Text

Application for Amends to Licenses DPR-71 & DPR-62,revising TSs to Format Consistent w/NUREG-1433,rev 1.Vols 1-15 of Improved TSs Encl
	ML20134G083
Person / Time
Site:	Brunswick
Issue date:	11/01/1996
From:	Campbell W; CAROLINA POWER & LIGHT CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20134G085	List: BSEP-96-0414, Application for Amends to Licenses DPR-71 & DPR-62,revising TSs to Format Consistent w/NUREG-1433,rev 1.Vols 1-15 of Improved TSs Encl;
References
	RTR-NUREG-1433 BSEP-96-0414, BSEP-96-414, NUDOCS 9611130037
	Download: ML20134G083 (34)
	v • d • e

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t Coreline Power & Ligitt Company Williom R. Campbell PO Box 10429 Vice President Southport NC 23461-0429 Brunswick Nuclear Plant j

SERIAL: BSEP 96-0414 10 CFR 50.90 TSC 96TSB02 NOV 011996 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk j

Washington, DC 20555

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BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUESY FOR LICENSE AMENDMENTS CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS Gentlemen:

t in accordant,e with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and ? These proposed amendments i

revise the Brunswick Plant Technical Specifications to a format consistent with NUREG-1433, Revision 1, " Standard Technical Specifications for General Eleric Plants, BWR 4."

The proposed amendment also extends the frequency of selects

.rveillance Requirements to 24 months to support conversion of the Brunswick Plant to a 2, onth fuel cycle.

The detailed description and justification for the proposed Technical Specification amendment consists of 15 volumes. A detailed description of the contents and organization of the 15 i

volumes is included as Attachments 1 through 4 of this letter. These attachments include:, Brunswick Unit 1 and Unit 2 Improved Technical Specification (ITS)

Submittal Synopsis, which describes the organization and content of the submittal and

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the organization and content of each of the-15 volumes. This attachment is designed to facilitate distribution of each section within the NRC and to familiarize reviewers with the content and organization of each section., Brunswick Unit 1 and Unit 2 ITS Conversion Document Status, which describes and provides the status of pending changes, including changes to be submitted, to the Brunswick Current Technical Specifications (CTS) that are incorporated t

nto this amendment request. This attachment also provides a list of the proposed gg beneric changes to NUREG-1433, Revisions 1, that are incorporated into the Brunswick ITS amendment request. In addition, Attachment 2 includes anticipated changes to the Brunswick CTS that may be submitted during the course of NRC review. This information is in inded to facilitate Brunswick and NRC c mment control during the Brun7 ck ITS i

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l ADO O

j Tel 910 457-249 ax 910 AS7-2803 f0k

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n Document Control Desk BSEP 96-0414 / Page 2 review and approval process.

, Significant Deviations From NUREG-1433 and Brunswick CTS. The purpose of this attachment is to identify those changes which are beyond the scope of both NUREG-1433 and the Brunswick CTS and either have or are being submitted separately from this license amendment request.

l, Evaluations Used to Justify 24-Month Surveillance Requirement Frequencies. This attachment provides a detailed description of the methodology used to justify the extension of the frequency of selected Surveillance Requirements to 24 months to support conversion of the Brunswick Plant to a 24-month fuel cycle.

As a part of the overall conversion effort, CP&L is adopting numerous new Surveillance Requirements (SRs). The new SRs are grouped into two categories (Category A and Category B SRs). Category A SRs are those SRs which are new in their entirety compared to current

