BSEP 16-0083, Steam Electric Plant, Units 1 And. 2 - Application to Revise Technical Specifications to Adopt TSTF-535, Revision O, Revise Shutdown Margin Definition to Address Advance Fuel Designs

Steam Electric Plant, Units 1 And. 2 - Application to Revise Technical Specifications to Adopt TSTF-535, Revision O, Revise Shutdown Margin Definition to Address Advance Fuel Designs

ML16343A521
Person / Time
Site:	Brunswick
Issue date:	11/18/2016
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 16-0083, TSC-2016-09
Download: ML16343A521 (13)

Text

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l;.i.s. NL!cie_at Regui~tory Comrnisslcm ATTN:: Documeril.Coiitrol Desk Wa!Shington, PC. 2QS§g"'.O,O'C)J Su!)ject~. Brun5wick steam Electric Plant, Unit Nos. 1 and. 2 R~newed F'acilitY operatJng License: Nos~ OPR~n and OPR-62 Docl<erNos. so;32s and so-324, Wlifiatn:ft~ Gideon

'vice.Presidenr

~ru-i\\s.~_~k;f\\J~~ieaiJ,1l!lfit P.O.BOx-10429:

• soutliport;.t-,tc:2~st

.o: 910;457:3698 1 O>CFR so; go

• AppljcatiC!n ~o*,0evis,e Te.choic~f_$p~qiflca~ionSi te>*Adopt;l'$Tr.;5?Si ~_eyjslon.*o, "Revise.Shutdown.Margin Definition to.Address' Advanced Fuel Desi_gns" P.ur$Ua:nt fo. fo. CFR ~-Q.90, buke Energy Progress, ~L.C (Duke Energy), is subn1itti:ng a requ:est

for: an amenament to the Technical SpeCifications (TS) for* Brunswick.Steam Electrii:: Planf*

(BSEP) Units 1.and 2, T_h~ prppo~~q-jimencj_rn_~rilrnpdifi~$ tl:l~ T$ de,iflipor1 of"Shu~down M~rgi11'.' (~D~l) to reqL1Jr~

calQulatibrt of tt:ie SOM t:it~: reactor rnoderato.r tei:npe_ratLJte..of 68°F, cwa bighenemp:er~ture* t!lat represents the most reactive state throughout ttie operating cycle. This clian9~--is nee'ded to,

• addre$s new aoiling Water t::i~~c.tor (13\\fi/R) fu~I d~signs_ whll::h may l>,e more, relJl.ciive at,

_shutdown temperatures above es0f=~ *

• Eric:le>sure j provides:.a: -d~*scriptlon and '~$s.essrne_n.t pf the P.te>Po$ed TS 'chang~.13-Enclosure 'g provides-the' existing TS pa~es marked-up. to shov:/tne proposed changes; Enclosure 3' provides reivisei;J (he~. fyp,e(;f) ts pag~i;.;

• J\\pp_ro:vi:it of.tile propqse_d ~11J~l'1drru~n\\* ;:mc:I relief requ~st:i~ requesfet:f _by JL1IY 1; 2P17*. Once approv.ed, tile amenc:tment_ shall.be frr1plemented Within 'go;days_.

In ElPC<:>r9anqewith: }Q ~fR 50~.~H;:a~ppy pf this appli.catipn,. with ~nck1sure$1 I$ being proVfc:lec:i

• to the.. desi_gnateCI Norin 'Carolina dfficiaL

U.S. Nuclear Regulatory Commission Page 2of3 If you should have any questions regarding this submittal, please contact Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

I declfiref under penalty of perjury, that the foregoing is true and correct. Executed on

\\I 1& lb

'2016.

Si~

William R. Gideon SWR/swr

Enclosures:

1. Description and Assessment of Technical Specifications Changes

2. Proposed Technical Specifications Changes (Mark-Up), BSEP Units 1 and 2

3. Revised Technical Specifications Pages, BSEP Units 1 and 2

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

U.S. Nuclear Regulatory Commission, Region II ATIN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATIN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATIN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) {Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 S Mail Service Center Raleigh, NC 21699-4300 swatson@ncuc.net

BSEP 16-0083 Description and Assessment of Technical Specifications Changes DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATIONS CHANGES

1.0 DESCRIPTION

The proposed amendment modifies the Technical Specifications (TS) definition of "Shutdown Margin" (SOM) to require calculation of the SOM at a reactor moderator temperature of 68"F, or a higher temperature that represents the most reactive state throughout the operating cycle.

