BSEP 17-0026, Response to Request for Additional Information, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423,Revision 1, Technical Specifications End States, NEDC-32988-A.

Response to Request for Additional Information, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423,Revision 1, Technical Specifications End States, NEDC-32988-A.

ML17086A006
Person / Time
Site:	Brunswick
Issue date:	03/25/2017
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 17-0026, CAC MF8466, CAC MF8467
Download: ML17086A006 (8)

Text

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 March 25, 2017 Serial: BSEP 17-0026 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A"

References:

1. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A", dated September 28, 2016, ADAMS Accession Number ML16287A415

2. U.S. Nuclear Regulatory Commission E-mail Capture, Brunswick Unit 1 and Unit 2 Request for Additional Information Related to LAR to Modify the TS Requirements for End States Associated with the Implementation of the Approved TSTF Traveler TSTF-423-A (CAC NOS. MF8466 and MF8467), dated February 3, 2017, ADAMS Accession Number ML17037A002 Ladies and Gentlemen:

By letter dated September 28, 2016 (i.e., Reference 1), Duke Energy Progress, LLC, (Duke Energy) 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 to risk-inform requirements regarding selected Required Action end states by incorporating the Boiling Water Reactor (BWR) Owners' Group (BWROG) approved Topical Report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants." Additionally, the proposed amendment would modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (i.e., Mode

3) on reactor startup. On February 3, 2017, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's response to the RAI is provided in Enclosure 1.

Revised regulatory commitments are contained in Enclosure 2 of this letter.

U.S. Nuclear Regulatory Commission Page 2 of 3 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 March 25, 2017.

William R. Gideon MAT/mat

Enclosures:

1. Response to Request for Additional Information

2. Regulatory Commitments

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

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 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, III, 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 17-0026 Enclosure 1 Page 1 of 4 Response to Request for Additional Information By letter dated September 28, 2016, Duke Energy Progress, LLC, (Duke Energy) 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) to risk-inform requirements regarding selected Required Action end states by incorporating the Boiling Water Reactor (BWR) Owners' Group (BWROG) approved Topical Report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants." Additionally, the proposed amendment would modify the TS Required Actions with a Note prohibiting the use of limiting condition for operation (LCO) 3.0.4.a when entering the preferred end state (i.e., Mode 3) on reactor startup. On February 3, 2017, by electronic mail, the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's response to the RAI is provided below.

NRC RAI 1

Background

While working on similar applications, the NRC staff had earlier noticed that a regulatory guidance document used in the staff's regulatory assessments for the end-states related TSTFs and referenced in the staff's model SEs for such TSTFs, had been superseded and therefore, is not valid guidance for the adoption of the staff's approved TSTFs. The issue concerns the reference to Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," (ADAMS Accession No. ML003699426) in TSTF-423, Revision 1 (ADAMS Accession No. ML093570241) as well as model safety evaluation (ADAMS Accession No. ML120200384) for the TSTF, which states, RG 1.182, "Assessing and Managing Risk before Maintenance Activities at Nuclear Power Plants" (Reference 6), provides guidance on implementing the provisions of 10 CFR 50.65(a)(4) by endorsing a revised Section 11 to NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (Reference 7).

On November 27, 2012, via Federal Register Notice 78 FR 70846, the NRC staff informed the industry that RG 1.182 had been withdrawn by the staff since it was determined that the document (RG 1.182) was redundant due to the inclusion of its subject matter in Revision 3 of RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The Notice also stated that withdrawal of RG 1.182 neither altered any prior or existing licensing commitments based on its use, nor constituted backfitting as defined in Title 10 of the Code of Federal Regulations (10 CFR) 50.109 (the Backfit Rule) and was not otherwise inconsistent with the issue finality provisions in 10 CFR, Part 52. In addition, the NRC staff observed that RG 1.160 endorsed Revision 4A of the Nuclear Management and Resources Council (NUMARC) 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." NUMARC 93-01 provides methods that are acceptable to the NRC staff for complying with the provisions of Section 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," of Title 10, of the Code of Federal Regulations, Part 50, "Domestic Licensing of Production and Utilization Facilities" (10 CFR Part 50) (Ref. 2). The model SE for the TSTF refers to the guidance in NUMARC 93-01,

BSEP 17-0026 Enclosure 1 Page 2 of 4 Section 11, "Assessment of Risk Resulting from Performance of Maintenance Activities," dated February 22, 2000 (ADAMS Accession No. ML003704489).