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Brunswick Plant Technical Specifications. Category B SRs are those current SRs which have been revised with ITS in some manner to be more restrictive than the current Technical Specifications require. provides a Listing of More Restrictive and New Surveillance Requirements divided into Category A and Category B types. CP&L will be reviewing each Category A and B SR to determine which will not be current upon ITS implementation, based on the projected Brunswick ITS implementation date. CP&L intends to have as many of these more restrictive surveillances current upon ITS implementation as practical; however, due to difficulties in determining the exact status of the plant and the variables associated with implementation (e.g.,

whether or not all of the more restrictive changes will be approved as currently written), CP&L proposes that the Category A changes are assumed to be performed and met, in accordance with ITS SR 3.0.1, upon implementation of the ITS. Accordingly, the initial due dato for each Category A SR will be determined based on: 1) the ITS implementation date,2) the ITS frequency of the SR and 3) SR 3.0.2. CP&L also proposes that the more restrictive Category B SRs are assumed to be performed and met, in accordance with ITS SR 3.0.1, upon implementation of the ITS. Accordingly, the due date for each Category B SR will be determined based on: 1) the last completion date of the associated CTS SR,2) the ITS frequency of the SR and 3) SR 3.0.2.

CP&L has determined that the approach discussed above will maintain compliance with the ITS and also provide the flexibility needed to implement the numerous new and more restrictive SRs which we have included as a part of our conversion to the Improved Standard Technical I

Specifications. provides the proposed changes to the Unit 2 Operating License to allow single i

recirculation loop operation. Included in this attachment is a mark-up of the Unit 2 license condition and a discussion of the change.

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Implementation of the proposed amendments is tentatively scheduled for the fourth quarter of 1997 and is based on: 1) the training schedules for licensed and non-licensed personnel,

Document Control Desk BSEP 96-0414 / Page 3

2) timing of the implementation with respect to refueling outages,3) the licensed operator examination schedule,4) the time required for procedure revisions and development of new programs,5) implementation of power uprate of both units, and 6) implementation of the Long-Term Thermal Hydraulic Insh 2ility resolution at the Brunswick Plant. Brunswick Plant ITS implementation is also predicated on NRC issuance of a Safety Evaluation by July 1997, along with issuance of Safety Evaluations for the pending changes, including those changes to be submitted, which have been incorporated into the ITS (see Attachment 2). CP&L will inform the NRC staff when the ITS implementation actions are complete.

l Carolina Power & Light Company has determined that Um proposed changes do not involve a significant hazards consideration. The evaluations for making this determination are included with each specification. CP&L has also provided an environmental evaluation for each specification which demonstrates that the proposed amendments meet the eligibility for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

an environmental assessment of the proposed changes is not required.

Carolina Power & Light Company is providing, in accordance with 10 CFR 50.91(b), Mr. Dayne l

H. Brown of the State of North Carolina with a copy of the proposed license amendments.

Please refer any questions regarding this submittal to Mr. Mark Turkal at (910) 457-3066.

Sincerely,

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W

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William R. Campbell KAH/kah Attachments: 1 Through 6

Enclosure:

Improved Technical Specifications Conversion Document - Brunswick Units 1 and 2 (15 Volumes) i

Document Control Desk BSEP 96-0414 / Page 4

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William R. Campbell, having been first duly sworn, did depose and say that the information contained heroin is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power & Light Company.

ia ilotary (S(a))

t My commission expires:

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U. S. Nuclear Regulatory Commission ATTN.: Mr. Stewart D. Ebneter, Regional Administrator 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323-0199 l

Mr. C. A. Patterson NRC Senior Resident inspector - Brunswick Units 1 and 2:

U.S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738 The Honorable H. Wells i

Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Dayne H. Brown Director - Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources P.O. Box 27687 Raleigh, NC 27611-7687 U.S. Nuclear Regulatory Commission (6 copies)

ATTN.: Mr. Christopher I. Grimes (Mail Stop OWFN 11 E22) 11555 Rockville Pike Rockville, MD 20852-2738 1

ATTACHMENT 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING I ICENSE NOS. DPR-71 AND DPR-62 REQUEST s JR LICENSE AMENDMENTS IMPROVED TECHNICAL SPECIFICATION (ITS) SUBMITTAL SYNOPSIS The CP&L Brunswick Plant Improved Technical Specification (ITS) submittal consists 15 volumes. This attachment describes each component of the Brunswick Plant ITS submittal, and their organization within each volur.'e. This attachment is designed to facilitate distribution of each Brunswick ITS section within the NRC and to familiarize reviewers with the content and l

organization of each section. A description of each volume included in the Brunswick Plant ITS l

submittal follows.

