BSEP 08-0083, License Amendment Request for Adoption of TSTF-484, Revision 0 - Use of TS 3.10.1 for Scram Time Testing Activities

License Amendment Request for Adoption of TSTF-484, Revision 0 - Use of TS 3.10.1 for Scram Time Testing Activities

ML081840064
Person / Time
Site:	Brunswick
Issue date:	06/19/2008
From:	Waldrep B Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 08-0083, TSC-2008-03
Download: ML081840064 (16)

Text

~ Progress Energy &4? Benjamin C.Waidrep BVricusicentualan Brunswick Nuclear Plant Progress Energy Carolinas, Inc.

June 19, 2008 SERIAL: BSEP 08-0083 10 CFR 50.90 TSC-2008-03 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. 503 255and 50-324/License Nos. DPIR-71 and DPR-!6 2' License Amendment Request for Adoption of TSTF-484, Revision 0 - Use of TS 3.10.1 for SclramnTime Testing Activities.

Ladies and Gentlemen:

In ýaccordance with the Code of Federal Regulations, Title 10, Pgirt 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,

is requesti Ig na revision to the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and'2.'"

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212 degrees F as a consequence of inservice leak and'hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with. an-inservice leak or hydrostatic test, while considering operational conditions to be in Mode4., This change is consistent with NRC approved Revisi:on 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-4841 "Use of TfS 3.10.1 for Scram Time Testing Activities'i. The availability of the TS 3.10.11 revision was announced in the Federal Register on October 27, 2006 (71iFR 63050) as part of the consolidated line item improvement process (CLIIP).

Enclosure 1 provides an evaluation'of th&eproposed change. Enclosure 2 provides the existing Unit 1 TS pages marked-uplto show the proposed changes. Identical changes are being requested for the Unit 2 TSs. Enclosures 3 and 4 provide the proposed TS changes in final.typed 1 format forrUnits1: and,2, respectiyely. Enclosure 5 provides the existing Unit I TS Bases~pages marked-up ,t9 show the proposed changes. Identical changes are being proposedfor the Unit 2 TS Bases.

CP&L is providing, in accordance with 10 CFR 50.91(b), a copy of the proposed license amendment to the designated representative for the State of North Carolina.

CP&L requests approval of the proposed license amendment by January 16, 2009, and that once approved, the amendment shall be implemented within 60 days.

P.. Box 10429 Southport, NC 28461 T> 910.457.3698 - /

Document Control Desk BSEP 08-0083 / Page 2 There are no regulatory commitments contained in this submittal. Please refer any questions regarding this submittal to Mr. Gene Atkinson, Supervisor -

Licensing/Regulatory Programs, at (910) 457-2056.

1 declare, under penalty of perjury, that the foregoing is true and correct. Executed on June 19, 2008.

Sincerely, Benjamin C. Wa drep MAT/mat'

Enclosures:

1. Evaluation of Proposed License Amendment Request

2. Marked-up Technical Specification Pages - Unit 1

3. Typed Technical Specification Pages - Unit 1

4. Typed Technical Specification Pages - Unit 2

5. Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

Document Control Desk BSEP 08-0083 / 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. Joseph D. Austin, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 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 08-0083 Enclosure 1 Page 1 of 2 Evaluation of Proposed License Amendment Request

Subject:

License Amendment Request for Adoption of TSTF-484,.Revision 0 - Use of TS 3.10.1 For Scram Time Testing Activities 1.0 Description This letter is a request by Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., to amend the Technical Specifications (TS) of Renewed Facility Operating Licenses DPR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The proposed amendment would revise LCO 3.10.1, and the associated Bases, to expand its scope to include provisions for temperature excursions greater than 212 degrees F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

2.0 Proposed Change Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10. 1, "Inservice Leak and Hydrostatic Testing Operation." Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS

.amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program.

This application is being made in accordance with the CLIIP. CP&L is not proposing variations or deviations from the TS changes described in TSTF-484, Revision 0, or the*

NRC staff s model safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

3.0 Background The background for this application is adequately addressed by the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

BSEP 08-0083 Enclosure 1 Page 2 of 2 4.0 Technical Analysis CP&L has reviewed the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. CP&L has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to BSEP Unit Nos. 1 and 2 and therefore justify this amendment for the incorporation of the proposed changes to the BSEP TS.

