ML19254E076

Issuance of Amendment Nos. 294 and 322 to Revise Technical Specification 3.7.4 for Control Room Air Conditioning Subsystems

ML19254E076
Person / Time
Site:	Brunswick
Issue date:	10/25/2019
From:	Dennis Galvin Plant Licensing Branch II
To:	Krakuszeski J Duke Energy Progress
Galvin D
References
EPID L-2018-LLA-0232
Download: ML19254E076 (21)

Text

Mr. John A. Krakuszeski Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd., SE (M/C BNP001)

Southport, NC 28461 UNITED STATES WASHINGTON, D.C. 20555-0001 October 25, 2019

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 294 AND 322 TO REVISE TECHNICAL SPECIFICATION 3.7.4 FOR CONTROL ROOM AIR CONDITIONING SUBSYSTEMS (EPID L-2018-LLA-0232)

Dear Mr. Gideon:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 294 and 322 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), respectively. These amendments are in response to your license amendment request dated August 30, 2018.

The amendments revise Technical Specification 3.7.4, "Control Room Air Conditioning (AC)

System," to add new required actions and completion times for the condition of all three control room AC systems being inoperable. The changes are consistent with the intent of Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-477, Revision 3, "Add Action for Two Inoperable Control Room AC Subsystems."

Brunswick differs from TSTF-477 with three 50 percent capacity control room AC system trains rather than two 100 percent trains, which is the assumed configuration.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 294 to DPR-71

2. Amendment No. 322 to DPR-62

3. Safety Evaluation cc: Listserv Sincerely, Dennis J. Galvin, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 294 Renewed License No. DPR-71

1.

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

A.

The application for amendment filed by Duke Energy Progress, LLC (the licensee), dated August 30, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 1 O CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

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

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 294, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION

~~

Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: October 25, 2019

ATTACHMENT TO LICENSE AMENDMENT NO. 294 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace page 6 of Renewed Facility Operating License No. DPR-71 with the attached revised page 6.

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page 3.7-15 3.7-16 3.7-17 Insert Page 3.7-15 3.7-16 3.7-17 (c)

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C.

This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal.

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 294, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 294

3. 7 PLANT SYSTEMS Control Room AC System 3.7.4

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 AL TERA TIONS.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A.

One control room AC A.1 Restore control room AC 30 days subsystem inoperable.

subsystem to OPERABLE status.

8.

Two control room AC 8.1 Restore one inoperable 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystems inoperable.

control room AC subsystem to OPERABLE status.

C.

Three control room AC C. 1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> subsystems inoperable.

temperature< 90°F.

AND C.2 Restore two control room 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AC subsystems to OPERABLE status.

D.

Required Action and D.1

---

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

associated Completion Time LCO 3.0.4.a is not of Condition A, B, or C not applicable when entering met in MODE 1, 2, or 3.

MODE 3.

Be in MODE 3.

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

Brunswick Unit 1 3.7-15 Amendment No. 294

ACTIONS (continued)

CONDITION REQUIRED ACTION Control Room AC System 3.7.4 COMPLETION TIME E.

Required Action and

---

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

associated Completion Time LCO 3.0.3 is not applicable.

of Condition A or B not met during movement of irradiated fuel assemblies in E.1 the secondary containment Place OPERABLE control Immediately or during CORE AL TERA TIONS.

Brunswick Unit 1 room AC subsystem(s) in operation.

E.2.1 Suspend movement of Immediately irradiated fuel assemblies AND E.2.2 in the secondary containment.

Suspend CORE ALTERATIONS.

3.7-16 Immediately (continued)

Amendment No. 294 I

Control Room AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION F.

Required Action and

---

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

associated Completion Time LCO 3.0.3 is not applicable.

of Condition C not met during movement of COMPLETION TIME irradiated fuel assemblies in F.1 the secondary containment Suspend movement of Immediately or during CORE AL TERA TIONS.

SURVEILLANCE REQUIREMENTS AND F.2 irradiated fuel assemblies in the secondary containment.

Suspend CORE AL TERA TIONS.

SURVEILLANCE SR 3. 7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.

Brunswick Unit 1 3.7-17 Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 294 I

UNITED STATES WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 322 Renewed License No. DPR-62

1.

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

A.

The application for amendment filed by Duke Energy Progress, LLC (the licensee), dated August 30, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act}, and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

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

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 322, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 120 days.

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: October 2 5, 2 O 1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 322 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace page 6 of Renewed Facility Operating License No. DPR-62 with the attached revised page 6.

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page 3.7-15 3.7-16 3.7-17 Insert Page 3.7-15 3.7-16 3.7-17 (c)

Transition license Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48( c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2,

• Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C.