This change is needed to address new Boiling Water Reactor (BWR) fuel designs which may be more reactive at shutdown temperatures above 68°F.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Quke Energy Progress, LLC (Duke Energy), has reviewed the model safety evaluation dated February 19, 2013, as part of the Federal Register Notice of Availability. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-535, Revision 0. As described in the subsequent paragraphs, Duke Energy has concluded that the justifications presented in the TSTF-535 proposal and the model safety evaluation prepared by the NRC staff are applicable to Brunswick Steam Electric Plant (BSEP) Unit 1 and Unit 2 and justify this amendment for the incorporation of the changes to the BSEP Unit 1 and Unit 2 TS.

2.2 Optional Changes and Variations Duke Energy is proposing the following variations from the TS changes described in the TSTF-535, Revision o, or the applicable parts of the NRC staff's model safety evaluation dated February 19, 2013.

The traveler and model safety evaluation discuss the applicable regulatory requirements and guidance, including the 1 O CFR 50, Appendix A, General Design Criteria (GDC).

BSEP Unit 1 and Unit 2 were not licensed to the 10 CFR 50, Appendix A, GDC. GDC 26 addresses reactivity control system redundancy and capability. GDC 27 addresses combined reactivity control systems capability. The BSEP equivalents of GDCs 26 and 27 are described in the Updated Final Safety Analysis Report (UFSAR), sections 3.1.2.3.7 and 3.1.2.3.8, respectively.

The BSEP UFSAR section 3.1.2.3. 7 addresses GDC 26 as follows:

Each reactor unit contains two independent reactivity control systems of different design principles. Control of reactivity is provided by a combination of movable control rods, burnable poison, and reactor coolant recirculation system flow. These systems are able to accommodate fuel burn up, load changes, and long term reactivity changes. Reactor shutdown by the Control Rod Drive (CRD) System is designed to be sufficiently rapid to prevent fuel damage limits from being exceeded during either normal operation or any operational transients. A Standby Liquid Control (SLC) System provides independent backup to the above reactivity controls.

The reactivity control system is designed to provide sufficient reactivity compensation under conditions of normal operation to make the reactor always subcritical from its most Page 1

reactive condition. Means are provided for continuously regulating the reactor core excess reactivity and reactivity distribution.

The BSEP UFSAR section 3.1.2.3.a* addresses GDC 27 as follows:

The BSEP boiling water reactors (BWR) will never require the combined capability of a poison addition system in addition to a control rod system. The reactivity control during postulated accidents is entirely by means of the Control Rod System with appropriate margin for a stuck rod; the pattern of rod usage is normally controlled through the rod worth minimizer program of the on-line computer. The reactivity control is aided by the inherent negative power coefficient of reactivity. A SLC System is provided as an independent backup shutdown system to cover emergencies in the operational reactivity control system. This system is designed to maintain the reactor in a safe shutdown condition.

A comparison of GDC 26 and 27 with the design features and controls used at BSEP Unit 1 and Unit 2 shows that the difference does not alter the conclusion that the proposed change as presented in TSTF-535, Revision 0, and the associated model safety evaluation is valid for BSEP Unit 1 and Unit 2.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Duke Energy requests adoption of TSTF-535, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," which is an approved change to the standard technical specifications (STS), into the BSEP Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendment modifies the TS definition of "Shutdown Margin" {SOM) to require calculation of the SOM at a reactor moderator temperature of 68°F, or a higher temperature that represents the most reactive state throughout the operating cycle.