Volume 1:

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Volume 1 contains the Application of the Technical Specification Selection Criteria and a i

Relocation Matrix. This document lists each of the Brunswick Plant Current Technical Specifications (CTS) and shows the results of CP&L's application of the 10 CFR 50.36 c+ria for retention of requirements in Technical Specifications. For each of the Brunswick Piara GTS, this document identifies whether or not the requirement is retained in the Brunswick ITS, and the basis for its retention or exclusion. For those CTS items that did not meet the selection criteria and have not been retained in the proposed ITS, a detailed explanation of the application of the selection criteria and justification for relocation is provided. The Relocation Matrix provides the document location for each relocated CTS requirement.

Volumea 2 through 15:

Volumes 2 through 15 contain the Brunswick Improved Technical Specifications and associated supporting documentation for the proposed amendment request. The volumes are ordered on a Chapter /Section basis, as follows, to facilitate distribution to NRC staff reviewers:

Volume 2:

Brunswick ITS Chapter 1.0, Use and Application Chapter 2.0, Safety Limits Section 3.0, Limiting Condition for Operation Applicability and Surveillance Requirement Applicability Volume 3:

Brunswick ITS Sections 3.1, Reactivity Control Systems 3.2, Power Distribution Limits Volumes 4. 5. & 6:

Brunswick ITS Section 3.3, instrumentation Volume 7:

Brunswick ITS Section 3.4, Reactor Coolant System A1-1

y_olume 8 Brunswick ITS Section 3.5, Emergency Core Cooling Systems and Reactor Core Isolation Cooling System Volumes 9 & 10; Brunswick ITS Section 3.6, Containment Systems Volume 11:

Brunswick ITS Section 3.7, Plant Systems Volumes 12 & 13:

Brunswick ITS Section 3.8, Electrical Systems Volume 14:

Brunswick ITS Sections 3.9, Refueling Operations 3.10, Special Operations Volume 15:

Brunswick ITS Chapter 4.0, Design Features Chapter 5.0, Administrative Controls Each volume contains the Unit 1 and Unit 2 Brunswick ITS Specifications and Bases, a mark-up of the Brunswick CTS, a discussion of changes to the Brunswick CTS, the No Significant Hazards Evaluations for each of the changes to the CTS, Environmental Assessments for changes to the CTS, and mark-up of NUREG-1433, Revision 1 to indicate the Brunswick ITS and justifications for deviations from the NUREG. Each Chapter /Section in a volume is organized as follows:

l Tab. Brunswick Unit 1 Imoroved Technical Soecifications This tab contains the proposed Brunswick Unit 1 Improved Technical Specifications.

l Tab: Danswick Unit 1 Imoroved Technical Soecification Bases (as aoolicable)

This tat, contains the proposed Brunswick Unit 1 Improved Technical Specification Bases.

Tab: Brunswick Unit 2 Imoroved Technical Soecifications This tab contains the proposed Brunswick Unit 2 Improved Technical Specifications.

Tab: Brunswick Unit 2 tmoroved Technical Soecifications Bases (as acolicable)

This tab contains the proposed Brunswick Unit 2 Improved Technical Specification Bases.

Tab : Markuo of Brunswick Unit 1 and Unit 2 Current Technical Soecifications and Discussion of Chanaes Beina Made to the Brunswick CTS This tab contains a copy of the Brunswick Unit 1 and Unit 2 CTS pages annotated to provide a cross-reference to the equivalent Brunswick ITS requirement, showing the disposition of the existing requirements into the Brunswick ITS.

The annotated copy of the Brunswick CTS pages are marked with sequentially numbered

" clouds" which provide a cross-reference to a Discussion of Changes (DOCS) between the Brunswick CTS and the Brunswick ITS. The ITS number is noted on the top right corner of each CTS page, identifying the ITS LCO where the CTS requirement is located.

