Text

Request for License Amendment - Technical Specification 3.7.4, Control Room Air Conditioning (AC) System
	ML18242A395
Person / Time
Site:	Brunswick
Issue date:	08/30/2018
From:	William Gideon; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-18-0135
	Download: ML18242A395 (31)
	v • d • e

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 August 30, 2018 Serial: RA-18-0135 10 CFR 50.90 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 Request for License Amendment - Technical Specification 3.7.4, Control Room Air Conditioning (AC) System Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC (Duke Energy), is requesting an amendment associated with Technical Specification (TS) 3.7.4, Control Room Air Conditioning (AC) System, for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed change adds new Required Actions (RAs) and Completion Times (CTs) for three inoperable Control Room air conditioning (AC) subsystems.

BSEP has three 50 percent capacity AC subsystems versus the two 100 percent capacity AC subsystems assumed in NUREG-1433, Standard Technical Specifications General Electric BWR/4 Plants. At present, the BSEP TSs require entry into Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with three inoperable Control Room AC subsystems. The proposed BSEP RAs and CTs for three inoperable subsystems are consistent with the corresponding RAs and CTs in Technical Specification Task Force (TSTF) change traveler TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems, for two inoperable Control Room AC subsystems.

The Enclosure provides a description and assessment of the proposed change. Attachments 1 and 2 to the enclosure provide the existing TS pages, for Units 1 and 2, marked to show the proposed change. Attachments 3 and 4 provided revised (i.e., typed) TS pages. Attachment 5 provides existing Unit 1 TS Bases pages marked to show the proposed changes for information only.

Approval of the proposed amendment is requested within one year of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 120 days.

In accordance with 10 CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

This document contains no new regulatory commitments. Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.

U.S. Nuclear Regulatory Commission Page 2 of 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on August 30, 2018.

s~°Zj William R. Gideon MAT/mat

Enclosure:

cc:

Description and Assessment of the Proposed Change : Proposed Technical Specification Changes (Mark-Up) - Unit 1 : Proposed Technical Specification Changes (Mark-Up) - Unit 2 : Revised (Typed) Technical Specification Pages - Unit 1 : Revised (Typed) Technical Specification Pages - Unit 2 : Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only)

U. S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Dennis J. Galvin 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, 111, 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

RA-18-0135 Enclosure Page 1 of 9 Description and Assessment of the Proposed Change

Subject:

Request for License Amendment - Technical Specification 3.7.4, Control Room Air Conditioning (AC) System

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3.

TECHNICAL EVALUATION

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5.

ENVIRONMENTAL CONSIDERATION

6.

REFERENCES ATTACHMENTS:

1.

Proposed Technical Specification Changes (Mark-Up) - Unit 1

2.

Proposed Technical Specification Changes (Mark-Up) - Unit 2

3.

Revised (Typed) Technical Specification Pages - Unit 1

4.

Revised (Typed) Technical Specification Pages - Unit 2

5.

Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only)

RA-18-0135 Enclosure Page 2 of 9

1.

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC (Duke Energy), is requesting an amendment associated with Technical Specification (TS) 3.7.4, Control Room Air Conditioning (AC) System, for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The proposed change adds new Required Actions (RAs) and Completion Times (CTs) for three inoperable Control Room air conditioning (AC) subsystems.

BSEP has three 50 percent capacity AC subsystems versus the two 100 percent capacity AC subsystems assumed in NUREG-1433, Standard Technical Specifications General Electric BWR/4 Plants. At present, the BSEP TSs require entry into Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with three inoperable Control Room AC subsystems. The proposed BSEP RAs and CTs for three inoperable subsystems are consistent with the corresponding RAs and CTs in Technical Specification Task Force (TSTF) change traveler TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems (i.e., Reference 1), for two inoperable Control Room AC subsystems.

2.

DETAILED DESCRIPTION 2.1 System Design and Operation The Control Building Heating, Ventilation, and Air Conditioning system consists of individual once-through ventilation subsystems, a recirculating ventilation subsystem (i.e., the Control Room AC system), and an emergency air filtering subsystem. Redundant ventilating, air conditioning and emergency filtering equipment is provided to ensure proper environmental conditions within the Control Room, Computer Rooms, Electronic Equipment Rooms, and Electronic Workrooms. Various system supply fans draw outside air into the Control Building through two tornado pressure check valves. The air is then filtered by the supply plenum air filter and distributed to the various ventilation subsystems.

