Risk Assessment and Human Performance Branches) Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1 AC Sources.. BSEP 17-0116, Response to Request for Additional Information Regarding Request for Risk- Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of ..2017-12-0404 December 2017 Response to Request for Additional Information Regarding Request for Risk- Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of .. BSEP 17-0104, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination2017-11-29029 November 2017 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination BSEP 17-0111, Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements2017-11-28028 November 2017 Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements BSEP 17-0109, Response to Request for Additional Information Regarding Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times And.2017-11-24024 November 2017 Response to Request for Additional Information Regarding Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times And. BSEP 17-0108, Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements2017-11-22022 November 2017 Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements BSEP 17-0017, Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material2017-11-15015 November 2017 Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material BSEP 17-0100, Fifth 10-Year Inservice Testing Interval2017-11-0202 November 2017 Fifth 10-Year Inservice Testing Interval BSEP 17-0089, Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0093, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0078, Request for License Amendment - DC Sources - Operating Surveillance Requirement (SR) 3.8.4.52017-10-0303 October 2017 Request for License Amendment - DC Sources - Operating Surveillance Requirement (SR) 3.8.4.5 BSEP 17-0076, Registration for Use of General License Spent Fuel Casks2017-09-0606 September 2017 Registration for Use of General License Spent Fuel Casks BSEP 17-0081, Revision to Radiological Emergency Response Plan Implementing Procedures2017-09-0505 September 2017 Revision to Radiological Emergency Response Plan Implementing Procedures BSEP 17-0039, Submittal of Response to Inspection Report 05000324/2015404 and 05000325/2015404, Dated March 30, 2015, Inspection of Interim Cyber Security Milestones 1-7 and Target Set Requirements2017-08-15015 August 2017 Submittal of Response to Inspection Report 05000324/2015404 and 05000325/2015404, Dated March 30, 2015, Inspection of Interim Cyber Security Milestones 1-7 and Target Set Requirements BSEP 17-0071, ISFSI - Registration for Use of General License Spent Fuel Casks2017-08-15015 August 2017 ISFSI - Registration for Use of General License Spent Fuel Casks BSEP 17-0064, Application of Dissimilar Metal Weld Full Structural Overlay on Reactor Pressure Vessel Nozzle N92017-07-10010 July 2017 Application of Dissimilar Metal Weld Full Structural Overlay on Reactor Pressure Vessel Nozzle N9 BSEP 17-0060, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.2017-06-29029 June 2017 Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control. 2019-01-17
[Table view] |
Text
L .11:
Progress Energy James Scarola Vice President Brunswick Nuclear Plant Progress Energy Carolinas. Inc.
November 16, 2005 SERIAL: BSEP 05-0138 TSC-2005-05 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Response to Request for Additional Information Revised Main Steam Isolation Valve Leakage Limit (NRC TAC Nos. MC8106 and MC8107)
References:
Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: BSEP 05-0102), "Request for License Amendment - Revised Main Steam Isolation Valve Leakage Limit," dated August 11, 2005 (ML052310224)
Ladies and Gentlemen:
On August 11, 2005, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc., requested a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The proposed change revises Surveillance Requirement 3.6.1.3.9 with respect to the allowed leakage rate through each Main Steam Isolation Valve (MSIV). To support the MSIV leakage rate change, additional automatic initiation functions for the Control Room Emergency Ventilation (CREV) system were also included in TS 3.3.7.1, "Control Room Emergency Ventilation (CREV) System Instrumentation."
On October 28, 2005, the NRC provided an electronic request for additional information (RAI) concerning the calculation of control room doses associated with the proposed change to the MSIV leakage rate. The response to this RAI is enclosed.
No regulatory commitments are contained in this letter. Please refer any questions regarding this submittal to Mr. Edward T. ONeil, Manager - Support Services, at (910) 457-3512.
P.O.Box 10429 Southport, NC 28461 T> 910.457.3698 PC1-C F> 910.457.2803
Document Control Desk BSEP 05-0138 / Page 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 16, 2005.
Sincerely, James Scarola MAT/mat
Enclosure:
Response to Request for Additional Information
Document Control Desk BSEP 05-0138 / Page 3 cc:
U. S. Nuclear Regulatory Commission, Region II ATTN: 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 ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)
ATTN: Ms. Brenda L. Mozafari (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 27626-0510 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
In BSEP 05-0138 Enclosure Page 1 of 3 Response to Request for Additional Information
Background
On August 11, 2005, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc., requested a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The proposed change revises Surveillance Requirement 3.6.1.3.9 with respect to the allowed leakage rate through each Main Steam Isolation Valve (MSIV). To support the MSIV leakage rate change, additional automatic initiation functions for the Control Room Emergency Ventilation (CREV) system were also included in TS 3.3.7.1, "Control Room Emergency Ventilation (CREV) System Instrumentation."