Items on the CTS page that are located in one or more ITS locations or sections have the A1-2

appropriate location (s) noted adjacent to the items. When the ITS requirement differs from the CTS requirement, the CTS being revised is annotated with an alpha-numeric designator. This designator relates to the appropriate DOC. Each DOC provides a justification for the proposed change. The DOC for each ITS section immediately follows the marked up CTS pages. The alpha-numeric designator also relates the proposed change to the applicable No Significant Hazards Eduation (NSHE). An Environmental Assessment is also provided for each specification.

The alpha-numeric designator is based on the category of th6 sange and a sequential number within that category. The changes to the Brunswick CT3 are categorized =

follows:

A ADMINISTRATIVE - associated with restructuring, interpretation, and complex rearranging of requirements, and other changes not substantially revising an existing requirement. There is a single No Significant Hazards Evaluation (NSHE) for this category.

M TECHNICAL CHANGES - MORE RESTRICTIVE - changes to the CTS Deing proposed in converting to the ITS, resulting in added restrictions or eliminating flexibility. There is a single NSHE for this category.

L TECHNICAL CHANGES - LESS RESTRICTIVE - changes where requirements are relaxed, relocated, eliminated, or new flexibility is provided.

There are two groups of changes " Generic" and " Specific"in this category.

Each " Specific" LESS RESTRICTIVE change has a corresponding unique No Significant Hazards Evaluation (NSHE). The " Generic" LESS RESTRICTIVE changes are subdivided into 6 subcategories, each of which is identified uniquely as either LA, LB, LC, LD, LE, or LF changes. Each subcategory of

" Generic" LESS RESTRICTIVE change is justified by a single NSHE. The subcategories and their designation are as follows:

The "LA" changes consist of relocation of details out of the CTS and into the Bases, UFSAR, QA Manual, procedures, or other plant controlled documents. Typically, this involves details of system design and function or procedural details on methods of conducting a surveillance.

The "LB" changes are related to the extension of an instrument Completion Time or Surveillance Frequency in accordance with NRC approved vendor topical reports.

The "LC" changes reflect elimination of various instrumentation requirements, where the instrument is an alarm or an indication-only instrument function that does not otherwise meet the NRC Technical Specification selection criteria.

The "LD" changes reflect extension of the refueling outage surveillance interval from 18 months to 24 months for surveillances other than Channel Calibrations.

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The "LE" changes reflect extension of the refueling outage surveillance interval from 18 months to 24 months for Channel Calibration surveillances.

The "LF" changes reflect modifying the instrumentation Allowable Values to be consistent with the current calculations performed in accordance with the plant specific setpoint methodology.

R RELOCATED - specific requirements that do not meet the NRC Technical Specification selection criteria. These items are being relocated to other plant documents as part of the conversion to ITS. There is a single NSHE for this category.

Tab: Markuo of NUREG-1433. Revision 1 Technical Soecifications and Justifications for Deviations This tab contains a copy of NUREG-1433, Revision 1, Technical Specifications which have been annotated to indicate deviations between the NUREG (as modified by generic changes identified in Attachment 2 of this letter) and the proposed Brunswick ITS.

Justifications for each of the deviations are provided with the individual ITS Chapters / Sections. The annotated copy of NUREG-1433, Revision 1, and the discussion of the deviations are cross-referenced by " clouds" which are numbered sequentially for each Chapter /Section.