The Control Room AC system consists of three 50 percent capacity subsystems that provide cooling of recirculated Control Room air and outside air. Each manually controlled subsystem consists of a heating coil, a cooling coil, a supply fan, a compressor condenser unit, ductwork, dampers, and instrumentation and controls to provide temperature and humidity control for the Control Room during normal and accident conditions. The Control Room AC system make-up air and recirculated air are constantly filtered by the recirculation air filter to remove dust, smoke and other particles that may be present in the air. From the recirculation air filter, the air is routed to the air conditioning cooling coils. Control Room AC system is capable of handling the large concentrated heat gains from the computers and electronic equipment, as well as the variable heat gains from personnel and lighting. Individual heating coils are located in the discharge ducting of each air conditioning unit cooling coil to aid in temperature control. After conditioning, the air is directed to the suction of the three recirculating ventilation supply fans (i.e., one serves as a spare). The air discharged by the fans is routed to the Control Room area where it is dispersed to the various rooms. The air is then recirculated and conditioned for reuse.

The Control Room AC system is designed to provide a controlled environment under both normal and accident conditions. Two of the three subsystems provide the required temperature control to maintain a suitable Control Room environment for a sustained occupancy of 30 persons. The normal design conditions for the Control Room environment are 75 degrees F and 50 percent relative humidity.

RA-18-0135 Enclosure Page 3 of 9 The design basis of the Control Room AC system is to maintain the Control Room temperature for a 30-day continuous occupancy following a design basis event. The Control Room AC system components are arranged in redundant subsystems. During emergency operation, the Control Room AC system maintains a habitable environment and ensures the operability of components in the Control Room. A single failure of an active component of the Control Room AC system, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. The Control Room AC system is capable of removing sensible and latent heat loads from the Control Room, including consideration of equipment heat loads and personnel occupancy requirements to ensure equipment operability.

2.2 Current Technical Specification Requirements Currently, BSEP TS 3.7.4, Condition E, addresses the loss of three Control Room AC subsystems when in Mode 1, 2, or 3. Required Action E.1 specifies that the unit be placed in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

2.3 Reason for the Proposed Change The proposed change incorporates the TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems, RAs and CTs for two inoperable Control Room AC subsystems (i.e., NUREG-1433, TS 3.7.5 Condition B, for no operable Control Room AC subsystems) to an equivalent condition for BSEP (i.e., a new Condition C for three inoperable Control Room AC subsystems). In addition, this change potentially avoids unnecessary plant shutdowns by providing sufficient time to restore Control Room AC subsystems provided Control Room temperature is verified to be less than 90 degrees F every four hours.

2.4 Description of the Proposed Change The following table compares the proposed BSEP changes to those provided in TSTF-477, Revision 3. The proposed changes are applicable to BSEP TS 3.7.4, Control Room Air Conditioning (AC) System, which corresponds to NUREG-1433 TS 3.7.5, Control Room Air Conditioning (AC) System.

TSTF-477, Revision 3 Change Proposed BSEP Change Discussion Add new Condition B for two Control Room AC subsystems inoperable. Operation may continue for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided control room area temperature is verified to be < 90F once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Add new Condition C for three Control Room AC subsystems inoperable. Operation may continue for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided control room area temperature is verified to be < 90F once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

BSEP has three 50 percent capacity AC subsystems versus the two 100 percent capacity AC subsystems assumed in NUREG-1433.

The changes are essentially equivalent. Both the approved TSTF-477 change and the proposed BSEP change allow operation with no control room AC subsystems in operation provided control room area temperature is verified to be

< 90F once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

TSTF-477, Required Action B.2, restores one 100 percent

RA-18-0135 Enclosure Page 4 of 9 TSTF-477, Revision 3 Change Proposed BSEP Change Discussion capacity AC subsystem to operable status in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Similarly, BSEP proposed Action C.2, restores two 50 percent capacity AC subsystems to operable status in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In both cases, 100 percent capacity is restored in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Re-number Conditions B and C and associated Required Actions, because of adding new Condition B.

Re-number Conditions C and D and associated Required Actions, because of adding new Condition C.

BSEP has an existing Condition C, dealing with two inoperable Control Room AC subsystems.

The changes are essentially equivalent and are purely administrative in nature.

Included reference to new Condition B in re-numbered Condition C.

Included reference to new Condition C in re-numbered Condition D.

TSTF-477 Condition C and Condition D in the proposed BSEP change require the unit to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if Control Room AC subsystems are not restored to operable status within applicable Completion Times.

