ML19281A330

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Issuance of Amendment Nos. 296 and 324 to Adopt Technical Specification Task Force Traveler TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification
ML19281A330
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/21/2019
From: Andrew Hon
Plant Licensing Branch II
To: Krakuszeski J
Duke Energy Progress
Hon, Andrew
References
EPID L-2018-LLA-0594
Download: ML19281A330 (20)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 21, 2019 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

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 296 AND 324 TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-269-A, REVISION 2, "ALLOW ADMINISTRATIVE MEANS OF POSITION VERIFICATION FOR LOCKED OR SEALED VALVES" (EPID L-2018-LLA-0594)

Dear Mr. Krakuszeski:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 296 and 324 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant, Units 1 and 2, respectively. These amendments are in response to your license amendment request dated December 14, 2018.

The amendments adopt Technical Specification Task Force (TSTF) Traveler TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves."

The amendments revise Technical Specification (TS) 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," Required Actions A.2 and C.2, and TS 3.6.4.2, "Secondary Containment Isolation Dampers (SCIDs), Required Action A.2, to add a note to allow isolation devices that are locked, sealed, or otherwise secured to be verified using administrative means.

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

s~ ~--

Andrew Hon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 296 to DPR-71
2. Amendment No. 324 to DPR-62
3. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION 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. 296 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 December 14, 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.

Enclosure 1

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. 296, 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.

FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 21 , 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 296 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 Insert Page 3.6-8 3.6-8 3.6-9 3.6-9 3.6-31 3.6-31

(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. 296, 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. 296

PCIVs 3.6.1.3 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 -------~-~NOTES-----~~----

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is for isolation devices isolated. outside primary containment Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)

Brunswick Unit 1 3.6-8 Amendment No. 296 I

PCIVs 3.6.1.3 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. --------------NO TE-------------- 8.1 Isolate the affected 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed twoPCIVs. and de-activated automatic


valve, closed manual valve, or blind flange.

One or more penetration flow paths with two PCIVs inoperable except for MSIV leakage not within limit.

C. -------------NOTE-------------- C.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one closed valves (EFCVs) only one PCIV. and de-activated automatic


valve, closed manual valve, AND or blind flange.

One or more penetration 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for EFCVs flow paths with one PCIV inoperable.

AND C.2 ------------NO TES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

(continued)

Brunswick Unit 1 3.6-9 Amendment No. 296 I

SCIDs 3.6.4.2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 ------------NOTES-----------~

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 92 days penetration flow path is isolated.

B. --------------NO TE--------------- 8.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed

  • two isolation dampers. and de-activated automatic

damper, closed manual damper, or blind flange.

One or more penetration flow paths with two SCIDs inoperable.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or B not met AND in MODE 1, 2, or 3.

C.2 Be in MODE4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Brunswick Unit 1 3.6-31 Amendment No. 296 I

UNITED STATES NUCLEAR REGULATORY COMMISSION 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. 324 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 December 14, 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.

Enclosure 2

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.324, 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.

FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 21 , 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 324 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 Insert Page 3.6-8 3.6-8 3.6-9 3.6-9 3.6-31 3.6-31

(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 iteins, 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) 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. 324, 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 Licens~ 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. 324

PCIVs 3.6.1.3 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 ------------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside primary containment Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)

Brunswick Unit 2 3.6-8 Amendment No. 324 I

PCIVs 3.6.1.3 A CTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. -------------NO TE-------------- 8.1 Isolate the affected 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two PCIVs. and de-activated automatic


valve, closed manual valve, or blind flange.

One or more penetration flow paths with two PCIVs inoperable except for MSIV leakage not within limit.

C. --------------NO TE------------- C.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one closed valves (EFCVs) only one PCIV. and de-activated automatic


valve, closed manual AND valve, or blind flange.

One or more penetration 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for flow paths with one PCIV AND EFCVs inoperable.

C.2 ------------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

(continued)

Brunswick Unit 2 3.6-9 Amendment No. 324 I

SCIDs 3.6.4.2 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 ------------NOTES-~----------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 92 days penetration flow path is isolated.

B. -------------NO TE----------------- B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two isolation dampers. and de-activated automatic


damper, closed manual damper, or blind flange.

One or more penetration flow paths with two SCIDs inoperable.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A or B not met AND in MODE 1, 2, or 3.

C.2 Be in MODE4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

Brunswick Unit 2 3.6-31 Amendment No. 324 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTS NOS. 296 AND 324 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 December 14, 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 or BSEP).

The LAR would revise TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs)," Required Actions A.2 and C.2, and TS 3.6.4.2, "Secondary Containment Isolation Dampers (SCIDs),"

Required Action A.2, to allow isolation devices that are locked, sealed, or otherwise secured to be verified by use of administrative means. The licensee stated that this change is consistent with Technical Specification Task Force (TSTF) Traveler TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves" (Reference 2). The U.S. Nuclear Regulatory Commission (NRC or the Commission) approved TSTF-269-A, Revision 2, in a letter dated July 26, 1999 (Reference 3).

