Text

Application for Technical Specification Change Re Mode Change Limitations Using Consolidated Line Item Improvement Process
	ML033600115
Person / Time
Site:	Brunswick, Crystal River, Robinson
Issue date:	12/19/2003
From:	Hinnant C; Progress Energy Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PERAS03-127
	Download: ML033600115 (239)
	v • d • e

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an 0 is not ii , entry mt a MODE or er specifi condi *on in the icability all not be ade except en th ssociated IONS to be ntered pe continued eration in e MODE or er specifi condition the ApplicabiV for an un mited perio of time. s Specific ion shall prevent c nges in MOD or other specif d conditio in the App cability t are requir to mply with IONS or th are part o a shutdown the t.

(continued)

Brunswick Unit 2 3.0-1 Amendment No. (9

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 ceptions o this pecific ion ar tated the (continued) individu Spec fcations LCO .0.4 is appcable aly f entry to a MOD or oth sp ified c dition the A icabiX y in MOD 1, 2, LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Brunswick Unit 2 3.0-2 Amendment No. e

INSERT 1 (LCO 3.0.4)

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued)

SR 3.0.4 E ry into MODE o other s cified ndition the App icabilit of an 1 0 shall ot be a e unless'he ICO' Surv llances ave bee met wit n their pecifie Freque y. Thi provisi shall at preve t entry ito DES o other sp cified ndition in the plicabil y INlr45WE~RT 2 _ th t are quired comply ith Acfons or t t are pa t of a tf An 4hk .v\

SR 3.0. is on applic le for ntry in a MODE r other,\

bpecifi econdi on in t Applic ility i MODES 1, 2, an 3.

Brunswick Unit 2 3.0-5 Amendment No. C)

INSERT 2 (SR 3.0.4)

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS

NOTE~ ------------------------------------

no app 4 cab Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6.

not met.

C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status.

(continued)

Brunswick Unit 2 3.3-26 Amendment No.Q!)

Remote Shutdown Monitoring Instrumentation 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown Monitoring Instrumentation LCO 3.3.3.2 The Remote Shutdown Monitoring Instrumentation Functions shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS 3- 4NOT -- -------------------

2. Separate Cndition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

(continued)

Brunswick Unit 2 3.3-30 Amendment No. (e)

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump flow monitoring system; and

b. One channel of either primary containment atmosphere particulate or atmosphere gaseous radioactivity monitoring system.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain l-OT \ -i sump flow monitoring .0. is n t apli ble system inoperable. F\ < --

A.1 Restore drywell floor 30 days drain sump flow monitoring system to OPERABLE status.

(continued)

Brunswick Unit 2 3.4-9 Amendment No. (0)

RdS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required primary-NO containment atmosphere 10 0. ispot pp *caDte.

radioactivity monitoring system inoperable. B.1 Analyze grab samples Once per of primary 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment atmosphere.

AND B.2 Restore required 30 days primary containment atmosphere radioactivity monitoring system to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND or B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. All required leakage D.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

Brunswick Unit 2 3.4-10 Amendment No. ()

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity < 0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant- - -N E-specific activity LC 3. 4 i not ap ica le.

> 0.2 pCi/gm and

< 4.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT I-131 to within limits.

B. Required Action and B.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion EQUIVALENT 1-131.

Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months steam lines.

Reactor coolant specific activity OR

> 4.0 pCi/gm DOSE EQUIVALENT 1-131.

(continued)

Brunswick Unit 2 3.4-12 Amendment No.(TYD

INSERT 3 (TS 3.4.6 RCS Specific Activity)

NOTE -

LCO 3.0.4.c is applicable.

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure.

ACTIONS 2/ Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status.

AND (continued)

Brunswick Unit 2 3.4-14 Amendment No. (e

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig.

ACTION_ _ _ _ __ _ __

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

OR One low pressure coolant injection (LPCI) pump in each subsystem inoperable.

B. One LPCI pump B.1 Restore LPCI pump to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. OPERABLE status.

AND OR One core spray (CS) B.2 Restore CS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystem inoperable. to OPERABLE status.

(continued)

Brunswick Unit 2 3.5-1 Amendment No. (

INSERT 4 (TS 3.5.1 ECCS - Operatinci)

NOTE----------------------------

LCO 3.0.4.b is not applicable to HPCI.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONy_

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System 14 days to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

< 150 psig.

Brunswick Unit 2 3.5-12 Amendment No. (e)

INSERT 5 (TS 3.5.3 RCIC)

is NOTE ---- ---

LCO 3.0.4.b is not applicable to RCIC.

RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression NTE pool cooling subsystem L P 3 p.4 s n 4 ap icfle.\

inoperable. j--- -- 1 A.1 Restore RHR 7 days suppression pool cooling subsystem to OPERABLE status.

B. Two RHR suppression B.1 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months pool cooling suppression pool subsystems inoperable. cooling subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Brunswick Unit 2 3.6-24 Amendment No. (9

CAD System 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System LCO 3.6.3.2 .CAD System shall be OPERABLE.

APPLICABILITY: MODE 1 during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a scheduled reduction of THERMAL POWER to < 15% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CAD System inoperable. A.1 --- \--NO E L~t

.X. iknot\~

pp icae X Restore CAD System to 31 days OPERABLE status.

B. Required Action and C.1 Be in MODE 2. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months associated Completion Time not met.

Brunswick Unit 2 3.6-27 Amendment No.QD

RHRSW System 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Residual Heat Removal Service Water (RHRSW) System ICO 3.7.1 Two RHRSW subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS______ ___

CONDITION REQUIRED ACTION COMPLETION TIME A. One RHRSW pump A.1 \-\-NXE- -\

inoperable. L~ Np4i not \

Restore RHRSW pump to 14 days OPERABLE status.

(continued) 3.7-1 Brunswick Unit 2 3.7-1No.( )

~Amendment

RHRSW System 3.7.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One RHRSW subsystem B.1 ------- OTE -------

inoperable for reasons Enter applicable other than Conditions and Condition A. Required Actions of LCO 3.4.7,

'Residual Heat Removal (RHR)

Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

Restore RHRSW - 7 days subsystem to OPERABLE status.

C. Both RHRSW subsystems C.1 -------- NOTE---------

inoperable. Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

Restore one RHRSW 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months subsystem to OPERABLE status.

(continued)

Brunswick Unit 2 3.7-2 Amendment No. O8

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two Unit 2 qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System;

b. Four diesel generators (DGs); and

c. Two Unit 1 qualified circuits between the offsite transmission network and the onsite Class IE AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, and 3.

N SE RT (

ACTIONS _

CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE------ A.1 Restore Unit 1 45 days Only applicable when offsite circuit to Unit 1 is in MODE 4 OPERABLE status.

or 5.

One Unit 1 offsite circuit inoperable.

(continued)

Brunswick Unit 2 3.8-1 Amendment No. M I

INSERT 6 (TS 3.8.1 AC Sources - Operating)

NOTE------------------------

LCO 3.0.4.b is not applicable to DGs.

Document Control Desk PERAS 03-127/ Page 2 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachments 2 and 3 provide mark-ups of the existing TS and TS Bases pages to show the proposed changes. Attachment 4 provides revised (typed) TS pages. Attachment 5 documents that no new regulatory commitments are made in this submittal.

PEC and PEF request that the proposed amendments be reviewed by a single NRC reviewer and that approval of the proposed license amendments occur by March 31, 2004, with the amendments being fully implemented within 180 days after approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the States of North Carolina, South Carolina, and Florida.

Please refer any questions regarding this submittal to Mr. Tony Groblewski, Supervisor - Regulatory Affairs, at (919) 546-4579.

Sincerely, C. S. Hinnant RTG/rtg Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes

3. Proposed Technical Specification Bases Changes

4. Revised Technical Specification Pages

5. Regulatory Commitments C. S. Hinnant, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Progress Energy Carolinas, Inc. (PEC) and Progress Energy Florida, Inc. (PEF).

(Not eal)

My-coimission expires: ii-/o-OI

Document Control Desk PERAS 03-127/ Page 3 cc (with attachments):

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: NRC Senior Resident Inspector - Brunswick Nuclear Plant U. S. Nuclear Regulatory Commission ATTN: NRC Senior Resident Inspector - Crystal River Unit 3 U. S. Nuclear Regulatory Commission ATTN: NRC Senior Resident Inspector - Robinson Nuclear Plant U. S. Nuclear Regulatory Commission ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Chandu P. Patel (Mail Stop OWFN 8H12) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 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 Mr. Henry Porter Assistant Division Director, Radioactive Waste Management Section South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Attorney General - State of South Carolina Rembert C. Dennis Building Columbia, SC 29201

Document Control Desk PERAS 03-127/ Page 4 Dept. of Health, Bureau of Rad. Control Attn: Administrator - HSERE - BINC21 4052 Bald Cypress Way Tallahassee, FL 32399-1741 Chairman BOCC Board of County Commissioners 111 W. Main Street 3rd Floor Masonic Bldg.