Each line item in the annotated copy of NUREG-1433, Revision 1, Technical Specifications contains a cross-reference to the equivalent Brunswick CTS requirem+nt and/or discussion of change, as appropriate. This cross-reference is intended to p. wide reviewers with a quick reference to the equivalent CTS section.

l 1

Tab: Markuo of NUREG-1433. Revision 1 Technical Soecifications Bases and Justifications for Deviations l

This tab contains a copy of NUREG-1433, Revision 1, Technical Specifications Bases which have been annotated to indicate deviations between the NUREG Bases (as modified by generic changes identified in Attachment 2 of this letter) and the proposed Brunswick ITS Bases. Justifications for the deviations are provided with the individual ITS Chapters / Sections. The annotated copy of NUREG-1433, Revision 1, and the discussion of the deviations are cross-referenced by " clouds" which are numbered sequentially for each Chapter /Section.

l Tab: No Sianificant Hazards Evaluations l

This tab contains the required 10 CFR 50.92 No Significant Hazards Evaluations i

(NSHEs) for the proposed changes and demonstrates that the changes associated with the corresponding ITS section do not constitute a significant hazard consideration. As described for the DOC, the NSHEs are categorized as Administrative, Relocated, More Restrictive, Less Restrictive - Generic, and Less Restrictive - Specific, and are identified by an alpha-numeric designator relating the marked-up CTS and the DOC to the 1

applicable NSHE.

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This tab also includes an Environmental Assessment for each ITS specification and demonstrates that the proposed amendments meet the eligibility for categorical exclusion -

set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed changes is not required.

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ATTACHMENT 2 r

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS i

BRUNSWICK ITS CONVERSION DOCUMENT STATUS l

This attachment identifies 1) a listing of CTS changes that are pending approval from the NRC which have been included in the Brunswick Plant ITS submittal, including changes which will be l

i submitted, 2) generic NUREG changes which have been included in the Brunswick Plant ITS submittal,3) approved generic NUREG changes which have not been included in the Brunswick Plant ITS, and 4) the submittals that CP&L intends to make during the course of the NRC review of the Brunswick Plant ITS which have not been included in the Brunswick Plant ITS submittal, 1.

Technical Soecification Chance Reauests Pendina NRC Acoroval Which Have Been i

included in the Brunswick Plant ITS Submittal i

TSC 87TSB16:

Generic Letter 87-09 Implementation 4

TSC 91TSB13:

Generic Letter 91-09 Implementation i

TSC 94TSB14:

Deletion of Requirements for Suppression Chamber Average Temperature Monitoring Instrumentation l

l TSC 94TSB16:

Power Uprate TSC 95TSB32:

Unit 1 Fuel Cycle 11 Reload Licensing TSC 96TSB03:

Thermal Hydraulic Instability Long-Term Resolution - Enhanced Option i

l-A Stability Technical Specifications 2.

Technical Soecification Chance Reauests Which Have Been included in the Brunswick Plant ITS Submittal And Are Exoected To Be Submitted Bv November 22.1996 TSC 95TSB06:

Pressure-Temperature Limits Curves TSC 95TSB36:

Reactivity Anomalies TSC 96TSB01:

Drywell Air Temperature TSC 96TSB07:

Suppression Chamber Water Volume TSC 96TSB09:

Instrumentation Allowable Value Revision l

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3.

Technical Soecification Task Force (TSTF) Generic Chanaes incoroorated in The Brunswick Plant ITS Submittal TSTF-05:

Deletes Safety Limit violation notification requirements.

TSTF-17:

Extension of testing frequency of containment airlock interlock mechanism from 184 days to 24 months.

TSTF-32:

Slow / Stuck Control Rod separation criteria.

TSTF-33:

Specification 3.1.3, Required Action A.2 Completion Time Note.

TSTF-34:

Delete requirements to disarm the associated CRD when two or more withdrawn control rods are stuck.

TSTF-35:

Recirculation pump start RPV temperature limits verification Note.

TSTF-36:

Addition of LCO 3.0.3 N/A to shutdown electrical power specifications.

TSTF-38:

Revise visual surveillance of batteries to specify that inspection is for performance degradation.

4.

TSTF Acoroved Generic Chanaes Not incorocrated in The Brunswick ITS Submittal TSTF-60:

RCS Leakage Detection Instrumentation LCO 3.0.4 N/A Note.

l TSTF-106: Diesel Fuel Oil Testing Program Clarification.

5.