2.0 REGULATORY EVALUATION

2.1 Description of the Proposed TS Changes The proposed change to TS 3.6.1.3 is to add the following note under Required Actions A.2 and C.2:

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

The proposed change to TS 3.6.4.2 is to add the following note under Required Action A.2:

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.

Enclosure 3

In addition, the previous note for these three required actions will be revised to "notes," and the existing note, "Isolation devices in high radiation areas may be verified by use of administrative means," is renumbered as Note 1.

The licensee also stated the following variance to TSTF-269-A:

TSTF-269 also modified Specification 3.6.1.3, Required Action E.2, which is optional in the Standard BWR [Boiling Water Reactor]/4 Technical Specifications (i.e., Reference 6.2). The equivalent of Condition E does not appear in the BSEP TSs. This variation does not affect the applicability of TSTF-269 to the proposed license amendments.

2.2 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, which 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) limiting conditions of operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. More specifically, the regulation in 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 NRC staff used Revision 4.0 of NUREG-1433, "Standard Technical Specifications, General Electric BWR/4 Plants," Volume 1 (Reference 4), "Specifications," and NUREG-1433, "Standard Technical Specifications, General Electric BWR/4 Plants, Volume 2, "Bases" (Reference 5) in its review of the TS changes proposed for Brunswick.

3.0 TECHNICAL EVALUATION

TSTF-269-A, Revision 2, revised STS 3.6.3, "Containment Isolation Valves (Atmospheric, Subatmospheric, Ice Condenser, and Dual)," by adding a note under Required Actions A.2, C.2, and E.2 that isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

The NRC staff has reviewed the proposed changes to TS 3.6.3.1 and TS 3.6.4.2 against this approved TSTF traveler and has determined that administrative controls for such isolation devices (i.e., isolation valves and dampers) have proven to be adequate to ensure the devices are maintained in the positions required by the plant safety analyses when primary and secondary containment is required to be operable.

Periodic verification is required for a penetration with an inoperable isolation device in order to detect and correct inadvertent repositioning of the isolation device. Because the purpose of locking, sealing, or securing components is to prevent inadvertent repositioning, the licensee proposed that periodic reverification should be a verification of the administrative controls that ensures that the component remains in the required state.

TS LCO 3.6.1.3 states, "Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE." TS LCO 3.6.4.2 states, "Each SCIO shall be OPERABLE."

The OPERABILITY requirements for isolation devices ensure that components are capable of performing their safety functions within the time limits assumed in the safety analyses.

It is sufficient to assume that the initial establishment of component status (e.g., isolation valves closed) was performed correctly. Subsequently, verification is intended to ensure the component has not been inadvertently repositioned. Given that the function of locking, sealing, or securing components is to ensure the same avoidance of inadvertent repositioning, the periodic reverification should only be a verification of the administrative control that ensures that the component remains in the required state. It would be inappropriate to remove the lock, seal, or other means of securing the component solely to perform an active verification of the required state. The inoperable containment penetrations will continue to be isolated, and thus, perform their isolation function. In addition, the proposed change does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation.

Additionally, the NRC staff concludes that the requirements of 10 CFR 50.36(c)(2) will continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO, and the appropriate remedial actions are specified if the LCO is not met.

Based on the above, the NRC staff concludes that the change is consistent with TSTF-269-A (since administrative controls for isolation devices have proven to be adequate to ensure the devices are maintained in the positions required by the plant safety analyses). In addition, the NRC staff determined the variation does not affect the applicability of TSTF-269-A to the proposed license amendments because the equivalent of Condition E of TSTF-269-A does not appear in the Brunswick TSs. Therefore, the changes to TS 3.6.3.1 and TS 3.6.4.2 are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the North Carolina State official was notified of the proposed issuance ofthe amendments on October 7, 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 February 26, 2019 (84 FR 6179), 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 - Application to Revise Technical Specifications to Adopt TSTF-269, 'Allow Administrative Means of Position Verification for Locked or Sealed Valves,"' dated December 14, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18353A951 ).
2. Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF 269, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves," dated June 27, 1999 (ADAMS Accession No. ML040620100).
3. Beckner, William D., U.S. Nuclear Regulatory Commission, letter to Davis, James, Nuclear Energy Institute, dated July 26, 1999 (ADAMS Accession No. ML19067A141 ).
4. U.S. Nuclear Regulatory Commission, NUREG-1433, "Standard Technical Specifications, General Electric BWR/4 Plants," Volume 1, "Specifications," Revision 4.0, dated April 2012 (ADAMS Accession No. ML12104A192).
5. U.S. Nuclear Regulatory Commission, NUREG-1433, "Standard Technical Specifications, General Electric BWR/4 Plants," Volume 2, "Bases," Revision 4.0, dated April 2012 (ADAMS Accession No. ML12104A193).

Principal Contributor: Larry Wheeler Da~: November 21, 2019

ML19281A330 *by memo (ML19204A087) **by e-mail OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DSS/STSB/BC(A)*

NAME DGalvin (AHon for) LRonewicz PSnyder DATE 10/17/2019 10/17/2019 07/26/2019 OFFICE OGC-NLO* NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME STurk UShoop AHon DATE 11/12/2019 11/21/2019 11/21/2019