ML030430006

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Amendments 226 & 253 to Licenses DPR-71 & DPR-62, Respectively, Elimination of Requirements for Post-accident Sampling System
ML030430006
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 02/11/2003
From: Mozafari B
NRC/NRR/DLPM/LPD2
To: Keenan J
Carolina Power & Light Co
mozafari B, NRR/DLPM, 415-2020
References
TAC MB6774, TAC MB6775
Download: ML030430006 (17)


Text

February 11, 2003 Mr. J. S. Keenan Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: ELIMINATION OF REQUIREMENTS FOR POST-ACCIDENT SAMPLING SYSTEM (TAC NOS. MB6774 AND MB6775)

Dear Mr. Keenan:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 226 to Facility Operating License No. DPR-71 and Amendment No. 253 to Facility Operating License No.

DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2. The amendments are in response to your application dated November 13, 2002, as supplemented November 20, 2002.

The amendments delete Technical Specification 5.5.3, "Post Accident Sampling System (PASS)," and thereby eliminate the requirements to have and maintain the PASS at Brunswick Steam Electric Plant, Units 1 and 2.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions bi-weekly Federal Register Notice.

Sincerely,

/RA/

Brenda L. Mozafari, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 226 to License No. DPR-71
2. Amendment No. 253 to License No. DPR-62
3. Safety Evaluation cc w/enclosures: See next page

AMENDMENT NO. 226 TO FACILITY OPERATING LICENSE NO. DPR BRUNSWICK, UNIT 1 AMENDMENT NO. 253 TO FACILITY OPERATING LICENSE NO. DPR BRUNSWICK, UNIT 2 DISTRIBUTION:

PUBLIC PD II-2 Rdg.

OGC G. Hill (4)

R. Dennig W. Reckley H. Berkow L. Olshan B. Mozafari E. Dunnington (Paper copy)

ACRS P. Fredrickson, RII

February 11, 2003 Mr. J. S. Keenan Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: ELIMINATION OF REQUIREMENTS FOR POST-ACCIDENT SAMPLING SYSTEM (TAC NOS. MB6774 AND MB6775)

Dear Mr. Keenan:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 226 to Facility Operating License No. DPR-71 and Amendment No. 253 to Facility Operating License No.

DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2. The amendments are in response to your application dated November 13, 2002.

The amendments delete Technical Specification 5.5.3, "Post Accident Sampling System (PASS)," and thereby eliminate the requirements to have and maintain the PASS at Brunswick Steam Electric Plant, Units 1 and 2.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions bi-weekly Federal Register Notice.

Sincerely,

/RA/

Brenda L. Mozafari, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 226 to License No. DPR-71
2. Amendment No. 253 to License No. DPR-62
3. Safety Evaluation cc w/enclosures: See next page PACKAGE: ML030430008 TECH SPEC PAGES: ML030430383 &

ACCESSION NO.: ML030430006 ML030430387 OFFICE CLIIP LPM PDII-2/PM PDII-2/LA OGC PDII-2/SC NAME WReckley:rkb BMozafari EDunnington Not Reqd AHowe DATE 12/17/02 12/30/02 12/ 27 /02 2/6/03 OFFICIAL RECORD COPY

CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 226 License No. DPR-71

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Carolina Power & Light Company (the licensee), dated November 13, 2002, as supplemented November 20, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Facility Operating License No. DPR-71 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 226, are hereby incorporated in the license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Allen G. Howe, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: February 11, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 226 FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 5.0-7 5.0-7

CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 253 License No. DPR-62

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Carolina Power & Light Company (the licensee), dated November 13, 2002, as supplemented November 20, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Facility Operating License No. DPR-62 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 253, are hereby incorporated in the license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Allen G. Howe, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: February 11, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 253 FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 5.0-7 5.0-7

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 226 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO. 253 TO FACILITY OPERATING LICENSE NO. DPR-62 CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By letter dated November 13, 2002, as supplemented November 20, 2002, the Carolina Power

& Light Company (the licensee) submitted a request for changes to the Brunswick Steam Electric Plant, Units 1 and 2, Technical Specifications (TS). The requested changes would eliminate the requirements to have and maintain the post-accident sampling systems (PASS).