Note that both NUREG-1433, Revision 4 and the BSEP TS reflect implementation of TSTF-423, Technical Specifications End States, NEDC-32988-A. (i.e.,

References 2 and 3)

Deleted existing Condition D and associated Required Action to enter Limiting Condition for Operation (LCO) 3.0.3 when two Control Room AC subsystems are inoperable with the unit in Mode 1, 2, or 3.

Deleted Condition E and associated Required Action to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when three Control Room AC subsystems are inoperable with the unit in Mode 1, 2, or 3.

The changes are essentially equivalent. The deleted existing Conditions being replaced by the new Condition B (i.e., in TSTF-477) and Condition C (i.e.,

in the BSEP proposed change).

Conditions C and D (i.e., in TSTF-477 and the BSEP proposed change, respectively) maintain the requirement to be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if Control Room AC subsystems are not restored to operable status within applicable Completion Times.

RA-18-0135 Enclosure Page 5 of 9 TSTF-477, Revision 3 Change Proposed BSEP Change Discussion Revised Condition E to require entry when the Required Actions and associated Completion Times of new Condition B are not met.

Revised Condition F to require entry when the Required Actions and associated Completion Times of new Condition C are not met.

The changes are essentially equivalent. In both cases, failure to restore 100 percent AC capacity within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months results in immediate suspension of movement of irradiated fuel in secondary containment and core alterations.

Note that TSTF-542, Reactor Pressure Vessel Water Inventory Control, has been approved for BSEP (i.e., Reference 4).

Therefore, Required Actions associated with operations with the potential to drain the reactor vessel (OPDRVs) have been removed from the BSEP TSs.

3.

TECHNICAL EVALUATION Although BSEP is proposing a site-specific license amendment request, the regulatory precedent and technical justifications provided in TSTF-477, Revision 3, regarding the adequacy of maintaining Control Room temperature less than 90 degrees F with less than 100 percent Control Room AC capacity available are applicable to BSEP. TSTF-477, Revision 3, states:

The requirement to monitor control room temperature ensures the environment for the control room equipment is maintained with[in] the design limits. Provided that temperature may be maintained within the design limits, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore one [control room AC] subsystem for the BWR/4 plants. The 72-hour Completion Time is reasonable considering that control room temperature is being maintained within limits and the low probability of an event occurring that would require control room isolation.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is more conservative than the approved Completion Times for the BWR/6 plants and more conservative than other similar Conditions in the ISTS.

Alternate methods of maintaining control room temperature, such as non-safety grade air conditioning systems or fans, can also be used to maintain control room temperature.

This discussion is equally applicable to the proposed BSEP change. As previously mentioned, BSEP has three 50 percent capacity AC subsystems versus the two 100 percent capacity AC subsystems assumed in NUREG-1433 and TSTF 477, Revision 3. Consistent with TSTF-477, the proposed BSEP change establishes a 72-hour Completion Time for restoring two Control Room AC subsystems to operable status if three subsystems are inoperable. In addition, the proposed BSEP change maintains the existing 72-hour Completion Time of TS 3.7.4 Required Action B.2 for two inoperable Control Room AC subsystems. As such, the total Completion Time to restore 100 percent Control Room AC capacity is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , consistent with TSTF-477.

TSTF-477, Revision 3, also contains the following discussion regarding Topical Report NEDC 31336 PA.

RA-18-0135 Enclosure Page 6 of 9 Topical Report NEDC 31336 PA, "General Electric Instrument Setpoint Methodology,"

states that the error allowance for control room in-cabinet temperatures is 40 -

104 degrees F for BWR/6 plants and 40 to 156 degrees F for BWR/4 plants. The qualified life of the panel components (as an example, Rosemount 710 DU trip units) is dependent on the continuous ambient temperature at the installation site, from a maximum life of over 30 years for approximately 95-degree temperatures to just over two years for continuous ambient temperatures over 150 degrees. The temperature rise in closed control room trip panels is 14 to 18 degrees. With control room temperature controlled at less than 90 degrees, the maximum control room panel temperature would be less than the qualification temperature and would be within the temperature assumed in the setpoint accuracy calculations. This Traveler does not change the equipment qualification temperature in the control room. Therefore, the equipment enclosed in the cabinets is unaffected by this change.

The model Safety Evaluation for TSTF-477, Revision 3 (i.e., Reference 5) states.