RAI In order to justify adoption of the approved TSTF changes, please confirm that Brunswick's current licensing basis adheres to the RG 1.160 guidance and contains a commitment to the updated version of NUMARC 93-01. (For details, you may also refer to the NRC staff's letter dated, February 26, 2015 (ADAMS Accession No. ML15033A152), in response to the TSTF Group's letter, dated, September 16, 2014 (ADAMS Accession No. ML14259A575), on the subject matter.)

BSEP Response Duke Energy confirms that BSEP's current licensing basis adheres to Regulatory Guide 1.160 and commits to follow the guidance in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, Revision 4A, April 2011. Enclosure 2 contains revised commitments reflecting the BSEP current licensing basis.

NRC RAI 2

Background

Regarding the licensee's proposed change to LCO 3.5.1, "ECCS - Operating," the licensee's variation/deviation #3 in its application, states:

Condition C of BSEP TS 3.5.1 is proposed to be revised per TSTF-423; however, it applies when Conditions A or B are not met. Conditions in BSEP TS 3.5.1 are numbered differently from the Standard TS Conditions.

It further states:

Condition A of the Standard TS and Condition A of the BSEP TS 3.5.1 are equivalent.

BSEP TS 3.5.1 includes Condition B for one Low Pressure Coolant Injection (LPCI) pump and one Core Spray (CS) subsystem inoperable concurrently. The justification provided in the topical report and model Safety Evaluation for this change is also applicable to Condition B of the BSEP TS 3.5.1.

The proposed change to Condition A of BSEP TS 3.5.1 appeared to be equivalent to that of end state change specified for Condition A of the Standard TS 3.5.1. However, for Condition B regarding inoperability of one Low Pressure Coolant Injection (LPCI) pump and one Core Spray (CS) subsystem, the proposed change does not appear to be in accordance with the approved Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, i.e. the justification provided in the topical report and model Safety Evaluation for this change does not appear to be applicable to Condition B of the BSEP TS 3.5.1. Thus, the NRC staff considers the proposed change beyond the scope of the approved TSTF.

BSEP 17-0026 Enclosure 1 Page 3 of 4 RAI Please provide Emergency Core Cooling Systems (ECCS) analysis and containment analysis and results to verify acceptable ECCS performance, containment integrity, Environmental Equipment Qualification (EEQ), and containment heat removal for a design basis Loss of Coolant Accident (LOCA) in Mode 3 when one LPCI pump and one CS pump are concurrently inoperable in this mode.

BSEP Response The BSEP ECCS is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a loss of coolant accident (LOCA). The ECCS uses two diverse methods (i.e., flooding and spraying) to cool the core during a LOCA. The ECCS consist of the High Pressure Coolant Injection (HPCI) System, the Core Spray (CS) System, the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System, and the Automatic Depressurization System (ADS). The suppression pool provides the required source of water for the ECCS.

In order to determine the acceptability of the BSEP response to a LOCA, the most limiting combination of break size, location, and single failure was determined. The potential single failures considered in the ECCS LOCA analysis are summarized in Updated Final Safety Analysis Report (UFSAR) Table 6-15, "Single Failures and Available Systems Considered for ECCS LOCA Analysis." All potential single failures are no more severe than one of the single failures identified in UFSAR Table 6-15.

