ML20082G467

Safety Evaluation Supporting Amends 175 & 206 to Licenses DPR-71 & DPR-62,respectively

ML20082G467
Person / Time
Site:	Brunswick
Issue date:	03/30/1995
From:	Office of Nuclear Reactor Regulation
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ML20082G465	List: ML20082G462 ML20082G467
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NUDOCS 9504130266
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&# ~%;' 4 UNITED STATES NUCLEAR REGULATORY COMMISSION s o 'f WASHINGTON, D.C. 20066 4 001 o %...../ SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION E RELATED TO AMENDMENT NO.175 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO.- 206TO FACILTY OPERATING LICENSE NO. DPR-62 CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 i i i

1.0 INTRODUCTION

l By. letter dated October 28, 1994, as supplemented. February 16, 1995, the Carolina Power & Light Company (the licensee) submitted a request for changes to the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, Technical Specifications (TS). The proposed changes will revise TS requirements to increase the surveillance test intervals (STIs) and.the allowable out of service times (A0Ts) for instruments of the reactor protection system.(RPS), isolation actuation system, emergency core cooling system (ECCS) actuation-system, control rod withdrawal block system, control room emergency ventilation system, anticipated transient without scram (ATWS) recirculation pump trip (RPT), end-of-cycle (EOC) RPT, and reactor core isolation cooling (RCIC) actuation system. The proposed TS changes will include the following: 1. Increase STIs from weekly or monthly to quarterly. 2. Increase A0Ts for repairs from I hour to 12 or 24 hours. 3. . Increase A0Ts for surveillance tests from 2 hours to 6 hours. 4. Revise associated BASES and wordings of the action statements to implement revised A0Ts, STIs, and add clarifications and editorial corrections. The proposed revision to the TS is a part of the TS improvement program.. Revised STIs and A0Ts of the improved TS, would minimize the potential number of inadvertent plant scrams reducing excessive test cycles on equipment, _ l reduce occupational ex)osure, increase operational effectiveness of plant personnel, and allow tie savings in resources to be used for other tasks such as preventive maintenance. The revised wording of action statements and footnotes will clarify.the required actions and will preclude extended, uncompensated " loss-of-function" situations during surveillance testing and also during instrument repairs. The February 16, 1995, letter provided clarifying information that did not change the initial proposed no significant l hazards consideration determination.

2.0 BACKGROUND

In late 1983, the Boiling Water Reactor (BWR) Owner's Group (BWROG) formed a TS improvement committee establishing the BWR TS Improvement program for 9 9504130266 950330 PDR ADOCK 05000324 P PDR

_ developing PRA analyses to identify improvements to STIs and A0Ts specified in BWR TS. The BWORG issued the initial topical report, and subsequently issued several Licensing Topical Reports (LTRs) and supplemental letters, addressing the staff's questions and concerns. The staff reviewed the BWORG LTRs and issued safety evaluation reports'(SERs). These SERs approved various TS changes relating to extending STIs, and A0Ts for test and repairs of instruments of channels for the above described safety systems of BWR plants. However, the staff stipulated certain conditions that licensees must meet to include these pre-approved changes in their plant-specific TS. The BWORG's LTRs and NRC staff's SERs are included in the Reference section at the end of this document.

3.0 PROPOSED CHANGE

S AND EVALUATION (Unless otherwise noted the proposed changes are applicable to Units 1 and 2) 1. Table 3.3.1-1: Reactor Protection System Instrumentation Table 4.3.1-1: Reactor Protection System Instrumentation Surveillance Requirements 1.1 Prooosed chanae: Revise actions a & b and footnotes * &** to incorporate a check for trip capability (loss of function) and to provide an A0T for repair of either 1, 6, or 12 hours, depending on the degree of redundancy remaining for the Functional Unit. Evaluation: The RPS system is made up of two independent trip systems. There are usually four channels to monitor each parameter with two in each trip system. The outputs of the channels in a trip system are combined in a logic so that either channel will trip that trip system. The tripping of both trip systems will produce a reactor scram (1 out of 2 taken twice). BWROG-92102 Letter from C.L Tully (BWROG) to B. K. Grimes (NRC), dated November 4, 1992, includes revised statements for Actions a and b section 3.3.1 LCO, and associated foot notes marked by

• and **. The statements were revised by the BWROG to address the NRC staff's concern that model TS action proposed in NEDC-30851P-A would

) allow continued plant operation up to 12 hours with a combination of failures that could prevent a reactor scram function completing its logic when called upon (i.e., loss-of-function). The proposed change is in accordance with the above letter. 1.2 Proposed chanae: Change the description for Functional Unit 2.b in Tables 3.3.1-1 and 4.3.1-1, from " Flow Biased Neutron Flux - High" to ~ " Flow Biased Simulated Thermal Power High". Evaluation: This is an editorial change to make the description consistent with the item 2.b description in Table 2.2.1-1 for this Functional Unit. 1.3 frocosed chanae: Revise Table 3.3.1-1, Note (a) to increase the A0T for required surveillance testing from 2 hours to 6 hours and to incorporate a check for trip capability based on the terminology used in NUREG-1433