Duke Energy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 1 o CFR 50.92, "Issuance of amendment," as discussed 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 revises the definition of SOM. SOM is not an initiator to any accident previously evaluated. Accordingly, the proposed change to the definition of SOM has no effect on the probability of any accident previously evaluated. SOM is an assumption in the analysis of some previously evaluated accidents; and inadequate SOM could lead to an increase in consequences for those accidents. However, the proposed change revises the SOM definition to ensure that the correct SOM is determined for all fuel types at all times during the fuel cycle. As a result, the proposed change does not adversely affect the consequences of any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page2

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 revises the definition of SDM. The 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 operations. The change does not alter assumptions made in the safety analysis regarding SDM.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change revises the definition of SOM. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The proposed change ensures that the SDM assumed in determining safety limits, limiting safety system settings or limiting conditions for operation is correct for all BWR fuel types at all times during the fuel cycle.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Duke Energy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10CFR50.92{c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusions In conclusion, based on the considerations discussed above, (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 Commission's 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the r~stricted area, as defined in 10 CFR 20, or woulp 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 effluents 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 1 O CFR 51.22{c)(9).

Therefore, pursuant to 1 O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Page3

Proposed Technical Specification Changes (Mark*Up)

BSEP Units 1 and 2 BSEP 16*0083

1.-1 befiriltiQn~ ~(continu~d)

OPERABLE-OPERABILITY RA TED THERMALPOWER (f1TP)

.REACTOR PROtECTION SYSTEM(RPS)RESPONSE TIME SHUTDOWN.MARGIN (SOM) throu hounhe

, 9,.......

~p.e.ra.Jlni;i c.yq!e

, corresponding

• to the most

• ,.. :r:~~cJi'.I~ $t;:ij~,.

Brunswick Unit 1 Definitions 1.1 A system, subsystern, division, component, or device shall be OpERABJ,.E or have OP1:8ABJLITY'wheo. it is capa!:>!e (}f performing its specified safety function(s) arid when all neces~_aryattendant fosfrumeritation; ccmirols, norm.~I or emergency electrical power, cooling and seal water; lu.bricatlPIJi.am:I pther aLJ><iliary equipm~nt that are r~ufred for the system, subsystem9.diVision,,comP<>nent, or device to per:form its $pecffled safety f.u11cfion'(s) are al.SQ. capabie of performing *their related si.Jpp'ort function(s).

ATP shall be a.total reaciorcore heattransfei' rate to 1he reactor coPlan) e>t 2~2~ Mw1~

Ttle RPS* 8i:SPONSE TIME shall be that time intervai-from when the monito*red parameter exceeds its RPS trip se,tpoirit af the channel sensor until de-enf;!rgization of the scram pilot valve so_lenoids. The response tiinEt may be measure~ by mea.ns of any series of s.equ~ntial,, overlapping, or total steps so that,the entire respon~~ time is measured.

SOM shall be the amc;11,mt of reaqtivity by which the reactor is.

~ubcritical _or we>uld b~_ ~~~cri~icaltssuming that:...

a.

~etearfsx~9nf~e; J~

b; The moderator temperature 1s 68°~ and

c.

AU control rods are fully inserted except for.the single QQlitrol.rod 9f.higtJest reactivity \\VOrfQ;. l{ihich is ~~~~IJJB.d to beJully withdrawn.

With.control rods nof c~pable of,being fµIJy inserted, the reactivity worth of these :Control rods must" be accoimted tor in the det~l'.l'Tliiiation of SOM.

(continued) l Amendment No. 222 I

1.1 DefJhi~ons (contjnued)

QPERABLE;.OPERABILiTY

. RA TED THERMAL PO.WEA (ATP)

REACTOR PROTECTION SYSTEM(RPS)RESPONSE TIME.

SHUTDOWN MARGIN (SOM)

• tl;lroughol,it. lllf3.

• ope.ratiil~ GYc::fe '

' i' corr~~pohding to tb.& mpst

-reactive state:

Brunswick ljnit g P.efiriii!ons 1.1 A system, subsystem; dlvisi9n, component, or d~vfce_ $haii be:

OPERABLE or have OPERABILITY when. it is cap'able of performing jt~ ~pecifieci. s~f~ty.funcJi.on(~) and when.. all necessar}i attendant lnstrumentadon *. controis, normal or e,mergency ele(:trical power, *Cooling a[ld seal Water, lµbrfoation,~ and other auxiliary equipmenfthat are requited f()r the systern,,subsystem, diVisiori, comp*anent, or device to Perfor:rn. i~~ specif.ie9.*~afefy. funct_ion(s) areJ~lso. c.aPalJle* of.