Single Failures and Available Systems Considered for ECCS LOCA Analysis Break Location Single Failure Systems Available Suction None 2LPCS+4LPI2+HPCI+ADS Suction DC Power (i) 1LPCS+3LPI2+ADS Suction DC Power (j) 2LPCS+2LPCI+HPCI+ADS Suction Diesel Generator (i) 1LPCS+3LPI2+HPCI+ADS Suction Diesel Generator (j) 2LPCS+2LPCI+HPCI+ADS Suction LPCI Injection Valve 2LPCS+2LPCI+HPCI+ADS Suction HPCI System 2LPCS+4LPI2+ADS Discharge None 2LPCS+2LPCI+HPCI+ADS Discharge DC Power (i) 1LPCS+1LPCI+ADS Discharge DC Power (j) 2LPCS+HPCI+ADS Discharge Diesel Generator (i) 1LPCS+1LPCI+HPCI+ADS Discharge Diesel Generator (j) 2LPCS+HPCI+ADS

BSEP 17-0026 Enclosure 1 Page 4 of 4 Single Failures and Available Systems Considered for ECCS LOCA Analysis Break Location Single Failure Systems Available Discharge LPCI Injection Valve 2LPCS+HPCI+ADS Discharge HPCI System 2LPCS+2LPCI+ADS Core Spray Line DC Power (i) 3LP12+ADS Feed Water Line DC Power (i) 1LPCS+3LPI2+ADS Steam Line DC Power (i) 1LPCS+3LPI2+ADS NOTES 1LPCI - One LPCI pump into one loop 2LPCI - Two LPCI pumps into one loop 2LPI2 - Two LPCI pumps into two loops 3LPI2 - Three LPCI pumps into two loops 4LPI2 - Four LPCI pumps into two loops (i) These failures assume the failure of either a battery or diesel generator associated with the unit experiencing the LOCA.

(j) These failures assume the failure of either a battery or diesel generator associated with the unit not experiencing a LOCA.

In the above table, one LPCI pump and one CS pump concurrently inoperable corresponds to the highlighted 1LPCS+3LP12 System Available cases.

For each of the above cases, the BSEP LOCA Analysis demonstrates that their consequences are mitigated to within acceptable regulatory limits. The BSEP LOCA Analysis is performed at 102 percent of Rated Thermal Power (RTP) and fully bounds a hypothetical Mode 3 LOCA.

Therefore, containment integrity, EEQ, and containment heat removal for a Mode 3 LOCA when one LPCI pump and one CS pump are concurrently inoperable remain acceptable.

The above discussion demonstrates that one LPCI pump and one CS pump concurrent inoperability (i.e., BSEP TS 3.5.1, Condition B) is equivalent to having one LPCI pump inoperable in both LPCI subsystems (i.e., Standard TS 3.5.1, Condition A) with respect to the ability to deal with a hypothetical Mode 3 LOCA. Therefore, the comparative Probabilistic Safety Analysis evaluation (i.e., discussed in Section 4.5.2.3, "LCO 3.5.1 - ECCS (Operating) of NEDC-32988-A, "Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants") of the core damage risks of remaining in Mode 3 rather than going to Mode 4 is also applicable to Condition B of the BSEP TS 3.5.1.

BSEP 17-0026 Enclosure 2 Page 1 of 1 Regulatory Commitments The following table identifies those actions committed to by Duke Energy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr.

Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Regulatory Commitments Due Date / Event Duke Energy will follow the guidance Ongoing established in Section 11 of NUMARC 93-01, Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Nuclear Management and Resource Council, Revision 4A, April 2011.

Duke Energy will follow the guidance Upon implementation of amendment.

established in TSTF-IG-05-02, Revision 2, "Implementation Guidance for TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A,'" with the exception that Duke Energy will follow Regulatory Guide (RG) 1.160 in lieu of RG 1.182, and Duke Energy will follow Revision 4A of NUMARC 93-01 in lieu of Revision 3 of NUMARC 93-01.