This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59.of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

(2)

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 322, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 322

3. 7 PLANT SYSTEMS Control Room AC System 3.7.4 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 AL TERA TIONS.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A.

One control room AC A.1 Restore control room AC 30 days subsystem inoperable.

subsystem to OPERABLE status.

B.

Two control room AC B.1 Restore one inoperable 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystems inoperable.

control room AC subsystem to OPERABLE status.

C.

Three control room AC C.1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> subsystems inoperable.

temperature< 90°F.

AND C.2 Restore two control room 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AC subsystems to OPERABLE status.

D.

Required Action and D.1

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

associated Completion Time LCO 3.0.4.a is not of Condition A, B, or C not applicable when entering met in MODE 1, 2, or 3.

MODE 3.

Be in MODE 3.

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

Brunswick Unit 2 3.7-15 Amendment No. 322

ACTIONS (continued)

E.

CONDITION Required Action and associated Completion Time of Condition A or B not met during movement of REQUIRED ACTION Control Room AC System 3.7.4 COMPLETION TIME

---

NO TE---------------------

L CO 3.0.3 is not applicable.

irradiated fuel assemblies in E.1 the secondary containment Place OPERABLE control room AC subsystem(s) in operation.

Immediately or during CORE ALTERATIONS.

Brunswick Unit 2 OR E.2.1 Suspend movement of Immediately irradiated fuel assemblies AND E.2.2 in the secondary containment.

Suspend CORE ALTERATIONS.

3.7-16 Immediately (continued)

Amendment No. 322

Control Room AC System 3.7.4 ACTIONS (continued)

F.

CONDITION Required Action and associated Completion Time of Condition C not met during movement of REQUIRED ACTION

---

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

LCO 3.0.3 is not applicable.

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

or during CORE AL TERA TIONS.

AND F.2 Suspend CORE ALTERATIONS.

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

Brunswick Unit 2

3. 7-17 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. 322

UNITED STATES WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTS NOS. 294 AND 322 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62 DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By license amendment request (LAR) dated August 30, 2018 (Reference 1 ), Duke Energy Progress, LLC (the licensee), requested changes to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick).

The amendments would revise TS 3.7.4, "Control Room Air Conditioning (AC) System," to add new required actions and completion times for the condition of all three control room AC systems being inoperable. The changes would be consistent with the intent of Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-477, Revision 3, "Add Action for Two Inoperable Control Room AC Subsystems,"

(Reference 2). On March 26, 2007, the U.S. Nuclear Regulatory Commission (NRC) published in the Federal Register (72 FR 14143) a notice of availability of a model application related to the adoption of TSTF-477 and a model safety evaluation. The major difference from the TSTF is that Brunswick has three 50 percent capacity control room AC system trains rather than two 100 percent trains, which is the standard assumed configuration.

2.0

=

System Description===

As described in the LAR, the Brunswick, Units 1 and 2, control building heating, ventilation, and AC 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, AC, and emergency filtering equipment is provided to ensure proper environmental conditions within the shared control room, the 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 itself 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 makeup 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 AC cooling coils. The control room AC system can mitigate the large heat additions from the computers and electrical and electronic equipment, as well as the variable heat additions from personnel and lighting. Individual heating coils are located within the discharge ducting of each AC 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 distributed to the various rooms. Most of this 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 Fahrenheit (°F) and 50 percent relative humidity.

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 can remove 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 Description of the Proposed TS Changes The existing Brunswick, Units 1 and 2, TS 3.7.4 limiting condition for operation (LCO) requires three control room AC subsystems be operable when the plant is in Modes 1, 2, and 3, or when moving irradiated fuel in secondary containment or performing core alterations. TS 3.7.4 specifies that a condition of one control room AC subsystem being inoperable has a required action of restoring that subsystem's operability within 30 days. TS 3.7.4 specifies that a condition of two control room AC subsystems being inoperable has a required action of being in Mode 3 within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. TS 3.7.4 specifies that a condition of three control room AC subsystems being inoperable has a required action of being in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If either one or two control room AC subsystems are inoperable when moving irradiated fuel assemblies in secondary containment or performing core alterations, the operable control room subsystems are to be placed into operation immediately. If all three control room AC subsystems are inoperable when moving irradiated fuel assemblies in secondary containment or performing core alterations, then movement of irradiated fuel assemblies and core alterations are to be suspended immediately.

