BSEP 11-0068, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation

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License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation
ML11208B626
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/12/2011
From: Annacone M
Progress Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 11-0068
Download: ML11208B626 (22)
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Text

j Progress Energy ý41ýMichael J. Annacone VichPesident Brunswick Nuclear Plant July 12, 2011 SERIAL: BSEP 11-0068 10 CFR 50.90 TSC-2010-04 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 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,

is submitting a request for an amendment to the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The proposed amendment would revise the TS to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make TS Bases changes which reflect the proposed changes and more accurately reflect the contents of the facility design basis related to operability of the RCS leakage detection instrumentation. These changes are consistent with NRC-approved Revision 3 to TSTF Standard Technical Specifications Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on December 17, 2010 (i.e., 75 FR 79048), as part of the consolidated line item improvement process (CLIIP).

Enclosure 1 provides an evaluation of the proposed change. Enclosure 2 provides the existing Unit 1 TS pages marked-up to show the proposed changes. Identical changes are being requested for the Unit 2 TSs. Enclosures 3 and 4 provide the proposed TS changes in final typed format for Units I and 2, respectively. Enclosure 5 provides the existing Unit 1 TS Bases pages marked-up to show the affect of the proposed TS changes. These pages are being submitted for information only and do not require issuance by the NRC.

The Unit 2 TS Bases will be similarly revised.

Progress Energy Carolinas, Inc. 4 0 Southport, NC 28461 Lt* .

T> 910.457.3698

Document Control Desk BSEP 11-0068 / Page 2 CP&L requests approval of the proposed license amendment by December 15, 2011, with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91(a)(1), "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.

In accordance with 10 CFR 50.91(b), "State Consultation," CP&L is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

No regulatory commitments are contained in this submittal. Please refer any questions regarding this submittal to Mr. Lee Grzeck, Acting Supervisor - Licensing/Regulatory Programs, at (910) 457-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 12, 2011.

Sincerely, Michael J. Annacone MAT/mat

Enclosures:

1. Evaluation of Proposed License Amendment Request
2. Marked-up Technical Specification Pages - Unit 1
3. Typed Technical Specification Pages - Unit 1
4. Typed Technical Specification Pages - Unit 2
5. Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

Document Control Desk BSEP 11-0068 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Philip B. O'Bryan, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645

BSEP 11-0068 Enclosure I Page 1 of 6 Evaluation of Proposed License Amendment Request

Subject:

License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3 - Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation 1.0 Description The proposed amendment would revise the Technical Specifications (TS) to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable and make TS Bases changes. These changes are consistent with Technical Specifications Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on December 17, 2010 (i.e., 75 FR 79048), as part of the consolidated line item improvement process (CLIIP).

2.0 Proposed Changes The proposed changes revise and add a new Condition C to TS 3.4.5, "RCS Leakage Detection Instrumentation," and revise the associated bases. New Condition C is applicable when the primary containment atmosphere gaseous radioactivity monitor is the only operable TS-required instrument monitoring RCS leakage, i.e., TS-required particulate and sump monitors are inoperable. New Condition C Required Actions require monitoring RCS leakage by obtaining and analyzing grab samples of the primary containment atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; monitoring RCS leakage using administrative means every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; and taking action to restore monitoring capability using another monitor within 7 days.

Additionally, the TS Bases which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in Limiting Condition for Operation (LCO) Bases, delete discussion from the TS Bases that could be construed to alter the meaning of TS operability requirements, and revise the TS Bases to reflect the changes made to TS 3.4.5.

Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., is not proposing variations or deviations from the TS changes described in TSTF-514, Revision 3, or the NRC staff s model safety evaluation (SE) published in the FederalRegister on December 17, 2010 (75 FR 79048), as part of the CLIIP Notice of Availability.

BSEP 11-0068 Enclosure 1 Page 2 of 6 3.0 Background NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity,"

dated August 3, 2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to detect a one gallon per minute leak within one hour.

