BSEP 16-0072, Response to Request for Additional Information Regarding License Amendment Request to Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program

Response to Request for Additional Information Regarding License Amendment Request to Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program

ML16230A002
Person / Time
Site:	Brunswick
Issue date:	08/04/2016
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 16-0072
Download: ML16230A002 (5)

Text

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William R. Gideon e/DUKE Vice President

~;ENERGY Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 August 4, 2016 Serial: BSEP 16-0072 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20SSS-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. S0-32S and S0-324 Response to Request for Additional Information Regarding License Amendment Request to Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program

References:

1. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, Application For Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Ucensee-Controlled Program, dated December 21, 201 S, ADAMS Accession Number ML16004A249

2. NRC E-mail Capture, Brunswick Unit 1 and Unit 2 Request for Additional Information related to LAR to Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program (GAG NOS. MF7206 and MF7207), dated July 28, 2016, ADAMS Accession Number ML16210A193 Ladies and Gentlemen:

By letter dated December 21, 201 S (i.e., Reference 1), Duke Energy Progress, Inc., submitted a license amendment request (LAA) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment would modify the Technical Specifications (TSs) by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specification Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1. Additionally, the change would add a new program, the Surveillance Frequency Control Program, to TS Section S.S, "Programs and Manuals." The changes are consistent with Nuclear Regulatory Commission (NRC) approved Tec.hnical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change TSTFl42S, "Relocate Surveillance Frequencies to Lic'ensee Control - RITSTF Initiative Sb," Revision 3.

On July 28, 2016, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAA. Duke Energy's response is provided in the enclosure of this letter.

U.S. Nuclear Regulatory Commission Page 2 of 3 No new regulatory commitments are contained in this letter.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on August 4, 2016.

s~

William R. Gideon MAT/mat

Enclosure:

Response to Request for Additional Information

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRG Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services

• 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

.'- I ,,

BSEP 16-0072 Enclosure Page 1 of 2 Response to Request for Additional Information By letter dated December 21, 201S (i.e., Reference 1), Duke Energy Progress, Inc., submitted a license amendment request (LAA) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment would modify the Technical Specifications (TSs) by relocating specific surveillance frequencies to a licensee-controlled program with the implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specification Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1. Additionally, the change would add a new program, the Surveillance Frequency Control Program, to TS Section S.S, "Programs and Manuals." The changes are consistent with Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change TSTF-42S, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative Sb," Revision 3.

On July 28, 2016, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAA. Duke Energy's response is provided below.

NRC RAI:

RAI Regulatory Bases:

Title 1O of Code of Federal Regulations, Part SO, Section 36, Technical specifications. (c)

Technical specifications will include items in the following categories: (3) Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

RAI

• Note 4 of SR 3.3.1.1.17 for Units 1 and 2 contains a sentence Testing of APRM and Oscillation Power Range Monitor (OPRM) outputs shall alternate" that is marked for deletion. There is no provision provided in the approved TSTF-42S, Revision 3 for deletion of this sentence and there is no explanation or justification of this deviation from current technical specifications in the application for a license amendment.

Please explain the impact of the deletion of this sentence and the justification for its dele.tion.

Response

Brunswick Surveillance Requirement (SR) 3.3.1.1.17 corresponds to SR 3.3.1.1.1 S in Approved TSTF-42S, Revision 3. Brunswick SR 3.3.1.1.17, Note 4, reflects plant specific power range neutron monitoring system design as approved by the NRC on March 8, 2002, in Amendments 217 and 243 for Units 1 and 2, respectively (i.e., ADAMS Accession No. ML020720742). Note 4 is the same for both Units 1 and 2.

BSEP 16-0072 Enclosure Page 2 of 2 The following provides a comparison of the two SRs.

Brunswick SR 3.3.1.1.17 TSTF-425, Revision 3, SR 3.3.1.1.15

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NOTES-------------------------------- --------------------------------NOTES--------------------------------

1. Neutron detectors are excluded. 1. Neutron detectors are excluded.

2. For Functions 3 and 4, the sensor response time 2. For Function 5, "n" equals 4 channels for the may be assumed to be the design sensor response purpose of determining the STAGGERED TEST time. BASIS Frequency.

3. For Function 5, "n" equals 4 channels for the purpose of determining the STAGGERED TEST Verify the RPS RESPONSE TIME is within limits.

BASIS Frequency.

4. For Function 2.e, "n" equals 8 channels for the purpose of determining the STAGGERED TEST BASIS Frequency. Testing of APRM and Oscillation Power Range Monitor (OPRM) outputs shall alternate.

Verify the RPS RESPONSE TIME is within limits.

Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specification Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1, addressed relocation of staggered test basis frequencies to licensee control under the Surveillance Frequency Control Program. The approved TSTF-425, Revision 3, removed Notes (e.g., Note 2 for SR 3.3.1.1.15) which include explanatory detail associated with implementation of the staggered test basis frequency. The sentence "Testing of APRM and Oscillation Power Range Monitor (OPRM) outputs shall alternate" provides such explanatory detail associated with implementation of the staggered test basis frequency. The existing bases for Brunswick SR 3.3.1.1.17 states, in part:

Note 4 allows the STAGGERED TEST BASIS Frequency for Function 2.e to be determined based on 8 channels rather than the 4 actual 2-0ut-Of-4 Voter channels.

The redundant outputs from the 2-0ut-Of-4 Voter channel (2 for APRM trips and 2 for OPRM trips) are considered part of the same channel, but the OPRM and APRM outputs are considered to be separate channels for application of SR 3.3.1.1.17, so n = 8. The note further requires that testing of OPRM and APRM outputs be alternated.

Relocation of this phrase results in no greater loss in level of detail than elimination of Note 2 for SR 3.3.1.1.15 consistent with approved TSTF-425, Revision 3. Rather it moves explanatory detail associated with implementation of the staggered test basis frequency to the Surveillance Frequency Control Program, which is consistent with the relocation of the surveillance frequency.