,f y S n ' t 1.4.1 Proposed chanae: Increase the Channel Functional Test intervals in Table .4.3.1-1 from W (weekly)'.tc Q (quarterly) for the following Functional l Units. Average Power Range Monitor i a. item 2.b, Flow-Biased Simulated Th'ermal. Power-High' b. item.2.c, Fixed Neu'; roe flux - High,120% c. iten E.d, Inoperative d. item 2.e, Downscale 1.4.2 Proposed chanae: Increase the Channel Functional Test. intervals in Table' 4.3.1-1 from M (monthly) to Q (quarterly).for the following Functional Units. a. item 3, Reactor Vessel Steam Dome pressure - High b. item 4, Reactor Vessel Water Level - Low, Level 1 c. item 5, Main.! team Line ' Isolation Valve - Closure q d. item 6, Main Steam Line Radiation - High e. item 7, Drywell Pressure - High f. item 9, Turbine Stop Valve - Closure g. item 10, Turbine Control Valve Fast Closure, Control' 011 Pressure- - Low i 1.4.3 Proposed chance: Increase the Channel Calibration Test intervals in-Table 4.3.1-1 from M.(monthly) to Q (quarterly) for the following Functional Units. a. itw 3. Reactor Vessel Steam Dome pressure - High b. itu 4, Reactor Vessel Water Level - Low, Level 1 e. item 7, Drywell Pressure - High-Evaluation: The proposed changes. described in sections 1.3,-1.4.1, 1.4.2-and 1.4.3 above are in accordance with the pre-approved changes s described in the NRC staff's.SER dated July 15, 1987 for GE Topical Report NEDC-30851P, " Technical Specification improvement analysis for BWR Reactor protection System" for a plant that uses relay logic for the ] RPS. 1.5 Proposed changg: Revise note (f) of Table 4.3.1-1, that reads, "This calibration shall consist of the adjustment of the APRM flow-biased i setpoint to conform to a calibrated flow signal", to read,"This calibration shall consist of the adjustment of the APRM flow-biased channel to conform to a calibrated flow signal". Evaluation: The licensee in their submittal stated that changing the word "setpoint" to " channel" was required to conform to the intended surveillance required for this design feature. This change was made to the original Standard TS (NUREG-0123) subsequent to the adoption of these specifications by the Brunswick plants. This change brings the Brunswick plants into line with the surveillance practice established for similar. plants.

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4 --

1.6-Pronosed chanae: ' Add new Functional Unie Number 13, " Automatic Scram Contactors" to Tables 3.3.1-1 and 4.3.1-1, providing weekly testing l requirements for the automatic scram contactors. i i Evaluation: In their submittal the licensee stated that the' automatic: l scram contactors-are currently tested at..least once every seven days as a part of the APRM sensor channel tests. As discussed in sections 5.7.1 & 5.7.3 of.NEDC-30851P-A and Sections 5.3 & 5.6_of the NRC SER, the APRM sensor channel-tests can be increased to quarterly, provided the automatic scram contactors continue to be tested on a weekly basis.- For-later plant designs, as in'the generic model this can be accomplished by actuating the manual scram circuits-on a weekly basis. For earlier plant designs, such as BESP, the manual scram circuits are separate from the automatic scram circuits. For these designs, weekly functional - i testing of the automatic scram contactors can be assured by explicitly including them as a-separate line-item in the RPS instrumentation tables. 1.7 Proposed chanae: Revise footnote "1" to read " Transmitters are exempted from the quarterly channel calibration". Evaluatign: This is an editorial change to implement change described'in section 1.4.3 above. 1.8 Proposed chanae: Modify Bases Section 3/4.3.1 to reference the document NEDC-30851P-A and Plant-Specific Report MDE-81-0485, Rev.1 which provide the detailed basis for the above proposed changes. Evaluation: Proposed changes to Bases'section is consistent with the above proposed changes to TS requirements of STIs, A0Ts, action statements, and statements of revised footnotes. 2. Table 3.3.2-1: Isolation Actuation Instrumentation, Table 4.3.2-1: Isolation Actuation Instrumentation Surveillance Requirements i 2.1 Proposed chanae: Delete the phrase "and place the-inoperable channel in the tripped condition" from Table 3.3.2, Action "a". Evaluation: This is an editorial change. It does not change the intent of any existing requirement. Required actions for inoperable channels - are addressed in revised actions "b" and "c",. and Table 3.3.2-1, i therefore this phrase is redundant and unnecessary. 2.2 Pronosed chanae: Revise actions "b" and "c" and delete footnotes

• and j
  • to incluoe a check for loss of function and provide'an A0T for repair of 12 hours for Trip Functions that are common to RPS and 24 hours for l

Trip Functions'that are not common to RPS. 2.3 Proposed chanae: Revise Table 3.3.2-1, Notes (b) and (c) into one new ) Note (b) which retains the existing 2 hour A0T for Trip Functions 7 i