With the proposed Brunswick, Units 1 and 2, TS 3. 7.4 change, the condition of three control room AC subsystems being inoperable would allow continued plant operation in plant Modes 1 and 2 for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, so long as the control room area temperature is verified to be less than 90 °Fat least once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

2.3 Regulatory Requirements and Guidance The regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications." This regulation requires that the TSs include items in five specific categories. These categories include: (1) safety limits, limiting safety system settings and limiting control settings; (2) LCOs; surveillance requirements; (4) design features; and (5) administrative controls. More specifically, 10 CFR 50.36(c)(2)(i) states that, "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." Section 50.36 of 10 CFR does not specify which remedial actions are required or how quickly they must be completed.

The Brunswick 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 Federal Register on July 7, 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. Adequate radiation protection is to be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures more than specified values.

3.0 TECHNICAL EVALUATION

The LAR describes the proposed change as incorporating the intent of TSTF-477, Revision 3, required actions and completion times for two inoperable (no operable) control room AC subsystems (i.e., NUREG-1433, TS 3.7.5 Condition B (Reference 3)) to what would be an equivalent condition for Brunswick - a new condition C for three inoperable (no operable) control room AC subsystems. The proposed condition would be equivalent for Brunswick because Brunswick has three 50 percent capacity control room AC system trains rather than two 100 percent trains. The proposed change to allow a reasonable length of time to restore control room AC subsystems to operability before requiring a reactor shutdown avoids unnecessary plant transients and associated risk. During this new allowed completion time duration, plant risk is further mitigated by requiring the control room temperature to be verified less than 90 °F every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This verification ensures that the performance of electrical and electronic components in important plant parameter monitoring instrumentation and safety-related actuation systems remains reliable and predictable.

The allowances of TSTF-477, Revision 3, use the analysis in Topical Report NEDC-31336P-A, "General Electric Instrumentation Setpoint Methodology," which states that the error allowance for control room in-cabinet temperatures is40-104 °F for boiling water reactor (BWR)/6 plants and 40-156 °F for BWR/4 plants. The qualified life of the panel components is dependent on the continuous ambient temperature at the installation site from a maximum life of over 30 years for temperatures up to 95 °F to just over 2 years for continuous ambient temperatures over 150 °F. The temperature rise in closed control room trip panels is 14-18 °F. With control room ambient temperature controlled to less than 90 °F, the maximum control room panel temperature for Brunswick would be less than the qualification temperature and would be within the temperature assumed in the setpoint accuracy calculations and within the temperature range, assuring full equipment qualification lifespan.

The Brunswick, Units 1 and 2, TS LCO 3.7.4 remains the same. TS LCO 3.7.4 conditions would still have to be met, or the associated required actions taken accordingly within the specified completion times.

Section 50.36 of 1 O CFR does not specify which remedial actions are required or how quickly they must be completed, so the requested change remains consistent with this requirement.

The proposed change is also consistent with the intent of TSTF-477 in that the same completion time (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) will be allowed for the control room AC system loss of function, that is, when all three subsystems are inoperable in plant Modes 1 and 2. The required action to verify control room ambient temperature is the same as in TSTF-477 to ensure that the instrumentation in the control room area panels and cabinets would continue to perform predictably and reliably and incur no potential reduction in service lifespan.

The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff finds the requested change to add a limited completion time to TS LCO 3.7.4 for the condition of three control room AC subsystems being inoperable (loss of control room AC system function) is consistent with the intent of TSTF-477, and its justifications apply to Brunswick, Units 1 and 2. The NRC staff finds that based on the preceding regulatory and technical evaluations, the changes to TS 3.7.4 proposed in the LAR meet the applicable regulatory requirements, and thus, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the North Carolina State official was notified of the proposed issuance of the amendments on September 11, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on November 6, 2018 (83 FR 55571 ), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

7.0 REFERENCES

1. Gideon, William R., Duke Energy Progress, LLC, letter to U.S. Nuclear Regulatory Commission, "Brunswick Steam Electric Plant, Unit Nos. 1 and 2 - Request for License Amendment - Technical Specification 3.7.4, 'Control Room Air Conditioning (AC) System,"'

dated August 30, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18242A395).

2. Technical Specification Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF 477, Revision 3, "Add Action for Two Inoperable Control Room AC Subsystems," dated September 8, 2006 (ADAMS Accession No. ML062510321)

3. U.S. Nuclear Regulatory Commission, NUREG-1433, Revision 4, Volume 1, "Standard Technical Specifications - General Electric BWR/4 Plants: Specifications," dated April 2012 (ADAMS Accession No. ML12104A192).

Principal Contributor: Jerome Bettle Date: October 25, 2019

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 294 AND 322 TO REVISE TECHNICAL SPECIFICATION 3.7.4 FOR CONTROL ROOM AIR CONDITIONING SUBSYSTEMS (EPID L-2018-LLA-0232) DATED OCTOBER 25, 2019 DISTRIBUTION:

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