5.0 Regulatory Analysis 5.1 No Significant Hazards ConsiderationDetermination CP&L has reviewed the no significant hazards determination published on August 21, 2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. CP&L has concluded that the determination presented in thenotice is applicable to BSEP Unit Nos. 1 and 2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 Applicable Regulatory Requirements / Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

6.0 Environmental Evaluation CP&L has reviewed the environmental evaluation included in the safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability.

CP&L has concluded that the staff's findings presented in that evaluation are applicable to BSEP Unit Nos. 1 and 2 and the evaluation is hereby incorporated by reference for this application.

7.0 References

1. Federal Register Notice, Notice of Availability published on October 27, 2006 (71 FR 63050).

2. Federal Register Notice, Notice for Comment published on August 21, 2006 (71 FR 48561)

3. TSTF-484 Revision 0, "Use of TS 3.10.1 for Scram Times Testing Activities"

BSEP 08-0083 Enclosure 2 Markup of Technical Specification Pages - Unit 1

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to be in MODE 3; and the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may be suspended,

,, ,_o,, f , , . ;t;,c t -- provided the

/*- ~following MODE 3,,LCOs are met: .

/ LCO 3.3.6.2, a.~Functions "Secondary 1 and 3 of TableContainment 3.3.6.2-1; ,Isolation Instrumentation,"

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Dampers (SCIDs)";

and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212 0 F.

° For performance of an inservice leak or hydrostatic test,

° As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or

- As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, Brunswick Unit 1 3.10-1 Amendment No.-2eal-l",

BSEP 08-0083 Enclosure 3 Typed Technical Specification Pages .- Unit 1

Inservice Leak and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 Inservice Leak and Hydrostatic Testing Operation LCO 3.10.1 The average reactor coolant temperature specified in Table 1.1-1 for MODE 4 may be changed to "NA," and operation considered not to-be in MODE 3; and the requirements of LCO 3.4*8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may be suspended, to allow reactor coolant temperature > 2121F:

" For performance of an inservice leak or hydrostatic test,

• As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or

" As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation,"

Functions 1 and 3 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Dampers (SCIDs)";

and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212°F.

. Brunswick Unit 1 3.10-1 Amendment No. I

BSEP 08-0083 Enclosure 4 Typed Technical Specification Pages - Unit 2

I Inservice Leak and Hydrostatic Testing'Operation 3.10.1 3.10 SPECIAL OPERATIONS' 3.10.1 Inservice Leak and Hydrostatic Testing Operation, LCO 3.10.1 The average reactor coolant temperature specified. in Table 1.1-1 for MODE 4 may be changed to "NA," and 6peration considered not to be in MODE 3; and the requirements of LCO' 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown," may.be suspended, to allow reactor coolant temperature > 2121F:

• For performance of an inservice leak or hydrostatic test,

• As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or

• As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following MODE 3 LCOs are met:

a. LCO 3.3.6.2, ';Secondary Containment Isolation Instrumentation,"

Functions 1 and 3 of Table 3.3.6.2-1;

b. LCO 3.6.4.1, "Secondary Containment";

c. LCO 3.6.4.2, "Secondary Containment Isolation Dampers (SCIDs)";

and

d. LCO 3.6.4.3, "Standby Gas Treatment (SGT) System.'

APPLICABILITY: MODE 4 with average reactor coolant temperature > 212 0 F.

Brunswick Unit 2 3.10-1 Amendment No. I

BSEP 08-0083 Enclosure 5 Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

Bases Inserts Insert 1 or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 212 0F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 212°F when the control rod scram time testing is initiated in conjunction with an inservice leak or hydrostatic test. These control rod scram time tests would be performed in accordance with LCO 3.10.4, Single Control Rod Withdrawal - Cold Shutdown,"

during MODE 4 operation.

Insert 2 However, even with required minimum reactor coolant temperatures < 2121F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

Insert 3 The RCS hydrostatic and/or RCS system leakage tests require increasing reactor pressure to approximately 1050 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures > 800 psig. Other testing may be performed in conjunction with the allowances for inservice leak or hydrostatic tests and control rocf scram time tests.

Inser4t-4__

during, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, Insert 5 Additionally, even with required minimum reactor coolant temperatures < 212 0F, RCS temperatures may drift above 212'F during the performance of inservice leak and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with inservice leak and hydrostatic testing. While this Special Operations LCO is provided for inservice leak and hydrostatic testing, and for scram time testing initiated in conjunction with an inservice leak or hydrostatic test, parallel performance of other tests and inspections is not precluded.