I t l designed 'such that it is not possible to maintain trip capability during - required surveillance testing and to increase the A0T for required surveillance testing from 2 hours to 6 hours for Trip Functions that can 1 be tested while maintaining trip capability. 2.4.1 Proposed chanae: Increase the Channel Functional Test intervals in Table 4.3.2-1 from M (monthly) to Q (quarterly) for following Functional Units. Primary Containment Isolation a. Item 1.a.1, Reactor Vessel Water Level - Low, Level I b. item 1.a.2, Reactor Vessel Water Level - Low, Level 3 c. item 1.b, Drywell Pressure - High .) d. . item 1.c.1, Main Steam Line Radiation - High e. item 1.c.2, Main Steam Line - Pressure - Low f. item 1.c.3, Main Steam Line Flow - High g. item 1.d, Main Steam Line Tunnel -Temperature - High h. item 1.e, Condenser Vacuum - Low 1. item 1.f, Turbine Building Area Temperature - High j. item 1.h, Reactor Building Exhaust Radiation - high Secondary Containment Isolation 5 k. item 2.a, Reactor Building Exhaust Radiation - High ) 1. item 2.b, Drywell pressure - High-. m. item 2.c, Reactor Vessel Water Level - Low, Level 2 j Reactor Water Cleanup System Isolation i n. item 3.e, Reactor Vessel Water Level - Low, Level 2 'l Core Standby Cooling Systems Isolation i o. item 4.a.1, HPCI Steam line Flow - High j p. item 4.a.3, HPCI Steam Supply Pressure - Low q. item 4.a.6, HPCI Turbine Exhaust Diaphragm Pressure - High r. item 4.a.10, Drywell Pressure - High s. item 4.b.1, RCIC Steam Line Flow - High t. item 4.b.3, RCIC Steam Supply Pressure - Low u. item 4.b.6, RCIC Turbine Exhaust Diaphragm Pressure - High' i v. item 4.b.12, Drywell Pressure - High Shutdown Cooling System Isolation w. item 5.a, Reactor Vessel Water Level - Low, Level 1 x. item 5.b, Reactor Steam Dome Pressure - High 2.4.2 Proposed chanae: Increase the Channel Calibration Test intervals in Table 4.3.2-1 from M (monthly) to Q (quarterly) for the following Functional Units. Primary Containment Isolation a. item 1.a.1, Reactor Vessel Water Level - Low, Level 1 b. item 1.a.2, Reactor Vessel Water Level - Low, Level 3 c. item 1.b, Drywell Pressure - High i ~_

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4 1 l d. item 1.c.2, Main Stea's Line - Pressure -' Low l e. item 1.c.3,- Main Steam Line Flow - High f. item 1.e,-Condenser. Vacuum'- Low' Secondary Containment. Isolation g. item' 2.b, Drywell pressure - High h. ites 2.c, Reactor Vessel Water Level - Low, Level 2 Reactor Water Cleanup System Isolation 1. item 3.e, Reactor Vessel-Water Level-- Low, level 2. 1 Core Standby Cooling Systems Isolation. J. item 4.a.1, HPCI Steam line Flow - High k. item 4.a.10, Drywell Pressure - High 1. item 4.b.1, RCIC Steam Line Flow - High m. item 4.b.12, Drywell Pressure - High Shutdown Cooling System Isolation n. Item 5.a Reactor Vessel Water Level - Low. Level 1 Evaluation: The proposed changes described in sections 2.2. 2.3. 2.4.1. and 2.4.2 above are in accordance with the pre-approved change described =l in the staff's SER dated June 18, 1990, for instruments not common with 1 the RPS, and SER dated January 6, 1989, for' instruments which are common 1 with the RPS for the GE Topical Report, NEDC-31f77P-A, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation". 2.4.3 Pronosed chanae: Revise footnote "b" to read from "Trans'mitters are exempted from the monthly channel calibration" to " Transmitters are exempted from the quarterly channel' calibration". Evaluation: This is an editorial change to implement change described in section 2.4.2 above. 2.5 Pronosed chanae: Change " logic chains" to " logic trains" in the second sentence of Surveillance requirement 4.3.2.3. Evaluation: This is an editorial change to make the terminology consistent within this sentence and consistency with Surveillance Requirements 4.3.1.3 and 4.3.3.3. 2.6 Proposed chanae: Delete note c "If not performed within 31 days". - Evaluation: This note applies only to Functional Unit 5.b." Reactor Steam Dome Pressure - High". By deleting this note, functional _-test-requirements during startup are removed making the BSEP surveillance requirements for this Functional Unit in line with the STS and consistent with those for similar plants.

