RA-19-0446, Request to Correct Administrative Technical Specification Error

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Request to Correct Administrative Technical Specification Error
ML19351E364
Person / Time
Site: Brunswick Duke Energy icon.png
Issue date: 12/17/2019
From: Krakuszeski J
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0446
Download: ML19351E364 (8)


Text

John A. Krakuszeski Vice President Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 December 17, 2019 Serial: RA-19-0446 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit No. 2 Renewed Facility Operating License No. DPR-62 Docket No. 50-324 Request to Correct Administrative Technical Specification Error

References:

1. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," dated December 21, 2015, ADAMS Accession Number ML16004A249
2. Letter from Andrew Hon (NRC) to William R. Gideon (Duke Energy), "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments Regarding Request to Relocate Specific Surveillance Frequencies to a Licensee Controlled Program," dated May 24, 2017, ADAMS Accession Number ML17096A129
3. SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors," ADAMS Accession Number 9611250030 (Legacy Library)
4. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission, "Request for License Amendment Regarding Core Flow Operating Range Expansion," dated September 6, 2016, ADAMS Accession Number ML16257A410
5. Letter from Andrew Hon (NRC) to William R. Gideon (Duke Energy), "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendment Regarding Core Flow Operating Range Expansion (MELLLA+), dated September 18, 2018, ADAMS Accession Number ML18172A258 Ladies and Gentlemen:

Duke Energy Progress, LLC (Duke Energy), requests a correction of an error in the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit No. 2. The error was inadvertently introduced by issuance of Amendment 304 for Unit 2 on May 24, 2017 (i.e.,

Reference 2). The error was not noticed to the public, nor reviewed by the NRC as part of the application amendment process (i.e., Reference 1), and thus falls within the scope of guidance provided in SECY-96-238 (i.e., Reference 3). The affected page was re-issued with Amendment 313 for Unit 2 on September 18, 2018 (i.e. Reference 5). Again, the error was not noticed to the public, nor reviewed by the NRC as part of the application amendment process (i.e., Reference 4).

RA-19-0446 Enclosure 1 Page 1 of 2 Description of Technical Specification Error Requested Action Consistent with the information contained in SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors," Duke Energy Progress, LLC (Duke Energy),

requests a correction of an error in the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit No. 2.

Typographical Error On December 21, 2015 (i.e., Reference 1), Duke Energy submitted a license amendment request (LAR) to adopt Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," Revision 3. Surveillance Requirement (SR) 3.3.1.1.18 was not impacted by the requested LAR. However, SR 3.3.1.1.16 and SR 3.3.1.1.17 which appear on the affected page (i.e., Unit 2 page 3.3-7) were revised. The mark-up of page 3.3-7 did not alter SR 3.3.1.1.18 which stated:

Adjust recirculation drive flow to conform to reactor core flow.

The wording of SR 3.3.1.1.18 was inadvertently changed when typed pages were provided in support of issuance of the proposed LAR. SR 3.3.1.1.18, as issued in Amendment 304 for Unit 2 (i.e., Reference 2), now states:

Adjust the flow control trip reference card to conform to reactor flow.

On September 6, 2016 (i.e., Reference 3), Duke Energy submitted a LAR to expand the core flow operating range. As part of this LAR, SR 3.3.1.1.19 was deleted. Again, SR 3.3.1.1.18 was not impacted by the requested LAR and the TS mark-ups supporting the LAR did not include SR 3.3.1.1.18. On September 18, 2018 (i.e., Reference 4) Unit 2 page 3.3-8 was issued in Amendment 313 for Unit 2, indicating deletion of SR 3.3.1.1.19, with the incorrect wording of SR 3.3.1.1.18 remaining.

Correction to the Affected TS Page SECY- 96-238 (i.e., Reference 5) provides guidance for correction of inadvertent typographical errors in the TSs. It states, in part:

the case in which the staff or licensee can demonstrate that the error was introduced inadvertently in a particular license amendment and that the erroneous change was not addressed in the notice to the public nor reviewed by the staff. Under these limited circumstances, the change that introduced the typographical error was not a proper amendment to the license because it was neither addressed in the notice nor reviewed, and correction of the typographical error is not a "change" to the TSs. Accordingly, the typographical error may be corrected by a letter to the licensee from the NRC staff, instead of an amendment to the license.

The above error was not noticed to the public, nor was it reviewed by the NRC as part of the amendment process. The pre-notice for Amendment 304 was published in the Federal Register on March 29, 2016 (i.e., 81 FR 17504), and the pre-notice for Amendment 313 was published in the Federal Register on January 3, 2017 (i.e., 82 FR 158). Neither discussed revising

RA-19-0446 Enclosure 1 Page 2 of 2 SR 3.3.1.1.18. Similarly, the LARs supporting Amendments 304 and 313 did not indicate any change to SR 3.3.1.1.18. Therefore, this error may be corrected without a license amendment. provides a mark-up of the affected TS page as issued by Amendment 313. provides a revised (i.e., typed) copy of the TS page.

References

1. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," dated December 21, 2015, ADAMS Accession Number ML16004A249
2. Letter from Andrew Hon (NRC) to William R. Gideon (Duke Energy), "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments Regarding Request to Relocate Specific Surveillance Frequencies to a Licensee Controlled Program," dated May 24, 2017, ADAMS Accession Number ML17096A129
3. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission, "Request for License Amendment Regarding Core Flow Operating Range Expansion," dated September 6, 2016, ADAMS Accession Number ML16257A410
4. Letter from Andrew Hon (NRC) to William R. Gideon (Duke Energy), "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendment Regarding Core Flow Operating Range Expansion (MELLLA+), dated September 18, 2018, ADAMS Accession Number ML18172A258
5. SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors," ADAMS Accession Number 9611250030 (Legacy Library)

RA-19-0446 Enclosure 2 Mark-up of Affected Technical Specification Page

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop ValveClosure and Turbine In accordance with Control Valve Fast Closure, Trip Oil PressureLow the Surveillance Functions are not bypassed when THERMAL Frequency Control POWER is 26% RTP. Program SR 3.3.1.1.17 --------------------------------NOTES----------------------------

1. Neutron detectors are excluded.
2. For Functions 3 and 4, the sensor response time may be assumed to be the design sensor response time.

Verify the RPS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.18 Adjust recirculation drive flow to conform to reactor Once within 7 days core flow.Adjust the flow control trip reference card to after reaching conform to reactor flow. equilibrium conditions following refueling outage Brunswick Unit 2 3.3-8 Amendment No. 313

RA-19-0446 Enclosure 3 Revised (Typed) Technical Specification Page

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.16 Verify Turbine Stop ValveClosure and Turbine In accordance with Control Valve Fast Closure, Trip Oil PressureLow the Surveillance Functions are not bypassed when THERMAL Frequency Control POWER is 26% RTP. Program SR 3.3.1.1.17 --------------------------------NOTES----------------------------

1. Neutron detectors are excluded.
2. For Functions 3 and 4, the sensor response time may be assumed to be the design sensor response time.

Verify the RPS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program SR 3.3.1.1.18 Adjust recirculation drive flow to conform to reactor Once within 7 days core flow. after reaching equilibrium conditions following refueling outage Brunswick Unit 2 3.3-8 Amendment No. 313