In the aftermath of the accident at Three Mile Island (TMI), Unit 2, the Nuclear Regulatory Commission (NRC) imposed requirements on licensees for commercial nuclear power plants to install and maintain the capability to obtain and analyze post-accident samples of the reactor coolant and containment atmosphere. The desired capabilities of the Post-Accident Sampling System [or Station] (PASS) were described in NUREG-0737, Clarification of TMI Action Plan Requirements. The NRC issued orders to licensees with plants operating at the time of the TMI accident to confirm the installation of PASS capabilities (generally as they had been described in NUREG-0737). A requirement for a PASS and related administrative controls was added to the TS of the operating plants and was included in the initial TS for plants licensed during the 1980s and 1990s. Additional expectations regarding PASS capabilities were included in Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following an Accident.

Significant improvements have been achieved since the TMI accident in the areas of understanding risks associated with nuclear plant operations and developing better strategies for managing the response to potentially severe accidents at nuclear plants. Recent insights about plant risks and alternate severe accident assessment tools have led the NRC staff to conclude that some TMI Action Plan items can be revised without reducing the ability of licensees to respond to severe accidents. The NRCs efforts to oversee the risks associated with nuclear technology more effectively and to eliminate undue regulatory costs to licensees and the public have prompted the NRC to consider eliminating the requirements for PASS in TS and other parts of the licensing bases of operating reactors.

The NRC staff has completed its review of the topical report submitted by the Boiling-Water Reactor (BWR) Owners Group (BWROG) that proposed the elimination of PASS. The justifications for the proposed elimination of PASS requirements center on evaluations of the various radiological and chemical sampling and their potential usefulness in responding to a severe reactor accident or making decisions regarding actions to protect the public from possible releases of radioactive materials. As explained in more detail in the NRC staffs safety evaluations (SEs) of the topical report, the staff has reviewed the available sources of information for use by decisionmakers in developing protective action recommendations and assessing core damage. Based on this review, the NRC staff found that the information provided by a PASS is either unnecessary or is effectively provided by other indications of process parameters or measurement of radiation levels. The NRC staff agrees, therefore, with the owners group that licensees can remove the TS requirements for PASS, revise (as necessary) other elements of the licensing bases, and pursue possible design changes to alter or remove existing PASS equipment.

2.0 BACKGROUND

In its letter dated November 30, 2000, the BWROG submitted for the NRC staff's review Topical Report NEDO-32991, "Regulatory Relaxation for BWR Post Accident Sampling Stations (PASS)," for eliminating PASS requirements from BWRs. The NRC staff's SE for the BWROG topical report is dated June 12, 2001 (ADAMS Accession Number ML011630016). The BWROG proposed that relaxation of the PASS requirements be incorporated into the standard TS by submitting TS Task Force (TSTF)-413.

The NRC staff prepared this SE related to the elimination of requirements on post-accident sampling for BWRs and solicited public comment (66 FR 66949, dated December 27, 2001) in accordance with the Consolidated Line Item Improvement Process (CLIIP). The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the PASS requirements from TS. Licensees of nuclear power reactors to which this SE applies were informed (67 FR 13027, dated March 20, 2002) that they could request amendments conforming to the SE and, in such requests, should confirm the applicability of the SE to their reactors and provide the requested plant-specific verifications and commitments 3.0 EVALUATION The ways in which the requirements and recommendations for PASS were incorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the TMI accident are likely to have been the subject of confirmatory orders that imposed the PASS functions described in NUREG-0737 as obligations. The issuance of plant-specific amendments to adopt this change, which would remove the PASS and related administrative controls from TS, would also supersede the PASS-specific requirements imposed by post-TMI confirmatory orders.