Technical Soecificaljon Chanaes Which The Brunswick Plant Currentiv Plans To Submit To The NRC Staff Durina The Brunswick ITS Review Period Not included in The Brunswick Plant ITS Submittal 96TSB05: 4.16kV / BOP E-Bus Allowed Outage Time Revision 97TSB01: Unit 2 Fuel Cycle 13 Reload Licensing 96TSB10: EDG Compliance With Safety Guide 9 A2-2

ATTACHMENT 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS SIGNIFICANT ITS DEVIATIONS FROM THE BRUNSWICK CTS AND NUREG-1433. REV.1 This attachment provides a list of the Brunswick Plant ITS changes which represent significant deviations from both NUREG-1433, Revision 1, and the Brunswick Plant current Technic d Specifications.

1.

Enhanced Option I-A Stability Technical Specifications provided in ITS 3.2.3, 3.3.1.1, 3.3.1.3, and 5.6.5. These changes are also submitted in a separate Technical Specification Change Request (96TSB03).

2.

Pressure Temperature Limits Curves are updated in ITS 3.4.9. These changes are also submitted in a separate Technical Specification Change Request (96TSB06) 3.

ECCS Allowed Outage Times in ITS 3.5.1 are revised to reflect the current licensing basis SAFER /GESTR analyses described in the UFSAR.

4.

CAD System requirements in current Technical Specification 3/4.6.6.2 are relocated based on the current Brunswick Plant specific licensing basis related to Generic Letter 84-09.

5.

Service Water System Allowed Outage Times are revised in ITS 3.7.2 to reflect more consistent application of current approved analyses.

6.

Ultimate Heat Sink Temperature Limits and Allowed Outage Times in ITS 3.7.2 are provided which are more restrictive than current Technical Specification requirements but which reflect current administrative practice.

7.

Control Room Emergency Ventilation System Actions are revised in ITS 3.7.3 to be consistent with existing plant specific analyses.

8.

Primary Containment Leakage Rate Testing Program are updated in ITS 5.5.12 to reflect currently approved exemptions to 10 CFR 50, Appendix J.

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ATTACHMENT 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2' I

NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 3 -

REQUEST FOR LICENSE AMENDMENTS 1

JUSTIFICATION OF 24-MONTH SURVEILLANCE REQUIREMENT FREQUENCIES i

i I.

PURPOSE:

j To accommodate a planned change to a 24 Month Fuel Cycle for the Brunswick Nuclear i

Units 1 and 2, Carolina Power & Light (CP&L) is integrating the necessary changes to the BNP Units 1 and 2 Technical Specifications into the documents being used to convert to l

NUREG 1433, Standard Technical Specification for General Electric BWR 4. To facilitate j

the review of the 24 Month Fuel Cycle portion of this submittal, the following overview document is being provided to identify the scope of changes and the methodology used 2

to justify the changes.

The proposed Technical Specification changes were evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24 Month Fuel Cycle," dated April 2,1991.

11.

SCOPE:

i The 24 Month Fuel Cycle portion of this submittal includes a justification, when the SR I

Frequency is being changed, for all existing BNP Current Technical Specification (CTS)

Surveillance Requirements (SRs) that are being retained in the BNP Improved Technical Specifications (ITS) which have a BNP CTS Frequency of 18 months. In addition, some instrument's which are currently being calibrated on a quarterly basis are also being extended to a 24 month Channel Calibration Frequency using this same methodology.

4 These changes have been divided into two categories. The categories are: (1) changes involving the Channel Calibration Frequency identified as " Instrumentation Changes" (identified in the ITS Conversion document discussion of changes as "LEs"), and (2) other changes identified as "Non-Instrumentation Changes" (identified in the ITS Conversion document discussion of changes as "LDs").

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METHODOLOGY:

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in Generic Letter 91-04, dated April 2,1991, the Nuclear Regulatory Commission (NRC) provides generic guidance for evaluating going to a 24 Month Surveillance Test Interval for Technical Specification SRs. Generic Letter 91-04 specifies the steps for the evaluation needed to justify a 24 month surveillance interval. The following defines each step outlined by the NRC and provides a description of the methodology used by CP&L to complete the evaluation for each specific Technical Specification SR line itam.