y-M ~ _j_ q 2.7L. Proposed chanae: Modify Bases'Section 3/4.3.2 to reference the. document NEDC-30851P-A, Supplement 2 and NEDC-31677P-A which provide the detailed basis for the-above propcsed changes. t 4 ' Evaluation: Proposed changes to Bases section is consistent with the above proposed changes to TStrequirements of STIs, A0Ts, ACTION statements,,and. statements of revised foot-notes. t 3 Table 3.3.3-1 Emergency Core Cooling System Actuation Instrumentation, Table.4.3.3-1 Emergency Core Cooling System Actuation Instrumentation a Surveillance Requirements 3.1 Pronosed chanae: In specification 3.3.3, insert the word " channels" between " instrumentation and "shown". Evaluation:.This is an editorial change to make the wording of this-specification consistent with the wording of specifications 3.3.1 and R 3.3.2. 3.2 Pronosed chanae: Delete the phrase "and place the inoperable channel in the tripped condition" from TS 3.3.3, Action "a". Evaluation: This is an editorial change. It does not change the intent or any existing requirement. Required Actions for inoperable channels 1 are addressed in Action b and Table 3.3.3-1, therefore, this phrase is redundant and unnecessary. R 3.3 EroDosed chanae: Revise Table 3.3.3-1, including Actions' 30-33, to address " Minimum Operable Channels"on a "per Trip Function" basis instead of the current "per Trip System" basis. Evaluation: This is an editorial change to achieve consistency with the Standard TS including NUREG-0123 and NUREG-1433, and to simplify the~ application of the Topical reports of. the. Brunswick Units. 3.4 Pronosed chanae: Revise Table 3.3.3-1, Action 33 to reference HPCI -instead HPCS. Evaluation: This is an editorial change to correct a typographical error. 3.5 Proposed chanae: Revise and clarify Table 3.3.3-1 Actions to include,. depending on degree redundancy, a check for loss of function and an A0T for repair of 24 hours. Specifically, Actions 30 and 36 are revised, per inserts IC and 2C respectively, to require compensatory action within i one hour when a loss-of-function condition exists.and to allow up to 24 hours to repair inoperable channels provided a loss-of-function condition does not exist. Also revised Actions 30 and 36 are only applicable to the Trip Functions listed below. Therefore, the ACTION referenced by Table 3.3.3-l'is changed to 30 or 36 as indicated. c

e v i ' + Core Spray System. i a. Item 1.b, Reactor Steam Dome Pressure-Low, Referenced Action changed from 31 to 30.- Low Pressure Coolant Injection Mode of-RHR System a. Item 2.d.1, Reactor Steam Dome Pressure-Low, RHR Pump Start and LPCI Injection Valve Actuation, Referenced Action changed from 31 to 30. b. Item 2.d.2,. Reactor Steam Dome Pressure-Low, Recirculation Loop Pump Discharge Valve Actuation, Referenced Action changed from 31 to 30. l Automatic Depressurization System a. Item 4.b, Reactor Vessel Water level - low, Level 3, Referenced Action changed from 30 to 36.

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Item 4.c,- Reactor Vessel Water level - low, Level 1, Referenced i Action changed from 30 to 36. c. Item 4.d, ADS Timer, Referenced Action changed from 31 to 36. d. Item 4.e, Core Spray pump Discharge Pump pressure - High, Referenced Action changed from 31 to 36. f. Item 4.f, RHR (LPCI MODE) Pump Discharge Pressure -, High, t Referenced Action changed from 31 to 36. Evaluation: Revised statements for Actions 30 and 36 require the inoperable channel (s) to be placed in a " tripped condition" within I hour if sufficient channels are not OPERABLE (loss-of-function f condition), which provide a compensatory action within one hour when a loss-of-function condition exists. If a loss-of-function condition does not exist, 24 hours are allowed for repairs of an inoperable channel (s). Allowing 24 hours A0T for' repairs is in accordance with the pre-approved. change described in the Staff's SER dated December 9, 1988 for GE Topical. Report NEDC-30936P. 3.6 Proposed chanae: Revise Table 3.3.3-1, Note (a) to increase th'e A0T for required surveillance testing from 2 hours to 6 hours and to incorporate-a check for trip capability based on the terair Ngy used in NUREG-1433. 3.7.1 Proposed chanae: Increase the Channel Functional Test intervals in Table 4.3.3-1 from M (monthly) to Q (quarterly) for following Functional Units. Core Spray System

a. item 1.a. Reactor Vessel Water Level.- Low, Level 3

b. item 1.b, Reactor Steam Dome Pressure - Low

c. item 1.c, Drywell pressure - High Low Pressure Coolant Injection Mode of RHR System

d. item 2.a, Drywell Pressure - High

^

e. item 2.b, Reactor Vessel Water level - Low, Level 3

f. item 2.c, Reactor Vessel Shroud Level-

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g. Item 2.d.1, Reactor Steam Dome ~ Pressure - Low, RHR Pump Start and LPCI Injection Valve Actuation 1

h. item 2.d.2, Reactor Steam dome Pressure - Low, Recirculation. Loop Pump Discharge Valve Actuation High Pressure Coolant Injection System

1. item 3.a. Reactor Vessel water level - Low, Level 2

j. item 3.b, Drywell Pressure - High

k. item 3.c, Condensate Storage Tank Level - Low

1. item 3.d, Suppression Chamber Water Level - High Automatic Depressurization System

m. item 4.b, Reactor Vessel Water Level - Low, Level 3

n. item 4.c, Reactor Vessel Water Level - Low Level 1

o. item 4.e, Core Spray Pump Discharge Pressure - High

p. item 4.f, RHR(LPCI MODE) Pump Discharge Pressure - High 3.7.2 Proposed chanae: Increase the Channel Calibration Test intervals in Table 4.3.3-1 from M (monthly) to Q (quarterly) for following Functional Units.