• performing_ their r:elatedsupport fl:Jnction(s).

ATP shall be a total reactor c9re heattransfer rate to the reactor:coolant of 2923. MWt.

The RPS flE:SPONSE TIME shall be.that tfrn~ interval frorn when the. monitored parameJer exceed~ its RPS trip setpoinJ

~tthe channel !:!ensor until de-energization of the $.Cr.am.p!lot valve solenoids. The response time *may be measured by, means c::>t ~ny se(ies* of s_equenti~I. overlapping, or,tota! ~teps so. that the entire response tlme is measured.

SOM sha!Lbe the am<;>l!nt of reactivity t)ywhlch the: rea-ctc:>r is subciitical or -would be sUbcriticaltas'surriing* that:

a..

Theotear ls~en free; c=:0 b;

Tu*e,:moder~tor temperature is 60°11 an~.

c.

All control roos *are fully inserted except for the single cp[ttrql ~q(J.of l:iigh~st rellctivity wort.h, which iE; a~su.m~~

to. b*edully. withdrawn.

W.itl:t con~rol rods not c~pable, of bei.ng fully inse~ed, the reactivity worff1 of the$e~confrol rods must be accounted for in the-determination at*soM.

(continued) 1.1-5 Ame11dro_ent No. 247 I

Revised Technical Specification Pages BSEP Units 1 and 2 BSEP 16-0035

1.1 Definitions (continued)

OPERABLE-0.PE8ABl~llY RATED THERMAL POWER.

(ATP)

REACTOR PROTECTION SYSTEM (RPS) RESPONS.E TIME SHUTDOWN MARGIN (SOM)

Brunswick Unit 1 Definitions 1.1 A sy$tem, subsystem, division; component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing.its specified safety fun~tion(s) and when an necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are requfred for the system, subsyste!Tl. ~ivision, component; or device to perform its specified. safety function(s) are also capable c;>f performing th~ir related support function(s).

ATP shall b~ a total reactor core heat tr~nsfer rate to the reactor coolant of 2923. MWt The RPS RESPONSE TIME shall be that time interval from when the monitored parameter.exceeds its RPS trip setpoint at the channel sensor until de.. energization of the scram pilot valve solenoids. The response time may be mea~ured by means of any series bf sequential, overlapping, or total steps so that the entire response time is m13asured;

.SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a.

The reactor is xenon free;

b.

The moderator temperature is::? 68°F, corresponding to the most reactive state; C\\nd

c.

All control rods are fl.llly inserted exc*ept for the single c.ontrol rod of highest reactivity worth~ which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounte.d for in the determination of SOM.

(continued) l.1-5 Amendment.No.

1.1 Definitions (continued)

OPERABLE-OPERABILITY RATED THERMAL POWER (ATP)

REACTOR PROTECTION SYSTEM(RPS)RESPONSE TIME SHUTDOWNMARGIN (SOM)

Brunswick Uriit 2 Definitions 1.1 A system, subsystem, division, compon_ent, or device shall be OPERABLE or have OPERABILITY when it is capable.of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are: reqµired for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of perfqrming their related support function(s).

ATP shall.be a total reactor core heat transfer rate to the reactor coolant of 2923 MWt.

The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exce.eds its RPS trip setpolnt at the channel sensor µntil de*energizatio('I of tne scr~r11 pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so tt:iat the enti(e response time. i$ meas1,m~d~

SOM shall_ be the amount of reactivity by which the reactor is subcriticai or would be subcritica:I throughout the operating cycle assuming that:

a.

The reactor is xenon free;

b.

The moderator temperature i_s ~ 68°F, corre:Sponding to the rrl'ost reactive state; and

c.

All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully with.drawn.

Withcorittol rods not capable of being fully inserted, tlie reactivity worth of'these control rods must be accounted for in the determination of SOM.

(continued) 1.1-5 Amendment No.