Some licensees, in response to IN 2005-24, have taken action to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has shown that the primary containment atmosphere gaseous radioactivity monitor is often the first monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff met on April 29, 2008, and April 14, 2009, to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmosphere gaseous radioactivity monitor in the LCO list of required equipment, revise the specified safety function of the gas monitor to specify the required instrument sensitivity level, to revise the Actions requiring additional monitoring, and provide less time before a plant shutdown is required when the primary containment atmosphere gaseous radioactivity monitor is the only operable monitor.

4.0 Technical Analysis CP&L has reviewed TSTF-514, Revision 3, and the model SE published on December 17, 2010 (75 FR 79048), as part of the CLIIP Notice of Availability. CP&L has concluded that the technical bases presented in TSTF Traveler-514, Revision 3, and the model SE prepared by the NRC staff are applicable to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The BSEP design was reviewed for construction under the "General Design Criteria for Nuclear Power Plant Construction" issued for comment by the Atomic Energy Commission in July 1967 and is committed to meet the intent of the General Design Criteria (GDC), published in the FederalRegister on May 21, 1971, as Appendix A to 10 CFR Part 50. Criterion 30, "Quality of reactor coolant pressure boundary," requires that means be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage. BSEP is currently committed to Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 0, May 1973. Section 5.2.5, "Detection of Leakage Through Reactor Coolant System Boundary," of the BSEP Updated Final Safety Analysis Report (UFSAR) provides details associated with the leakage detection systems in use at BSEP.

The administrative means of monitoring include diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. CP&L will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell pressure, drywell temperature, Reactor Building Closed Cooling Water (RBCCW) system cooling water temperature to and from the primary containment atmosphere coolers, and reactor water level.

BSEP 11-0068 Enclosure 1 Page 3 of 6 There are diverse alternative methods for determining that RCS leakage has not increased, from which appropriate indicators may be selected based on plant conditions. CP&L will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell pressure, drywell temperature, RBCCW system cooling water temperature to and from the primary containment atmosphere coolers, and reactor water level. Actions to verify that these indications have not increased since the required monitors became inoperable and analyze primary containment atmosphere grab samples are sufficient to alert the operating staff to an unexpected increase in RCS leakage.

5.0 Regulatory Analysis 5.1 No Significant Hazards ConsiderationDetermination CP&L has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has detennined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

Description of Amendment Request: The proposed amendment would revise TS 3.4.5, "Reactor Coolant System (RCS) Leakage Detection Instrumentation," Conditions and Required Actions and the licensing basis for the primary containment atmosphere gaseous radioactivity monitor, as well as make associated TS Bases changes for TS 3.4.5.

Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91 (a), the CP&L analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the primary containment atmosphere gaseous radioactivity monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

BSEP 11-0068 Enclosure 1 Page 4 of 6

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS required operable RCS leakage detection instrumentation monitor is the primary containment atmosphere gaseous radioactivity monitor. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the primary containment atmosphere gaseous radioactivity monitor. Reducing the amount of time the plant is allowed to operate with only the primary containment atmosphere gaseous radioactivity monitor operable increases the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, CP&L concludes that the requested change does not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."

5.2 Applicable Regulatoiy Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the FederalRegister Notice of Availability on December 17, 2010 (75 FR 79048). CP&L has reviewed the NRC staff s model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is not applicable to BSEP. The following regulatory requirements apply to BSEP.

The BSEP design was reviewed for construction under the "General Design Criteria for Nuclear Power Plant Construction" issued for comment by the Atomic Energy Commission in July 1967 and is committed to meet the intent of the General Design Criteria (GDC), published in the FederalRegister on May 21, 1971, as Appendix A to 10 CFR Part 50. Criterion 30, "Quality of

BSEP 11-0068 Enclosure 1 Page 5 of 6 reactor coolant pressure boundary," requires that means be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

BSEP is committed to Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973. RG 1.45 describes acceptable methods of implementing this requirement with regard to the selection of leakage detection systems for the reactor coolant boundary. The position of RG 1.45 is that at least three different detection methods should be employed. Two of these methods should be: (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring. The third method may involve either monitoring of condensate flow rate from air coolers or monitoring of gaseous radioactivity.