Core Spray-System

a. item 1.a, Reactor Vessel Water Level - Low, Level 3

b. item 1.b, Reactor Steam Dome Pressure - Low

c. item 1.c, Drywell pressure - High Low Pressure Coolant Injection Mode' of RHR System

d. item 2.a, Drywell Pressure - High

e. item 2.b, Reactor Vessel Water level - Low, Level 3

f. item 2.c, Reactor Vessel Shroud Level i

g, item 2.d.1, Reactor Steam Dome Pressure - Low, RHR Pump Start and LPCI Injection Valve Actuation

h. item 2.d.2, Reactor Steam Dome Pressure - Low, Recirculation Loop Pump Discharge Valve Actuation High Pressure Coolant Injection System

1. item 3.a, Reactor Vessel water level - Low, Level 2

j. item 3.b, Drywell Pressure - High Automatic Depressurization System

k. ' item 4.b, Reactor Vessel Water Level - Low, Level 3

1. item 4.c, Reactor Vessel Water Level - Low Level 1 Evaluation: The proposed changes described above in sections 3.6, 3.7.1 and 3.7.2 are in accordance with the pre-approved change described in the Staff's SER dated December 9,1988 for GE Topical Report NEDC-30936P,"BWR Owners Group Technical Specification Improvement Methodology (with demonstration for BWR ECCS actuation Instrumentation) Part 2".

M, a r +, c o ax Revise footnote "b" to read from " Transmitters are 3.7.3 Pronosed chanae: exempted from the monthly channel calibration" to " Transmitters are exempted from the quarterly channel calibration". Evaluation: This is an editorial change. Since calibration frequency is now changed from monthly to quarterly, revision to footnote "b" was :

J necessary for consistency.

li 3.8 Proposed chanae: Delete temporary Note'(f).. l Evaluation: As indicated by this note, this was a temporary exception to ACTION 31 (proposed ACTION 30) and is no longer applicable. 3.9 Pronosed chanae: Modify Bases Section 3/4.3.3 to reference documents NEDC-30936P-A and plant-specific report RE-Oll, Revision 1, which-provide the detailed basis.for the above proposed changes.. Evaluation: Proposed changes to the Bases section is consistent with the above proposed changes to the'TS requirements of STIs, A0Ts, ACTION statements, and statements'of revised foot-notes. '4 Table 3.3.4-1 Control Rod Withdrawal Block Instrumentation,. Table 4.3.4-1 Control Rod Withdrawal Block Instrumentation Surveillance Requirements' 4 5 4.1 Proposed chanae: Revise Table 3.3.4-1, Note (a) to ' increase the A0T for required Surveillance testing from 2 hours to 6 hours and to incorporate a check for trip capability based on the terminology used in NUREG-1433.- 4.2 Proposed chanae: Increase the Channel Functional Test Requirement in Table. 4.3.4-1 from M(monthly) to _Q (quarterly) for the following Trip Functions: APRM

a. item 1.a, Upscale (Flow Biased)

b. item 1.c, Downscale d -

Rod Block Monitor

c. item 2.a. Upscale

d. item 2.c, Downscale Evaluation:.The proposed changes described above in sections 4.1 and 4.2 are in accordance with the pre-approved change described'in the Staff's SER dated July 21, 1992 for GE Topical Report GENE-770-06-1, " Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications", and in the staff's SER dated September 22, 1988 for GE Topical, NEDC-30851P-A, Supplement 1, October 1988, " Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation".

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T I -. 11 - .I - l ' 4.3 - Proposed chanae: Modify Bases Section 3/4.3.4 to reference documents i NEDC-30851P-A Supplement'I and GENE-770-06-1-A which provide the. 1 detailed basis for the above proposed changes. Evaluation:. Proposed changes'to the Bases?section are consistent with the above proposed changes.to-the TS requirements of STIs, A0Ts, ACTION statements,.and statements of the revised foot-notes. 1 5.. Table 4.3.5.5-1, Control Room Emergency Ventilation System, - 1 Instrumentation Surveillance Requirements 5.1 Proposed chanaes: Increase the Channel Functional Test interval for i Table 4.3.5.5-1, Radiation Protection,-item 1, Control Building' Air-i Intake, from M(monthly) to Q (quarterly) Evaluation: The proposed change is in accordance with the pre-approved change described in the Staff's SER dated July 21,'1992 for GE Topical-1 Report GENE-770-06-1. 5.2 Proposed chanaes: Modify Bases Section 3/4.3.5.5 to reference document GENE-770-06-1-A, which provides'the detailed basis for the above proposed changes.- Evaluation:. Proposed changes to the Bases section is-consistent with the above proposed changes to the TS requirements of STIs, A0Ts, ACTION statements, and statements of the revised foot-notes. 6. Table 3.3.6.1-1, ATWS Recirculation Pump Trip System Instrumentation, Table 4.3.6.1-1, ATWS Recirculation Pump Trip System Instrumentation Surveillance Requirements 6.1 Pronosed chanae: In specification 3.3.6.1, replace " trip systems" with " channels" and revise Table 3.3.6.1-1 column heading from " Minimum Number Operable Trip Systems Per Operating Pump" to " Minimum Operable i Channels Per Trip System". Evaluation: This is an editorial change to clarify intent; provide consistency with the language used in-the Action statements and to make i ' the wording of this specification consistent with the wording of Specifications 3.3.1, 3.3.2, and 3.3.3. 6.2 Proposed chance: Replace TS 3.3.6.1, Actions b,c,d and e with new i Actions b,c,and d. Evaluation: The licensee in their submittal stated that the proposed change reflects the system design, describes the intent'of the actions clearly and will provide appropriate compensatory actions when a loss of-function condition exist. In addition, the proposed change incorporates appropriate A0Ts for repairing inoperable channels and trip systems in f I l.-. -m., m

