BSEP 16-0109, Response to Request for Additional Information, Revision to Requested Implementation Schedule, and Status Update - License Amendment Request Regarding Relocation of Specific Surveillance Frequency Requirements to Licensee-

Response to Request for Additional Information, Revision to Requested Implementation Schedule, and Status Update - License Amendment Request Regarding Relocation of Specific Surveillance Frequency Requirements to Licensee-

ML16348A548
Person / Time
Site:	Brunswick
Issue date:	11/17/2016
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 16-0109
Download: ML16348A548 (5)

Text

(-..DUKE William R. Gideon

~JENERGY Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 November 17, 2016 Serial: BSEP 16-0109

- U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Re-newed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information, Revision to Requested Implementation Schedule, and Status Update - License Amendment Request Regarding 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 Licensee-Controlled Program, dated December 21, 2015, ADAMS Accession Number ML16004A249

2. U.S. Nuclear Regulatory Commission E-m*ail Capture, Brunswick Unit 1 and Unit 2 Request for Additional Information Related*_to LAR to Relocate Specific Surveillance Frequency Requirements to Licensee Controlled Program (GAG Nos. MF7206 and MF7207), dated November 14, 2016

3. U.S. Nuclear Regulatory Commission letter, Brunswick Steam Electric Plant, Unit Nos. 1 a!Jd 2; Shearon Harris Nuclear Power Plant, Unit 1; Catawba Nuclear Station, Units 1 and 2; McGuire Nuclear Station, Units 1 and 2; and Oconee Nuclear Station, Units 1, 2, and 3: Issuance of Amendments Regarding Adoption of TSTF-523 (CAC Nos. MF6413 Through MF6422), dated April 29, 2016, ADAMS Accession Number ML16085A113

4. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, Clarification of Responses for Requests for Additional Information License Amendment Request for Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program, dated November 1, 2016, ADAMS Accession Number ML16321A406

U.S. Nuclear Regulatory Commission Page 2 of 3

• Ladies and Gentlemen:

By letter dated December 21, 201 S (i.e., Reference 1), Duke Energy Progress, LLC, submitted a license amendment request (LAR) 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." 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 November 14, 2016, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's response to this RAI is enclosed.

On April 29, 2016 (i.e., Reference 3), the NRC issued Amendments 270 and 298 to the Renewed Facility Operating License for BSEP, Units 1 and 2, respectively. These amendments approved the adoption of TSTF-S23, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," and must be implemented within one year of issuance. Amendments 270 and 298 included new Surveillance Requirements (SRs) and revised existing SRs that fall within the scope of the proposed TSTF-42S LAR.

• In order to allow implementation of Amendments 270

• and 298 (i.e., which are to be implemented within one year of issuance) prior to implementation of the TSTF-42S amendments, Duke Energy requests that the NRC authorize a 180-day implementation period for the TSTF-42S amendments. This 180-day implementation period supersedes the originally requested 120-day implementation period.

As a result of conversations with the NRC, Duke Energy requests that review of the proposed TSTF-42S LAR be temporarily placed on hold until the following action is completed.

Duke Energy will conduct a focused-scope peer review in accordance with Regulatory Guide 1.200, Revision 2, for the internal flooding technical elements based on the enhancements made since the 201 O peer review. All finding-level F&Os from the 201 O peer review, as well as any finding-level F&Os from the new focused-scope peer review itself, will be resolved.

This action was most recently committed to in Duke Energy's November 1, 2016, RAI clarification submittal (i.e., Reference 4). The focused-scope peer review is currently scheduled to be performed in January 2017. Duke Energy will provide the results of the review upon completion.

No ne':'V regulatory commitments are contained in this letter.

l Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (91 O) 4S7-2487.

U.S. Nuclear Regulatory Commission Page 3 of 3 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 17, 2016.