Maintaining the CR Temperature < 90 degrees assures that the Safety Related Equipment in the CR will remain within the original licensed design operating temperature, because the maximum allowable CR Temperature is unchanged by TSTF-477. The NRC staff finds that the proposed changes in TSTF-477 are acceptable for the BWR/4 because the TSTF-477 changes provide TS requirements that the CR Temperature will be maintained within the original licensed design operating temperature of the CR equipment The above discussions are applicable to the BSEP change. The proposed change for BSEP does not change the equipment qualification temperature in the control room and maintains a maximum allowable ambient Control Room temperature of 90 degrees F when all control room AC subsystems are inoperable. This is consistent with the guidance provided in the NRCs clarification letter dated December 21, 2007 (i.e., ADAMS Accession Number ML073240051).

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 "Technical specifications," establish the requirements related to the content of the TS. Section 50.36(c)(2) states:

Limiting conditions for operation. Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The regulatory requirements in 10 CFR 50.36 are not specific regarding the actions to be followed when TS requirements are not met other than a plant shut down. The proposed change provides remedial actions in the TSs to be followed when the Limiting Condition for Operation is not met. Therefore, the proposed change is consistent with the requirements of 10 CFR 50.36.

The BSEP design was reviewed for construction under the General Design Criteria for Nuclear Power Plant Construction, issued for comment by the AEC in July 1967 and is committed to

RA-18-0135 Enclosure Page 7 of 9 meet the intent of the General Design Criteria (GDC), published in the Federal Register on May 21, 1971, as Appendix A to 10 CFR Part 50.

GDC 19, Control Room, requires that a Control Room be provided from which action can be taken to operate the nuclear reactor safely under normal conditions and to maintain the reactor in a safe condition under accident conditions, including a loss-of-coolant accident (LOCA).

Adequate radiation protection is to be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of specified values. The proposed change does not affect BSEP's compliance with the intent of GDC 19.

Therefore, based on the considerations discussed above, Duke Energy has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the TS, and does not affect conformance with the intent of any GDC differently than described in the Updated Final Safety Analysis Report.

4.2 Precedent The regulatory precedent and technical justifications provided in TSTF-477, Revision 3, regarding the adequacy of maintaining Control Room temperature less than 90 degrees F with less than 100 percent Control Room AC capacity available are applicable to BSEP (i.e.,

Reference 1).

The requested LAR is similar to amendments approved for Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2, dated December 10, 2014 (i.e., Reference 6), which also has three Control Room AC subsystems.

4.3 No Significant Hazards Consideration Determination Analysis Duke Energy Progress, LLC (Duke Energy), is requesting an amendment associated with Technical Specification (TS) 3.7.4, Control Room Air Conditioning (AC) System, for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed change adds new Required Actions (RAs) and Completion Times (CTs) for three inoperable Control Room air conditioning (AC) subsystems.

Duke Energy has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 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 does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The proposed change adds new RAs and CTs for three inoperable Control Room AC subsystems. The equipment qualification temperature of the control room equipment is not affected. Future changes to the Bases or licensee-controlled document will be evaluated pursuant to the requirements of 10 CFR 50.59, Changes, tests and experiments, to ensure that such changes do not

RA-18-0135 Enclosure Page 8 of 9 result in more than a minimal increase in the probability or consequences of an accident previously evaluated.

The proposed change does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the way the plant is operated and maintained. The proposed change does not adversely affect the ability of structures, systems and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed change does not affect the source term, containment isolation, or radiological consequences of any accident previously evaluated. Further, the proposed change does not increase the types and the amounts of radioactive effluent that may be released, nor significantly increase individual or cumulative occupation/public radiation exposures.

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

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 adds new RAs and CTs for three inoperable Control Room AC subsystems. The change does not involve a physical altering of the plant (i.e., no new or different type of equipment will be installed) or a change in methods governing normal pant operation. The proposed TSs continue to require maintaining the control room temperature within the design limits.

Therefore, the proposed amendments do 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 adds new RAs and CTs for three inoperable Control Room AC subsystems. Instituting the proposed change will continue to maintain the control room temperature within design limits. Changes to the Bases or licensee-controlled document are performed in accordance with 10 CFR 50.59. This approach provides an effective level of regulatory control and ensures that the control room temperature will be maintained within design limits.

Therefore, the proposed amendments do not result in a significant reduction in the margin of safety.

Based on the above, Duke Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

RA-18-0135 Enclosure Page 9 of 9 4.4 Conclusion 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 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.

5.

ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 amendment 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 amendment.

6.