Insert 6 and for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

Insert 7

, or as a consequence of, hydrostatic or leak testing, or as a consequence of control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, Page 1 of 1

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 Inservice Leak and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this. Special Operations LCO is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) or plant temperature control capabilities during these tests require the pressure testina temperatures > 212°F (normally corresponding to MODE 3 Inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation, decay heat, and a water solid RPV are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (P/T) limits required by LCO 3.4.9, "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vesseLtemperatu re-increases:for:a-given-pressure>2:Periodic:u pdates-to:_ ...........

the RCS P/T limit curves are performed as necessary, based upon the (

APPLICABLE results of analyses of irradiated surveillance specimens removed vessel. Hydrostatic and leak testing may eventually be renuired with minimum reactor coolant temperatures > 212 0 F.

AIlowin the reactor to be considered in MODE 4"...

-- i0. t from the z=

H 1

SAFETY ANALYSES when. the reactor coolant temperature is > 212 0 F ifectively rovides an exception to MODE 3 requirements, including OPERABILI of primary containment and the full complement of redundant Emergency Core Cooling Systems. Since the drsidrc' tests are performed water solid, at low decay heat values, and near ODE 4 conditions, the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel and a subsequent increase in (continued)

Brunswick Unit 1 B 3.10.1 -1 Revision No. Y,

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES APPLICABLE coolant activity above the LCO 3.4.6, "RCS Specific Activity," limits are SAFETY ANALYSES minimized. In addition, the secondary containment will be OPERABLE, (continued) in accordance with this Special Operations LCO, and will be capable of handling any airborne radioactivity or steam leaks that could occur during the performance of hydrostatic or leak testing. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment described in References 2 and 3. Therefore, these requirements will conservatively limit radiation releases to the environment.

In the event of a large primary system leak, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. The capability of the low pressure coolant injection and core spray subsystems, as required in MODE 4 by LCO 3.5.2, "ECCS-Shutdown," would be more than adequate to keep the core flooded under this low decay heat load condition. Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

For the purposes of this test, the protection provided by normally required MODE 4 applicable LCOs, in addition to the secondary containment requirements required to be met by this Special Operations LCO, will ensure acceptable consequences during normal ydrostatic test conditions and during postulated accident conditions.

As described in LCO 3.0.7, compliance with Special Operations LCOs is optional, and therefore, no criteria of 10 CFR 50.36(c)(2)(ii) (Ref. 4) apply.

Special Operations LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.

LCO As described in LCO 3.0.7, compliance with this Special Operations LCO is optional. Operation at reactor coolant temperatures > 212°F can be in accordance with Table 1.1-1 for MODE 3 operation without meeting this Special Operations LCO or its ACTIONS. This option may be required (continued) tc tL Brunswick Unit 1 B 3.10.1-2 Revision No. 31 I

Inservice Leak and Hydrostatic Testing Operation B 3.10.1 BASES LCO due to P/T limits, however, which require testing at temperatures (continued) > 21 20 F, while performance of inservice leak and hydrostatic testing results in the in subsystems required when > 212°F (i.e.,

MODE 3).

If it is desired to perform these tests while complying with this Special Operations LCO, then the MODE 4 applicable LCOs and specified MODE 3 LCOs must be met. This Special Operations LCO allows changing Table 1.1-1 temperature limits for MODE 4 to "NA" and suspending the requirements of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown." The additional requirements for secondary containment LCOs to be met will provide sufficient protection for operations at reactor coolant temperatures

> 21 21F for the purpose of performing CZZan inservice leak or hydrostatic test,--'.

This LCO allows primary containment to be open for frequent unobstructed access to perform inspections, and for outage activities on various systems to continue consistent with the MODE 4 applicable reqiremnts9 + 01I. -I0tQýIAt

-...A PPLI CABILI-T-Y-....--.-T-he-MODE-4-req uirements-may-only-be-modified-for-the-performance-of-inservice leak or hydrostatic tests so that these operations can be considered as in MODE 4, even t ough the reactor coolant temperature is

> 21 20 F. The additional requirement for secondary containment OPERABILITY according to the imposed MODE 3 requirements provides conservatism in the response of the unit to any event that may occur.

Operations in all other MODES are unaffected by this LCO.

ACTIONS A Note has been provided to modify the ACTIONS related to inservice leak and hydrostatic testing operation. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the (continued)

Brunswick Unit 1 B 3.10.1-3 Revision No.il