The regulatory guide recommends that the sensitivity and response time of each leakage detection system employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of one gallon per minute (gpm) in less than one hour.

Section 5.2.5, "Detection of Leakage Through Reactor Coolant System Boundary," of the BSEP Updated Final Safety Analysis Report (UFSAR) provides details associated with the leakage detection systems in use at BSEP. TS 3.4.5 establishes LCOs for three of these systems: (1) the drywell floor drain sump flow monitoring system, (2) the primary containment atmosphere particulate monitoring system, and (3) the primary containment atmosphere gaseous monitoring system. As discussed in the UFSAR, drywell pressure, drywell temperature, Reactor Building Closed Cooling Water (RBCCW) system cooling water temperature to and from the primary containment atmosphere coolers, and reactor water level also provide a means for detecting leaks within the primary containment.

6.0 Environmental Consideration The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

BSEP 11-0068 Enclosure 1 Page 6 of 6 7.0 References

1. FederalRegister Notice of Availability published on December 17, 2010 (75 FR 79048).
2. TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation."
3. Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 0, May 1973

BSEP 11-0068 Enclosure 2 Markup of Technical Specification Pages - Unit 1

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Required primary B.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphere primary containment radioactivity monitoring atmosphere.

system inoperable.

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

Required Action and Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A(ý4not met. AND_

OR __ Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> All required leakage detection systems inoperable.

S S _______________

NOTE --------

C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Only applicable when the primary primary containment containment atmospheric atmosphere.

gaseous radiation monitor is the only OPERABLE monitor. AND C.2 Monitor RCS LEAKAGE Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Drywell floor drain sump by administrative means.

monitoring system inoperable. AND C.3 Restore drywell floor drain 7 days sump monitoring system to OPERABLE status.

______________________________ J Brunswick Unit 1 3.4-10 Amendment No. -gK

BSEP 11-0068 Enclosure 3 Typed Technical Specification Pages - Unit 1

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Required primary B.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphere primary containment radioactivity monitoring atmosphere.

system inoperable.

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

-NOTE---------- C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Only applicable when the primary primary containment containment atmosphere atmosphere.

gaseous radiation monitor is the only OPERABLE monitor. AND C.2 Monitor RCS LEAKAGE Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Drywell floor drain sump by administrative means.

monitoring system inoperable. AND C.3 Restore drywell floor drain 7 days sump monitoring system to OPERABLE status.

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

D.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR All required leakage detection systems inoperable.

Brunswick Unit 1 3.4-10 Amendment No. I

BSEP 11-0068 Enclosure 4 Typed Technical Specification Pages - Unit 2

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. Required primary B.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphere primary containment radioactivity monitoring atmosphere.

system inoperable.

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

-NOTE---------- C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Only applicable when the primary primary containment containment atmosphere atmosphere.

gaseous radiation monitor is the only OPERABLE monitor. AND C.2 Monitor RCS LEAKAGE Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Drywell floor drain sump by administrative means.

monitoring system inoperable. AND C.3 Restore drywell floor drain 7 days sump monitoring system to OPERABLE status.

D. Required Action and associated Completion Time D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> II of Condition A, B, or C not AND met. I D.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR All required leakage detection systems inoperable.

Brunswick Unit 2 3.4-10 Amendment No. I

BSEP 11-0068 Enclosure 5 Marked-up Technical Specification Bases Pages - Unit I (For Information Only)

RCS Leakage Detection Instrumentation B 3.4.5 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 RCS Leakage Detection Instrumentation BASES _J.. - 0)

BACKGROUND The UFSAR (Ref. 1), rquires means for detecting RCS LEAKAGE.