REFERENCES

1. TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems

2. TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A, dated December 22, 2009 (ADAMS Accession No. ML093570241)

3. Letter from Andrew Hon (NRC) to William Gideon (Duke Energy), Brunswick Steam Electric Plant (BSEP), Units 1 and 2 - Issuance of Amendments to Adopt TSTF-423, Technical Specifications End States, NEDC-32988-A, dated August 29, 2017 (ADAMS Accession No. ML17180A596)

4. Letter from Andrew Hon (NRC) to William Gideon (Duke Energy), Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated April 13, 2018 (ADAMS Accession No. ML18039A444)

5. NRC Model Safety Evaluation Report, 71 FR 75774, dated December 18, 2006

6. Letter from Robert Martin (NRC) to C. R. Pierce (Southern Nuclear), Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Control Room Air Conditioning System, dated December 10, 2014 (ADAMS Accession No. 14279A261)

RA-18-0135 Enclosure Proposed Technical Specification Changes (Mark-Up) -

Unit 1

Control Room AC System 3.7.4 Brunswick Unit 1 3.7-15 Amendment No. 283 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One control room AC subsystem inoperable.

A.1 Restore control room AC subsystem to OPERABLE status.

30 days B.

Two control room AC subsystems inoperable.

B.1 Restore one inoperable control room AC subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C.

Three control room AC subsystems inoperable.

C.1 Verify control room area temperature < 90°F.

AND C.2 Restore two control room AC subsystems to OPERABLE status.

Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours D C. Required Action and associated Completion Time of Condition A, B, or C B not met in MODE 1, 2, or 3.

D C.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Control Room AC System 3.7.4 Brunswick Unit 1 3.7-16 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E D. Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

E D.1 Place OPERABLE control room AC subsystem(s) in operation.

OR E D.2.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND E D.2.2 Suspend CORE ALTERATIONS.

Immediately Immediately Immediately E.

Three control room AC subsystems inoperable in MODE 1, 2, or 3.

E.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Control Room AC System 3.7.4 Brunswick Unit 1 3.7-17 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition C not met Three control room AC subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.

In accordance with the Surveillance Frequency Control Program

RA-18-0135 Enclosure Proposed Technical Specification Changes (Mark-Up) -

Unit 2

Control Room AC System 3.7.4 Brunswick Unit 2 3.7-15 Amendment No. 311 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One control room AC subsystem inoperable.

A.1 Restore control room AC subsystem to OPERABLE status.

30 days B.

Two control room AC subsystems inoperable.

B.1 Restore one inoperable control room AC subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C.

Three control room AC subsystems inoperable.

C.1 Verify control room area temperature < 90°F.

AND C.2 Restore two control room AC subsystems to OPERABLE status.

Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours D C. Required Action and associated Completion Time of Condition A, B, or C B not met in MODE 1, 2, or 3.

D C.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Control Room AC System 3.7.4 Brunswick Unit 2 3.7-16 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E D. Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

E D.1 Place OPERABLE control room AC subsystem(s) in operation.

OR E D.2.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND E D.2.2 Suspend CORE ALTERATIONS.

Immediately Immediately Immediately E.

Three control room AC subsystems inoperable in MODE 1, 2, or 3.

E.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Control Room AC System 3.7.4 Brunswick Unit 2 3.7-17 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition C not met Three control room AC subsystems inoperable during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.

In accordance with the Surveillance Frequency Control Program

RA-18-0135 Enclosure Revised (Typed) Technical Specification Pages -

Unit 1

Control Room AC System 3.7.4 Brunswick Unit 1 3.7-15 Amendment No. 283 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One control room AC subsystem inoperable.

A.1 Restore control room AC subsystem to OPERABLE status.

30 days B.

Two control room AC subsystems inoperable.

B.1 Restore one inoperable control room AC subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C.

Three control room AC subsystems inoperable.

C.1 Verify control room area temperature < 90°F.

AND C.2 Restore two control room AC subsystems to OPERABLE status.

Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours D.

Required Action and associated Completion Time of Condition A, B, or C not met in MODE 1, 2, or 3.

D.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Control Room AC System 3.7.4 Brunswick Unit 1 3.7-16 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

E.1 Place OPERABLE control room AC subsystem(s) in operation.

OR E.2.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND E.2.2 Suspend CORE ALTERATIONS.

Immediately Immediately Immediately (continued)

Control Room AC System 3.7.4 Brunswick Unit 1 3.7-17 Amendment No. 283 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition C not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.