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1 accordance with'the pre-approved change described in the Staff's'SER: dated July 21,.1992 for GE Topical Report GENE-770-06-1. 6.3 'Pronosed chanae: Revise Table 3.3.6.1-1, Footnote (a) to increase the A0T for required surveillance testing from 2 hours to 6 hours and to incorporate a check for trip capability based on the terminology used in NUREG-1433.. 6.4.1 Proposed chanae:. Increase the ATWS-RPT Channel Functional Test intervals' i in Table 4.3.6.1-1 from M(monthly) to Q (quarterly) for the following: i Trip Functions- .a. item 1, Reactor Vessel Water Level - Low, level 2 b. item 2, Reactor Vessel Pressure - High 6.4.2 Proposed changg: Increase the ATWS-RPT Channel Calibration intervals in Table 4.3.6.1-1 from M(monthly) to Q (quarterly) for the.following-Trip Functions: a. item 1, Reactor Vessel Water Level - Low, level 2 b. item 2, Reactor Vessel Pressure - High Evaluation: The proposed changes described in sections 6.3, 6.4.1 and 6.4.2 above are in accordance with the pre-approved changes described in the Staff's SER dated July 21, 1992 for GE Topical Report GENE-770-06-1. '6.4.3 Prooosed chanae: Revise footnote "b" to read from " Transmitters are exempted from the monthly channel calibration" to " Transmitters are exempted from the quarterly channel. calibration". Evaluation: This is an' editorial change and is required to implement the change described in section 6.4.2.above. ~ 6.5 Proposed chanae: For unit 2 only, change the Channel Functional Test interval from M(monthly) to NA(Not Applicable) for the Reactor Vessel Pressure - High, Transmitter in Table 4.3.6.1-1. Evaluation: This is an editorial change to correct a typographical error. The Channel Functional Test is performed at the analog trip unit and is correctly indicated in the corresponding Unit 1 specification as not applicable to the transmitter. 6.6 Proposed chanae: Modify Bases Section 3/4.3.6 to reference the document GENE-770-06-1-A which provides the detailed basis for the above proposed changes. Evaluation: Proposed changes to Bases section is consistent with the above proposed changes to TS requirements of STIs, A0Ts, action statements, and statements of revised foot-notes. ~

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7.

(Unit 2 only) Table'3.3.6.2-1, End of Cycle Recirculation Pump Trip System Instrumentation, and Table 4.3.6.2.1-1, End of. Cycle Recirculation-Pump Trip System Surveillance Requirements 7.1 Proposed chanae: Revise TS 3.3.6.2, Actions b and c.1 from "within 1 hour" to "within 12 hours" to provide an A0T for a repair of 12 hours. 7.2 Proposed chanae: Revise Table 3.3.6.2-1, Footnote' (a) to increase the A0T for required surveillance testing from 2 hours to 6 hours and to incorporate a check for trip capability based on the terminology used in NUREG-1433. 7.3 Proposed chanae: Increase the EOC-RPT Channel Functional Test intervals in Table 4.3.6.2.1-1 from M(monthly) to Q(quarterly) for the following Trip Functions.

a. item 1, Turbine Stop Valve - Closure

b. item 2, Turbine Control Valve - Fast Closure Evaluation: The proposed changes described in sections 7.1, 7.2 and 7.3 above are in accordance with the pre-approved change described in the Staff's SER dated July 21, 1992 for GE Topical Report GENE-770-06-1.