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A.

Non-Instrumentation (LDs):

Generic Letter 91-04 identifies three steps to evaluate Non-Instrumentation:

STEP 1:

" licensees should evaluate the effect on safety of the change in surveillance intervals to accommodate a 24 month fuel cycle."

CP&L EVALUATION CP&L has evaluated each SR being changed. This evaluation provides a specific justification for each BNP CTS non-instrumentation SR which is being retained in BNP -

ITS. The evaluation is summarized in the discussion of change identified as "LDs". The following information provides a description of the purpose of surveillance testing and a general description of the methodology utilized.

The purpose of surveillance testing is to verify through the performance of the specified SRs that the tested Technical Specification Function / Feature will perform as assumed in the associated safety analysis or in accordance with the associated Function's design.

By periodically testing the Technical Specification Function / Feature, the availability of the associated Function / Feature is confirmed. As such, with the extension of BNP's operating cycle and the associated extension of the refueling cycle surveillance test interval (Frequency), a longer period of time will exist between performances of the surveillance test. If a failure resulting in the loss of a Safety Function occurs during the operating cycle and that failure would be detected only by the performance of the periodic Technical Specification SR, then the increase in the surveillance testing interval would result in a decrease in the associated Function's availability and thus have a potential impact on safety.

CP&L evaluated each associated SR to demonstrate that the potentialimpact, if any, on availability is small as a result of the change to a 24 month Frequency. The evaluations were based on the fact that the Function / Feature is tested on a more frequent basis during the operating cyclo (e.g., functionally tested quarterly), is designed to be single failure proof, or is highly reliable.

STEP 2

" Licensees should confirm that historical maintenance and surveillance data do not invalidate this conclusion".

CP&L EVALUATION CP&L has evaluated the surveillance test history of the affected SRs. This evaluation consisted of a review of the surveillance test results. Only SR test failures were evaluated because failures detected by other plant activities such as Preventative Maintenance Tasks or Surveillance Tests that are more frequent than 18 months were assumed to continue to detect failures. This review of surveillance test history validated the conclusion that the impact, if any, on system availability will be small as a result of the change to a 24 Month Fuel Cycle.

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STEP 3

" Licensees should confirm that the performance of surveillance's at the bounding surveillance intervallimit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis."

CP&L EVALUATION As part of the evaluation of each SR, CP&L reviewed the impact of these changes against assumptions in BNP licensing basis. In general, these changes have no impact on the plant licensing basis. However, in some cases, the change may require a change to commitments described in the BNP Updated Final Safety Analysis Report (UFSAR). If changes were required they are identified in the associated Discussion of Changes.

B.

Instrumentation (Channel Calibrations (LEs)):

Generic Letter 91-04 identifies seven steps for the evaluation of instrumentation changes (LEs).

1 STEP 1

" Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval."

CP&L EVALUATION CP&L evaluated the effect of longer calibration intervals on the TS instrumentation by performing a review of the surveillance test history for all instrumentation including, where necessary, instrument drift. The failure history evaluation and drift study demonstrates, except on rare occasion that, instrument drift has not exceeded the current allowable limits. In performing the drift study an effort was made to retrieve all recorded Channel Calibration data for associated instruments, when available, for the past several operating cycles. By obtaining all recorded calibration data for the past several cycles of operation, a true representation of instrument drift can be determined.

STEP 2

" Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data."

CP&L EVALUATION CP&L has performed a drift evaluation, where necessary, using calibration data obtained from surveillance tests of affected BNP ITS instrument by make, model number, and range.

The CP&L drift evaluation was performed using a computer model for drift determination A4-3 I

developed by General Electric (GE) and based on NEDC-31336, "GE instrument Setpoint Methodology". This document was submitted to the NRC, and approved.