Regulatory Guide 1.45'(Ref. 2) describes acceptable methods for selecting leakage detection systems.

Limits onnLAAEfo LEAKAGE from the reco oln reactor coolant rssr pressure onay(CB (RCPB) boundary

"-*. Limi~~~ts the are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref. 2). Leakage detection systems for the RCS

> 7* are provided to alert the operators when LEAKAGE rates above normal 4* ';z, V) - background levels are detected and also to supply quantitative measurement of LEAKAGE rates. The Bases for LCO 3.4.4, "RCS J.-* N \ Operational LEAKAGE," discuss the limits on RCS LEAKAGE rates.

,-.* _*

  • Systems for separating the LEAKAGE of an identified source from an

_ , *' --- *unidentified i source are necessary to provide prompt and quantitative

Ž;

P *information to the operators to permit them to take corrective action.

,. W -, LEAKAGE from the RCPB inside the drywell is detected by at least one of

- A' two independently monitored variables, such as drywell floor drain sump flow changes and drywell gaseous or particulate radioactivity levels. The

- " primary means of quantifying LEAKAGE in the drywell is the drywell floor

- , , drain sump flow monitoring system.

The drywell floor drain sump flow monitoring system monitors the

" LEAKAGE collected in the floor drain sump. This unidentified LEAKAGE

" "'* r consists of LEAKAGE from control rod drives, valve flanges, floor drains, the Reactor Building Closed Cooling Water System, and drywell cooler drains, and any LEAKAGE not collected in the drywell equipment drain sump. The drywell floor drain sump is provided with two sump pumps.

A flow transmitter in the common discharge line of the drywell floor drain sump pumps inputs to a flow integrator. In addition to the required instrumentation, the starting frequency and run duration of a sump pump motor are monitored by timer circuitry to provide a signal (alarm) in the control room indicating that LEAKAGE has reached a specified limit.

(continued)

Brunswick Unit 1 B 3.4.5-1 Revision No. 31 I

RCS Leakage Detection Instrumentation B 3.4.5 BASES BACKGROUND The primary containment atmosphere radioactivity monitoring systems (continued) (particulate and gaseous) continuously monitor the primary con ent atmosphere for airborne Darticulate, an gaeous radioactivi*Th

  • men . met eapl oF,,&,

-_:o.Ssg elms*r.

ifiatiy inces of radkoac;wt:y, whic may be attributed to a sudden increase in RCPB steam or reactor water LEAKAGE, is annunciated in the control room.

APPLICABLE A threat of significant compromise to the RCPB exists if the barrier SAFETY ANALYSES contains a crack that is large enough to propagate rapidly. LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted fro

.. A',<ACE ',cs -th.-. the establi:s~hed LEAKGErtei*.samlpuvdimg Elprcfrlffta E118Fm EInd/cr indiccticn of cxer, E..AKAGE! irmthe ee.!`tc* 8.1 A control room alarm/indication allows the operators to evaluate the significance of the indicated LEAKAGE and, if necessary, shut down the reactor for further investigation and corrective action. The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Ref. 5). Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii) (Ref. 6).

LCO T!l 0, le C d ic l ufI, yv. 11l. W-a-- d .-. i;t. 0 flo ~

requirod to quantify the tim;demtbfied LEAKAGE froi ii ! i Re5. Tim~

rCO uired do'ow-l fiOr drai cm on 99W mHitring Gym Gflo itf,,r, ymons-"

inludes the floW trnasmitter and integrator, as well as a flow totelio..

litEone ohgn~ncl of the othor ,montorinFgsystems (pc,"tieulctc r ,Fgeo) .

rodo',y a.',.,-s to the eperoters so ',.r , ,aminatin of stlher d t..ti .d. 6e m.