Sincerely, (

~

William R. Gideon MAT/mat

Enclosure:

Response to Request for Additional Information 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 ATIN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Andrew.Hon@nrc.gov U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC 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

BSEP 16-0109 Enclosure Page 1 of 2 Response to Request for Additional Information By letter dated December 21, 2015, Duke Energy Progress, LLC, submitted a license amendment request (LAR) 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 5b, Risk-Informed Method for Control of Surveillance Frequencies." Additionally, the change would add a new program, the Surveillance Frequency Control Program, to TS Section 5.5, "Programs and Manuals." The changes are consistent with Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force {TSTF) Standard Technical Specifications (STS) Change TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b,"

Revision 3. On November 14, 2016, by electronic mail, the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's responses to this RAI is provided below.

NRC RAI:

SR 3.3.1.2.4 contains a two part frequency, "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" marked for replacement in its entirety with "In accordance with the Surveillance Frequency Control Program." The first part of the frequency, "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS," appears to meet one of the four exclusion criteria of part 2.0 of the approved TSTF-425, Revision 3 traveler as a "frequency that is related to a specific condition ... " Propose a new markup that replaces only the second part of the frequency or alternately explain why the exclusion does not apply and how the complete frequency will be addressed in the Surveillance Frequency Control Program.

Response

No specific guidance was found which defines a Frequency that is related to a specific condition. However, this RAI is similar to the following RAI, raised during the NRC's initial review of TSTF-425, and responded to by the Technical Specifications Task Force (TSTF) on January 17, 2008 (i.e., ADAMS Accession Number ML080280272).

In NUREG-1433 SR 3.8.6.6, and NUREG-1434 SR 3.8.6.6, TSTF-425 will relocate the 12-month and 24-month surveillance frequencies associated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity. This is inconsistent with the proposed changes to similar SRs in NUREG-1430, NUREG-1431, and NUREG-1432, which would only relocate the 60-month frequency associated with non-degraded batteries. The staff considers the specific conditions of battery degradation, age, and capacity as not within the scope of NEI 04-10. Provide a revision to TSTF-425 which retains, in NUREG-1433 and NUREG-1434, the SRs for degraded or old batteries.

The above RAI indicates that a specific condition is associated with the state of the component on which the SR is being performed. Unlike SR 3.8.6.6, the qualifier on the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency for SR 3.3.1.2.4 is not related to a specific condition (i.e., state) of the components to be tested (i.e., as is the case for a battery) or a condition for the performance of the SR. The qualifier only affects the Frequency and, therefore, this Frequency does not meet the TSTF-425 exception.

BSEP 16-0109 Enclosure Page 2 of 2 The note modifies the Applicability of one of the Frequencies. The SR is equivalent to two SRs:

one with a periodic frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and a second with a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> periodic frequency in which the Surveillance is modified by a Note that states "Only required to be performed during Core Alterations." Had the SR been written in this technically equivalent manner, relocation of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency to the Surveillance Frequency Control Program (SFCP) would clearly be acceptable.

The BSEP markup of SR 3.3.1.2.4 is consistent with the marked-up SR in the NRG approved TSTF-425, as currently incorporated into NUREG-1433, "Standard Technical Specifications for General Electric BWR/4 Plants," Revision 4, with both portions of the Frequency replaced by a reference to the SFCP. Additionally, the bases for SR 3.3.1.2.4, states:

[ The Frequency is based upon channel redundancy and other information available in the control room, and ensures that the required channels are frequently monitored while core reactivity changes are occurring. When no reactivity changes are in progress, the Frequency is relaxed from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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RE\llEWER'S NOTE------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

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]

The bases clearly demonstrates that the NRG approved TSTF 425, as currently incorporated into NUREG-1433, replaces both the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency of SR 3.3.1.2.4.

Based on the above discussions, the proposed BSEP SR 3.3.1.2.4 is acceptable as submitted.

The relocated Frequencies will be treated separately (i.e., equivalent to two SRs: one with a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency during CORE ATERATIONS and a second with a frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) in the SFCP.