7.4 Proposed chanae: Modify Bases Section 3/4.3.6 to reference the document -GENE-770-06-1-A which provides the detailed basis for the above proposed changes. Evaluation: Proposed changes to the Bases section is consistent with the above proposed changes to the TS requirements of STIs, A0Ts, ACTION statements, and statements of revised foot-notes. 8. Table 3.3.7.1, Reactor Core Isolation Cooling System Actuation Instrumentation, Table 4.3.7.1-1, Reactor Core Isolation Cooling System Actuation Instrumentation Surveillance Requirements 8.1 Proposed chanae: Correct typographical error in LCO statement 3.3.7. ^ Change "ther" to "their" Evaluation: This is an editorial change. 8.2 Proposed chanae: Revise Table 3.3.7-1, Footnote (a) to increase the A0T for required surveillance testing from 2 hours to 6 hours and, except for Functional Unit 2 (Reactor Vessel Water Level - High), to incorporate a check to ensure that trip capability is maintained. 8.3 Proposed chanae: Revise Table 3.3.7-1, Actions 50.a. 51 and 52 to provide 24 hours to repair an inoperable channel and to provide appropriate compensatory actions when a loss of function condition exists. I

4 J8.4.1 Prooosed chanae: Increase the Channel Functional Test intervals in Table 4.3.7.1-1 from M (monthly) to Q (quarterly) for the following Functional Units. a. item 1, Reactor Vessel. Water Level - Low, Level 2 b. item 2, Reactor Vessel Water Level - High c. item 3, Condensate Storage Tank Level - Low 8.4.2 Pronosed chanae: Increase the Channel Calibration Test intervals in-t Table 4.3.7.1-1 from M (monthly) to Q (quarterly) for the following Functional Units. a. item 1, Reactor Vessel Water Level - Low, Level 2 b. item 2, Reactor Vessel Water Level - High j Evaluation: The proposed changes described above in sections 8.2, 8;3, 8.4.1 and 8.4.2 are in accordance with the pre-approved changes described in the Staff's SERs dated September 13,1991 and July 30, 1992 for GE Topical Report GENE-770-06-2," Addendum to Bases for changes to Surveillance Test Intervals and Allowed Out-of-Service Times'for Selected Instrumentation Technical Specifications",(BWR RCIC Instrumentation). 8.4.3 Prooosed chanae: Revise footnote (b) of Table 4.3.7.1-1, which reads. " Transmitters are exempted from the monthly channel calibration" to - " Transmitters are exempted from the quarterly channel calibration". Evaluation: The proposed change is editorial type and is required to implement the changes described in section 8.4.2 above. 8.5 Proposed chanae: Modify Bases Section 3/4.3.7 to reference the document GENE-770-06-2P-A which provides the detailed basis for the above 1 proposed changes. Evaluation: Proposed changes to the Bases section are consistent with the above proposed changes to the TS requirements of STIs, A0Ts, ACTION statements, and statements of revised footnotes. 4.0 VERIFICATION OF CONDITIONS The staff stipulated following conditions which must be met by the licensee for application of the pre-approved' changes to the plant i specific TS. 4.1 Confirm the applicability of the generic analyses to the plant. Licensee's Response: The licensee has reviewed all the applicable i Licensing Topical Reports and completed the plant-specific evaluations necessary to confirm that the generic analyses'and conclusions of the LTRs and related NRC-SERs apply to BSEP units 1 and 2. This is acceptable to the staff, i

u - 15 4.2 Confirm that any' increase in. instrument drift due to extended'STIs is properly accounted for in the setpoint calculation methodology. Licensee's Resoonse: The licensee has evaluated field data from monthly-calibration checks performed over a nine year period. Approximately. 2900 data points were evaluated during this effort;for the affected analog trip. units. -The results of this evaluation indicated that the quarterly drift will-remain within the present tolerances for setpoint calculations. -The licensee has concluded that increasing the applicable Channel Functional Test. intervals and the Calibration intervals from ~ weekly or monthly to quarterly will not result in excessive drift relative to the current setpoints. This is acceptable to the staff. '4.3 Confirm that the differences between the parts of the RPS that perform the trip functions in the plant and those of the base-case plant were included in the specific analysis done using the procedures of. Appendix K to NEDC-30851P-A. Licensee's Resoonse: GE analysis MDE-81-0485, Rev.1," Technical Specification Improvement Analysis for the Reactor Protection System for 4 Brunswick Steam' Electric Plant Units 1 and 2", utilized the procedures e of GE Licensing Topical Report NEDC-30851P-A, Appendix K, to identify and evaluate the differences between the parts of the RPS that perform j the trip" functions at BSEP Units 1 and 2 and those analyzed in the-generic study.'The results of this analysis indicated that, although the RPS' configuration'for BSEP Units 1 and 2 differs from the configuration of the base case plant, the differences do not have a significant impact. Therefore, the conclusions reached in NEDC-30851P-A. apply to-BSEP and the plant specific changes contained in this license amendment i request are bounded by both the generic analysis and the NRC's SER. This is acceptable to the staff.

5.0 CONCLUSION

Based upon the above review, the staff finds the proposed TS modification to be acceptable.

6.0 REFERENCES

1. NEDC-30851P-A, Dated March 1988, " Technical Specification Improvement Analyses for BWR Reactor Protection System". (RPS) 2. MDE-81-0485, Rev.1, " Technical Specification. Improvement Analysis for the Reactor Protection System for BSEP, Units 1 and 2". (RPS) =3. BWORG-92102 Letter fror.: C.L Tully (BWORG) to B. K. Grimes (NRC), "BWR Owners'-Group (BWORG) Topical Reports on Technical Specification Improvement Analysis for BWR Reactor Protection Systems-Use For Relay and Solid State Plants (NEDC-30844 and NEDC-30851P)," dated November 4, 1992. (RPS) l

wv : -4. NRC-SER dated' July 15, 1987 for GE Topical report NEDC-30851P-A, Technical' Specification Improvement Analyses for BWR reactor Protection System".-(RPS)

5.