The technical evaluations for the elimination of PASS sampling requirements are provided in the SE dated June 12, 2001, of BWROG topical report NEDO-32991. As described in its SE for the topical report, the NRC staff finds that the post-accident sampling requirements for the following may be eliminated for BWR plants:

1. Reactor coolant dissolved gases.
2. Reactor coolant hydrogen.
3. Reactor coolant oxygen.
4. Reactor coolant chlorides.
5. Reactor coolant pH.
6. Reactor coolant boron.
7. Reactor coolant conductivity.
8. Radioisotopes in the reactor coolant.
9. Containment hydrogen.
10. Containment oxygen.
11. Radioisotopes in the containment atmosphere.
12. Suppression pool pH.
13. Chlorides in the suppression pool.
14. Boron in the suppression pool.
15. Radioisotopes in the suppression pool.

The NRC staff agrees that sampling of radioisotopes is not required to support emergency response decisionmaking during the initial phases of an accident because the information provided by PASS is either unnecessary or is effectively provided by other indications of process parameters or measurement of radiation levels. Therefore, it is not necessary to have dedicated equipment to obtain this sample in a prompt manner.

The NRC staff does, however, believe that there could be significant benefits to having information about the radioisotopes existing post-accident in order to address public concerns and plan for long-term recovery operations. As stated in the SE for the topical report, the NRC staff has found that licensees could satisfy this function by developing contingency plans to describe existing sampling capabilities and what actions (e.g., assembling temporary shielding) may be necessary to obtain and analyze highly radioactive samples from the reactor coolant system (RCS), suppression pool, and containment atmosphere. (See item 4.1 under Verifications and Commitments.) The contingency plans for obtaining samples from the RCS, suppression pool, and containment atmosphere may also enable a licensee to derive information on parameters such as hydrogen concentrations in containment and the pH of water in the suppression pool. The NRC staff considers the sampling of the suppression pool to be potentially useful in confirming calculations of pH and confirming that potentially unaccounted-for acid sources have been sufficiently neutralized. The use of the contingency plans for obtaining samples would depend on the plant conditions and the need for information by the decisionmakers responsible for responding to the accident.

In addition, the NRC staff considers radioisotope sampling information to be useful in classifying certain types of events (such as a reactivity excursion or mechanical damage) that could cause fuel damage without having an indication of a loss-of-reactor coolant inventory.

However, the NRC staff agrees with the topical reports contentions that other indicators of failed fuel, such as radiation monitors, can be correlated to the degree of failed fuel. (See item 4.2 under Verifications and Commitments.)

In lieu of the information that would have been obtained from the PASS, the NRC staff believes that licensees should maintain or develop the capability to monitor radioactive iodines that have

been released to offsite environs. This information would be useful for decisionmakers trying to assess a release of and limit the publics exposure to radioactive materials. (See item 4.3 under Verifications and Commitments.)

The NRC staff believes that the changes related to the elimination of the PASS that are described in the topical report, related SE and this proposed change to TS are unlikely to result in a decrease in the effectiveness of a licensees emergency plan. Each licensee, however, must evaluate possible changes to its emergency plan in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(q) to determine if the change decreases the effectiveness of its site-specific plan. Evaluations and reporting of changes to emergency plans should be performed in accordance with applicable regulations and procedures.

The NRC staff notes that containment hydrogen concentration monitors are required by 10 CFR 50.44 and are relied upon to meet the data reporting requirements of 10 CFR Part 50, Appendix E, Section VI.2.a.(ii)(3). The NRC staff concludes that these hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident. The NRC staff sees value in maintaining the capability to obtain grab samples for complementing the information from the hydrogen monitors in the long term (i.e., by confirming the indications from the monitors and providing hydrogen measurements for concentrations outside the range of the monitors). As previously mentioned, the licensees contingency plan (see item 4.1) for obtaining highly radioactive samples will include sampling of the containment atmosphere and may, if deemed necessary and practical by the appropriate decisionmakers, be used to supplement the safety-related hydrogen monitors.