On October 28, 2005, the NRC provided an electronic request for additional information (RAI) concerning the calculation of control room doses associated with the proposed change to the MSIV leakage rate. The response to this RAI follows.
NRC Question 1 The Licensee states in Section 4 of enclosure 1 that concerning the calculation of direct dose to the control room, "This arrangement of dose analysis locations differs from the previous analysis in that the locations chosen represent actual crew work locations, whereas the previous analysis was based on evaluating the highest dose point in the control building." The Licensee also states that, "There are no control functions or activities that take place in the area previously analyzed for the control room occupancy 30-day dose. The space is not essential to control room functioning in either normal or emergency mode."
Using the assumptions outlined in the proposed change what is the control room occupancy 30-day dose for the highest dose point in the control building?
Response to NRC Question 1 Using the assumptions outlined in the proposed change, the control room occupancy 30-day dose for the highest dose point in the control building is 4.722 Rem TEDE.
The following table provides a summary of the various dose contributions to the 30-day control room dose. For comparison purposes, it also provides the results from the calculation supporting the MSIV leakage change and the original Alternative Source Term calculation. The only dose contribution that varies between the "highest dose location" case and the case provided in support of the MSIV leakage submittal is the Emergency Core Cooling System (ECCS) piping shine. This dose is from a core spray discharge line located to the west of the control room.
Assuming operators at the "worst case location" increases this dose. However, the dose received from other sources to the control room staff were not reduced due to the assumed receiver location near the exterior wall at either the northwest or southwest comer of the control room.
Thus, for example, the dose received from the source buildup on the CREV filter is assumed to
BSEP 05-0138 Enclosure Page 2 of 3 be the same, although it is in fact dependent on position. The "highest dose location" actually refers only to the dose received from the core spray shine, whereas the underlying assumption for CREV filter dose has always been an individual standing directly beneath (i.e., physically closest to) the filter. This conservative method of dose summation is consistent with previous practice.
Control Room Dose Comparisons (Rem TEDE)
MSIV Leakage Original Alternative
-Dose Contribution H Dos Increase Source Term :
Loain- Calculation Calculation Primary Leakage - Reactor Building 0.6321 0.6321 0.22 Primary Leakage - Stack 0.1128 0.1128 Engineered Safety Feature Leakage - 0.4940 0.4940 0.25 Reactor Building Engineered Safety Feature Leakage - Stack 0.0797 0.0797 ----
MSIV/Secondary Containment Leakage 2.9402 2.9402 1.64 External Cloud 0.0057 0.0057 0.01 Reactor Building Direct Shine 0.0572 0.0572 0.36 Standby Gas Treatment System Filter Negligible Negligible 0.18 Direct Shine _ _ _ _ _ _ _ _ _ _
CREV Filter Direct Shine 0.0676 0.0676 0.64 ECCS Piping Shine 0.333 0.0001 0.10' Totals 4.7223 4.3894 3.40 Regulatory Limit 5 5 5 The result shows that the total 30-day dose of 4.39 Rem TEDE, calculated in support of the MSIV leakage increase, is comparable to the dose as calculated for the "highest dose location" in the control room. Additionally, assuming previous worst case locations, the control room dose remains below the regulatory limit of 5 Rem TEDE.
NRC Ouestion 2 The evaluation of direct shine dose in the control room appears to take credit for limitations on the time that operations personnel can occupy certain locations within the control room. The submittal states that, "BSEP's current emergency plans post a health physics technician in the control room to monitor exposure rates."
' This value differs from that for the highest dose location due to an error identified in the original dose calculation.
The original dose calculation value of 0.10 Rem is based on a mistaken assumption of a 6-inch diameter pipe line, whereas the recalculated value of 0.333 Rem is correctly based on a 12-inch diameter pipe line.
BSEP 05-0138 Enclosure Page 3 of 3 A. Is this health physics position in the control room an emergency plan required minimum staff position?
B. Does the health physics technician have other duties in addition to monitoring personnel exposure within the control room?
C. Are there plans to incorporate any warning signs or physical barriers to limit stay times in the specified higher dose areas within the control room?
Response to NRC Ouestion 2 Item A No, a health physics (HP) technician is not proposed or currently a part of the required control room staff complement. This position is fulfilled by the radiological team assigned to respond to site radiological events in accordance with the BSEP emergency response program.
Item B Yes, as a part of the radiological team, a technician who performs the control room surveys/exposure monitoring may also be assigned to assist radiological conditions assessment for a particular in-plant mission. Nevertheless, the radiological team performs periodic control room habitability surveys, approximately hourly.
Item C Yes, closeout activities associated with this project include placing placards in the northwest and southwest corners of the control room to identify the potential elevated dose rates in these areas in the event of a corresponding unit LOCA. An action item has been established in the plant Corrective Action Program to ensure this activity is completed. However, as stated in response to Question 1, even assuming previous worst case locations, the control room dose remains below the regulatory limit of 5 Rem TEDE.