NEDC-30851P-A, Supplement 2, March 1989, " Technical Specification Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation". (Isolation Actuation) 6. NEDC-31677PrA, July 1990, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation".(Isolation Actuation) 7. OG90-579-32A, June 25, 1990, letter from W.P. Sullivan and J.F. 3 Klapproth (GE) to Millard L. Wohl (NRC), " Implementation Enhancements to Technical Specifications on Changes given in Isolation Actuation i Instrumentation Analysis".(Isolation Actuation) 3. GENE-A31-00001-02, September 23,1994, " Assessment of Brunswick Nuclear Plant Isolation Actuation Instrumentation Against NEDC-31677P-A Bounding Analysis". (Enclosure 8 to the submittal).(Isolation Actuation) ) 9. NRC-SER dated June 18, 1990 for NEDC-31677P, " Technical Spacification Improvement Analysis for BWR Isolation Actuation Instrumentation", July 1990. (for isolation actuation instruments which are not common to RPS and ECCS)(Isolation Actuation) 10. NRC-SER dated January 6,1989 for GE Topical NEDC-30851P, Supplement 2,- " Technical Specification Improvement Analysis for BWR Isolation Instrumentation common to RPS and ECCS Instrumentation".(Isolation Actuation) i 11. NEDC-30936P-A Part 1, November 1985, " BWR Owner's Group Technical l Specification Improvement Methodology (with demonstration for BWR ECCS Actuation Instrumentation)". (ECCS) 12. NRC-SER of GE Topical Report NEDC-30936P-A Part 1, December 9,1988 " BWR Owner's Group Technical Specification Improvement Methodology (with Demonstration for BWR ECCS Actuation Instrumentation)"-(ECCS) 13. NEDC-30936P-A Part 2, February 1987, "BWR Owner's Group Technical Specification Improvement Methodology (with Demonstration for BWR ECCS Actuation Instrumentation)". (ECCS) L 14. NRC-SER of GE Topical Report NEDC-30936P-A Part 2, December 9,1988, "BWR Owner's Group Technical Specification Improvement Methodology (with Demonstration for BWR ECCS Actuation Instrumentation)". (ECCS) 15. 0G90-319-32D/MFN 024-90, March 22,1990, Letter form GE to M.L.Wohl (NRC), " Clarification of TS Changes Given in'ECCS Actuation Instrumentation Analysis". (ECCS, RCIC) 16. RE-Oll, Rev.1, " Technical Specification Improvement Analysis for the ECCS Actuation Instrumentation for BSEP Units 1 and 2" (Enclosure 7 to j-the submittal) (ECCS) 17.- GENE-770-06-1, " Bases for changes to Surveillance Test Intervals and Allowed Out-of-Service times for selected Instrumentation Technical Specifications". (Rod Block, Control Room Ventilation System, ATWS-RPT, i EOC-RPT) 18. NRC-SER dated July 21, 1992.

• GE Topical GENE-770-06-1, " Bases for Changes to Surveillance Test im.ervals and Allowed Out-of-Service times for Selected Instrumentation Technical Specifications".(Rod Block, Control Room Ventilation System, ATWS-RPT, E0C-RPT) i

ll } c j 17 - i 19. NEDC-30851P-A, Supplement 1, October 1988, " Technical Specification. i Improvement Analysis for.BWR Control Rod Block Instrumentation".(Rod- ~ B1ock, Control Room Ventilation System, ATWS-RPT, EOC-RPT)

20..

NRC-SER dated September 22,.1988, for GE Topical, NEDC-30851P-A,~- 1f Supplement 1, October 1988, " Technical Specification Improvement l Analysis for BWR Control Rod Block Instrumentation".(Rod Block, Control .l Room Ventilation System, ATWS-RPT, EOC-RPT)_ 21. GENE-770-06-2P-A, December 1992,, " Addendum to Bases for Changes to i Surveillance Test Intervals and Allowed Out-of-service Times for Selected Instrumentation Technical Specifications". (RCIC) ,22. NRC-SER, July 30,1992 and September 13, 1991, for GE Topical Report, GENE-770-06-2P-A, December 1992,, " Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications". (RCIC) 1

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments. The State 1 official had no comments. 1

7.0 ENVIRONMENTAL CONSIDERATION

i The amendments change a requirement with respect to installation.or use of a ' facility component located within the restricted area as defined in 10 CFR Part 20 and changes the Surveillance Requirements. 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, and there has been no public comment on such finding (59 FR 63114). ~Accordingly, the amendments meet the eligibility criteria for j categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR l 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments. \\

8.0 CONCLUSION

I i The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the l public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor: S. V. Athavale i Date: March 30, 1995 l 1 i i 4 -r-w -r .-~ .w, y -. - -,,,}}