4.0 Verifications and Commitments As requested by the NRC staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.

4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain),

contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, suppression pool, and containment atmosphere.

The licensee has made a regulatory commitment to develop contingency plans for obtaining and analyzing highly radioactive samples from the RCS, suppression pool, and containment atmosphere. The licensee has committed to maintain the contingency plans within applicable radiation control procedures. The licensee will implement this commitment within 180 days of the issuance of this amendment.

4.2 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), a capability for classifying fuel damage events at the Alert level threshold (typically this is 300 FCi/ml dose equivalent iodine). This capability may utilize the normal sampling system and/or correlations of radiation readings to radioisotope concentrations in the reactor coolant.

The licensee has made a regulatory commitment to establish the capability of classifying fuel damage events at the Alert level threshold of 300 FCi/ml dose equivalent iodine. The methodology will be described within applicable emergency preparedness procedures. The licensee will implement this commitment within 180 days of the issuance of this amendment.

4.3 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), an I-131 site survey detection capability, including an ability to assess radioactive iodines released to offsite environs, by using effluent monitoring systems or portable sampling equipment.

The licensee has made a regulatory commitment to establish an I-131 site survey detection capability, including an ability to assess radioactive iodines released to offsite environs. The methodology is described in applicable radiation control procedures. The licensee will implement this commitment within 180 days of the issuance of this amendment.

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.

Should the licensee choose to incorporate a regulatory commitment into the emergency plan, final safety analysis report, or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.

The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements that would require prior NRC approval of subsequent changes. The NRC staff has agreed that NEI 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff.

(See Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000 [ADAMS Accession Number ML003741774].) The commitments should be controlled in accordance with the industry guidance or comparable criteria employed by a specific licensee. The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (68 FR 799). Accordingly, the amendments meet the eligibility

criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: W. Reckley Date: February 11, 2003

Mr. J. S. Keenan Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 cc:

Mr. William D. Johnson Mr. Robert P. Gruber Vice President and Corporate Secretary Executive Director Carolina Power & Light Company Public Staff - NCUC Post Office Box 1551 4326 Mail Service Center Raleigh, North Carolina 27602 Raleigh, North Carolina 27699-4326 Mr. Donald E. Warren Mr. C. J. Gannon Brunswick County Board of Commissioners Director - Site Operations Post Office Box 249 Carolina Power & Light Company Bolivia, North Carolina 28422 Brunswick Steam Electric Plant Post Office Box 10429 Resident Inspector Southport, North Carolina 28461 U. S. Nuclear Regulatory Commission 8470 River Road Mr. Norman R. Holden, Mayor Southport, North Carolina 28461 City of Southport 201 East Moore Street Mr. John H. ONeill, Jr. Southport, North Carolina 28461 Shaw, Pittman, Potts & Trowbridge 2300 N Street NW. Mr. Dan E. Summers Washington, DC 20037-1128 Emergency Management Coordinator New Hanover County Department of Ms. Beverly Hall, Acting Director Emergency Management Division of Radiation Protection Post Office Box 1525 N.C. Department of Environment Wilmington, North Carolina 28402 and Natural Resources 3825 Barrett Dr. Mr. Terry C. Morton, Manager Raleigh, North Carolina 27609-7721 Performance Evaluation and Regulatory Affairs CPB 7 Mr. W. C. Noll Carolina Power & Light Company Plant Manager Post Office Box 1551 Carolina Power & Light Company Raleigh, North Carolina 27602-1551 Brunswick Steam Electric Plant Post Office Box 10429 Mr. Edward T. ONeil Southport, North Carolina 28461 Manager - Support Services Carolina Power & Light Company Public Service Commission Brunswick Steam Electric Plant State of South Carolina Post Office Box 10249 Post Office Drawer 11649 South Port, North Carolina 28461 Columbia, South Carolina 29211 Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602