In accordance with the Surveillance Frequency Control Program

RA-18-0135 Enclosure Revised (Typed) Technical Specification Pages -

Unit 2

Control Room AC System 3.7.4 Brunswick Unit 2 3.7-15 Amendment No. 311 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Three control room AC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One control room AC subsystem inoperable.

A.1 Restore control room AC subsystem to OPERABLE status.

30 days B.

Two control room AC subsystems inoperable.

B.1 Restore one inoperable control room AC subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C.

Three control room AC subsystems inoperable.

C.1 Verify control room area temperature < 90°F.

AND C.2 Restore two control room AC subsystems to OPERABLE status.

Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours D.

Required Action and associated Completion Time of Condition A, B, or C not met in MODE 1, 2, or 3.

D.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Control Room AC System 3.7.4 Brunswick Unit 2 3.7-16 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and associated Completion Time of Condition A or B not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

E.1 Place OPERABLE control room AC subsystem(s) in operation.

OR E.2.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND E.2.2 Suspend CORE ALTERATIONS.

Immediately Immediately Immediately (continued)

Control Room AC System 3.7.4 Brunswick Unit 2 3.7-17 Amendment No. 311 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition C not met during movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS.

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

LCO 3.0.3 is not applicable.

F.1 Suspend movement of irradiated fuel assemblies in the secondary containment.

AND F.2 Suspend CORE ALTERATIONS.

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.

In accordance with the Surveillance Frequency Control Program

RA-18-0135 Enclosure Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only)

Control Room AC System B 3.7.4 Brunswick Unit 1 B 3.7.4-3 Revision No. 97 BASES (continued)

ACTIONS A.1 With one control room AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition, the remaining OPERABLE control room AC subsystems are adequate to perform the control room air conditioning function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystems could result in loss of the control room air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystems can provide the required protection, and the availability of alternate safety and nonsafety cooling methods.

B.1 With two control room AC subsystems inoperable, the Control Room AC System may not be capable of performing the intended function.

However, since the BNP control room is common to both Units 1 and 2, the risk associated with continued operation for a relatively short time could be less than that associated with an immediate controlled shutdown of both units. Therefore, additional time is allowed to restore one of the inoperable control room AC subsystems to OPERABLE status. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining the Control Room AC System OPERABLE. This time period also ensures that the probability of an accident (requiring Control Room AC System OPERABILITY) occurring during periods when two control room AC subsystems are inoperable is minimal.

C.1 and C.2 If three Control Room AC subsystems are inoperable, the Control Room AC System may not be capable of performing its intended function.

Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected. With the control room temperature being maintained within the temperature limit, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore two Control Room AC subsystems to OPERABLE status. This Completion time is reasonable considering that the control room temperature is being maintained within limits and the low probability of an event occurring requiring control room isolation.

CD.1 In MODE 1, 2, or 3, if Required Action A.1, or B.1, C.1, or C.2 cannot be completed within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(continued)

Control Room AC System B 3.7.4 Brunswick Unit 1 B 3.7.4-4 Revision No. 97 BASES ACTIONS CD.1 (continued)

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action CD.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

DE.1, DE.2.1, and DE.2.2 LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition D E are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS, if Required Action A.1 or B.1 cannot be completed within the associated Completion Time, the OPERABLE control room AC subsystem or subsystems may be placed immediately in operation. This action ensures that the remaining subsystem(s) is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action DE.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.

If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position.

(continued)

Control Room AC System B 3.7.4 Brunswick Unit 1 B 3.7.4-5 Revision No. 97 BASES ACTIONS E.1 (continued)

If three control room AC subsystems are inoperable in MODE 1, 2, or 3, the Control Room AC System may not be capable of performing the intended function. Therefore, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action E.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1 and F.2 LCO 3.0.3 is not applicable while in MODE 4 or 5. However, since irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown.

During movement of irradiated fuel assemblies in the secondary containment or during CORE ALTERATIONS, with three control room AC subsystems inoperable, if Required Actions C.1 and C.2 cannot be met within the required Completion Times, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.

(continued)

v t e Letter Sequence Request
EPID:L-2018-LLA-0232, (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2018-08-30 [Table View]

RA-18-0135, Request for License Amendment - Technical Specification 3.7.4, Control Room Air Conditioning (AC) System

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RA-18-0135, Request for License Amendment - Technical Specification 3.7.4, Control Room Air Conditioning (AC) System

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