.nsystems will ... . t t..... i.... th... t.. . .

may be rcquirod. With the leage doteotio. sy(toen actonthiat tne i*RoporalolE, mon~itOR9n forI EAKAGE: in the PC'12P is deciradcd (continued)

Brunswick Unit 1 B 3.4.5-2 Revision No. 31 I

Insert 1 This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires two instruments to be OPERABLE.

The drywell floor drain sump monitoring system is required to quantify the unidentified LEAKAGE rate from the RCS. Thus, for the system to be considered OPERABLE, the flow transmitter and integrator, as well as a flow totalizer, must be OPERABLE and capable of determining the leakage rate. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell floor drain sump and it may take longer than one hour to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the primary containment, can be detected by the gaseous or particulate primary containment atmosphere radioactivity monitor. Only one of the two detectors is required to be OPERABLE. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate primary containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation. However, the gaseous or particulate containment primary atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the drywell floor drain sump monitoring system, in combination with a gaseous or particulate primary containment atmosphere radioactivity monitor, provides an acceptable minimum.

RCS Leakage Detection Instrumentation B 3.4.5 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4.

ACTIONS A.1 With the drywell floor drain sump flow monitoring system inoperable, no other required instrumentation can provide the equivalent information to quantify LEAKAGE. However, the primary containment atmosphere radioactivity monitor will provide indication of changes in LEAKAGE.

With the drywell floor drain sump flow monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (SR 3.4.4.1), operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available.

B.1 and B.2 With both gaseous and particulate primary containment atmosphere radioactivity monitoring channels inoperable (i.e., the required primary containment atmosphere monitoring system), grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic LEAKAGE information. Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the plant may be operated for up to 30 days to allow restoration of at least one of the required monitors.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available.

If any Required Action and associated Completion Time of Condition A cannot be met, or with all required monitors inoperable, the plant Cý I ust be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems.

I (continued)

Brunswick Unit 1 B 3.4.5-3 Revision No. 43 I

Insert 2 C.1, C.2, and C.3 With the drywell floor drain sump monitoring system and the primary containment atmosphere particulate monitor inoperable, the only means of detecting LEAKAGE is the primary containment atmosphere gaseous radioactivity monitor. A Note clarifies this applicability of the Condition. The primary containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within one hour when RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the primary containment atmosphere must be taken and analyzed and monitoring of RCS leakage by administrative means must be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to provide alternate periodic information.

Administrative means of monitoring RCS leakage include monitoring and trending parameters that may indicate an increase in RCS leakage. There are diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. It is not necessary to utilize all of these methods, but a method or methods should be selected considering the current plant conditions and historical or expected sources of unidentified leakage. The administrative methods are drywell pressure, drywell temperature, Reactor Building Closed Cooling Water (RBCCW) system cooling water temperature to and from the primary containment atmosphere coolers, and reactor water level. These indications, coupled with the atmosphere grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified LEAKAGE.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

RCS Leakage Detection Instrumentation B 3.4.5 BASES (continued)

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere radioactivity monitoring system. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.5.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies, for the radioactivity monitoring channels only, the required alarm function of the instrument string. A source check along with a channel check will be used to determine the relative accuracy of the instrument. Failure of the source check not attributed to an instrument indication problem (e.g., problem with source check mechanism and not the detector), would not immediately result in instrument inoperability. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 3.4.5.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 24 months is consistent with the Brunswick refueling cycle and considers channel reliability. Operating experience has proven this Frequency is acceptable.

REFERENCES 1. UFSAR, Section 5.2.5.

2. Regulatory Guide 1.45, May 1973.
3. GEAP-5620, Failure Behavior in ASTM A106B Pipes Containing Axial Through-Wall Flaws, April 1968.
4. NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping in Boiling Water Reactors, October 1975.
5. UFSAR, Section 5.2.5.2.2.
6. 10 CFR 50.36(c)(2)(ii).

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Brunswick Unit 1 B 3.4.5-4 Revision No. 52 1

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