Inverness, FL 32650

ATTACHMENT 1 APPLICATION FOR TECHNICAL SPECIFICATION CHANGES FOR THE MODIFICATION OF REQUIREMENTS REGARDING MODE CHANGE LIMITATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS DESCRIPTION AND ASSESSMENT In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Progress Energy Carolinas, Inc. (PEC) and Progress Energy Florida, Inc. (PEF), propose changes to the Technical Specifications (TS), for the following Operating Licenses:

Progress Energy Carolinas, Inc. (PEC)

BRUNSWICK STEAM ELECTRIC PLANT, DOCKET NOS. 50-325 AND 50-324 UNIT NOS. 1 AND 2 LICENSE NOS. DPR-71 AND DPR-62 H. B. ROBINSON STEAM ELECTRIC DOCKET NO. 50-261 PLANT, UNIT NO. 2 LICENSE NO. DPR-23 Progress Energy Florida, Inc. (PEF)

CRYSTAL RIVER UNIT 3 NUCLEAR DOCKET NO. 50-302 GENERATING PLANT LICENSE NO. DPR-72 The proposed changes concern TS improvements to modify the requirements regarding MODE change limitations using the Consolidated Line Item Improvement Process (CLIIP).

1.0 DESCRIPTION

The proposed amendments would modify the Technical Specifications (TS) requirements for mode change limitations in LCO 3.0.4 and SR 3.0.4.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-359, Revision 9. The FederalRegister notice announced the availability of this TS improvement through the Consolidated Line Item Improvement Process (CLUP) in the Federal Register, which is described as "TSTF-359, Revision 8, as modified by the notice in the Federal Register published on April 4, 2003." The modifications to Revision 8 are now incorporated into Revision 9.

Al-I

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation PEC and PEF have reviewed the safety evaluation dated on April 4, 2003, as part of the CLIIP.

This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-359 Revision 9. PEC and PEF have concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to BSEP, Units 1 and 2, RNP Unit 2, and CR3, and justify these amendments for the incorporation of the changes to the BSEP, Units 1 and 2, RNP Unit 2, and CR3, TS.

2.2 Optional Changes and Variations PEC and PEF are not proposing any variations or deviations from the TS changes described in TSTF-359 Revision 9 and the NRC staff's model safety evaluation dated April 4, 2003.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration PEC and PEF have reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister on April 4, 2003, as part of the CLUP and have concluded that the proposed NSHCD presented in the FederalRegister notice is applicable to BSEP, Units 1 and 2, RNP Unit 2, and CR3 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on April 4, 2003, for this TS improvement, plant-specific verifications were performed as follows:

The licenses have established TS Bases for LCO 3.0.4 and SR 3.0.4 which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to operable status before entering an associated mode or other specified condition in the TS Applicability.

The modification also includes changes to the bases for LCO 3.0.4 and SR 3.0.4 that provide details on how to implement the new requirements. The bases changes provide guidance for changing Modes or other specified conditions in the Applicability when an LCO is not met. The bases changes describe in detail how: LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and Al-2

establishment of risk management actions, if appropriate; and LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g., Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient), though it may be applied to other Specifications based on NRC plant-specific approval. The bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. In addition, the bases state that upon entry into a Mode or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions for no more than the duration of the applicable Completion Time or until the LCO is met or the unit is not within the Applicability of the TS. The bases also state that SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. Finally, the license is expected to have a bases control program consistent with Section 5.5 (Section 5.6 for CR3) of the STS, and the equivalent of STS SR 3.0.1 and associated Bases.

4.0 Environmental Evaluation PEC and PEF have reviewed the environmental evaluation included in the model safety evaluation dated April 4, 2003, as part of the CLIIP and concluded that the staff's findings are applicable to BSEP, Units 1 and 2, RNP, Unit 2, and CR3. The evaluation is hereby incorporated by reference for this application.

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ATTACHMENT 2 APPLICATION FOR TECHNICAL SPECIFICATION CHANGES FOR THE MODIFICATION OF REQUIREMENTS REGARDING MODE CHANGE LIMITATIONS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UPS)

Progress Energy Carolinas, Inc. (PEC)

BRUNSWICK STEAM ELECTRIC PLANT, DOCKET NOS. 50-325 AND 50-324 UNIT NOS. I AND 2 LICENSE NOS. DPR-71 AND DPR-62 H. B. ROBINSON STEAM ELECTRIC DOCKET NO. 50-261 PLANT, UNIT NO. 2 LICENSE NO. DPR-23 Progress Energy Florida, Inc. (PEF)

CRYSTAL RIVER UNIT 3 NUCLEAR DOCKET NO. 50-302 GENERATING PLANT LICENSE NO. DPR-72

BNP TS Mark ups