The Boiling Water Reactor Owners' Group (BWROG) committee for Calibration interval Extension determined that the drift module of the GE Instrument Setpoint Methodology could be used to determine instrument drift for periods longer than 18 months based on actualinstrument performance in plant environments. GE, under the direction of the BWROG Calibration Interval Extension committee, developed the " General Electric 7

Instrument Trending Analysis System"(GEITAS). This quality assured program has been used to determine the drift for other plants including Limerick Generating Station and Peach Bottom Atomic Power Statien, which both received approval for the extension of Channel Calibration SRs using this program.

A copy of the verified and validated GEITAS program was obtained from GE and was used to project the thirty month drift number. The as-found and as-left data was taken i

from instrument calibration surveillance tests and was analyzed. The analysis included a review of the data points to determine any data points which would not provide a true indication of instrument drift, a change in the input / output relationship over time. If adjustments or elimination of data points were made, these changes were placed into one of the following seven (7) catemrizes: (1)" Clerical Data Entry problem" (Review identified typographical data entry enror. Data point was adjusted ta correct the error.),

(2)" Technician dats entry problem" (Review identified an obvious transposition error by the Technician entering the data. Data point was eliminated based on the data entry error.), (3)"New Instrument" (Review identified that new instrument was installed. Data point "As-found" data was zeroed because this data would not be reflective of drift. Any repetitive instrument failures would be identified in the Surveillance Test History Review.),

(4)" Chronic instrument problem" (Review of the data indicated repetitive bad data points for a single instrument with excessive changes in the input / output relationship, while all other instruments in the same application did not exhibit the same characteristics. This instrument's data was eliminated based on a unique instrument problem. Any repetitive instrument failures would be identified in the Surveillance Test History Review.), (5)"Out of Calibration Test Equipment" (Review indicated that the instrument was calibrated with an out of calibration instrumer.t. Data point was eliminated based on the fact that any recorded change could not be correlated to the performance of the instrument), (6)" Poor Calibration Methodology", (Review of the calibration methodology identified that the method of calibration would result in inconsistent and untrendable calibration results.

Data points calibrated using these techniques were eliminated based on the fact that any recorded change could not be correlated to the performance of the instrument.), and (7)" Poor Calibration Techniques", (Review identified that poor calibration techniques were used. Data point was eliminated based on the fact that any recorded change could not be correlated to the performance of the instrument.) All eliminated data points were individually evaluated and independently verified to meet these categories if they were adjusted or eliminated. Poor Calibration Methodology and Poor Calibration Techniques have been corrected through procedure revisions, training and increased supervisory over sight. The analysis produced values at intervals from one to thirty months or greater. The drift value was then compared with the drift uncertainty associated with the i

specific instrument setpoint analysis.

The results of the GEITAS evaluations showed acceptable 30 month drift values that were within setpoint analysis drift allowances in those cases where there was a sufficient A4-4

amount of historical data to satisfy the computer algorithms and the majority of the as-found and as-left values were within acceptable limits.

In some cases, a different methodology was utilized to demonstrate that the drift was acceptable. These cases included instruments that were recently installed or where the GEITAS program could not be applied. For each instrument where the GE program was not utilized to evaluate the drift data, a summary of the methodology is contained in the specific discussion of change ("LE.x").

STEP 3

" Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications."

CP&L EVALUATION in accordance with the methodology described in the previous section, the magnitude of instrument drift has been determined with a high degree of probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument make and model number. As required by the GEITAS software, a review was performed to ensure that there were greater than 30 data points in the data set used to perform the statistical analysis. If less than 30 data points were used in the data set, a discussion is provided in the associated discussion of change (LE.x) to provide further support for the change to a 24 month Channel Calibration frequency. The associated instruments for each affected BNP ITS SR are listed in the corresponding discussion of change ("LEs").

j STEP 4 e

" Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to i

accommodate larger drift errors, provide proposed TS changes to update trip setpoints.

if the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded."

l CP&L EVALUATION The calculated drift value was compared to the allowances for the associated instruments as calculated in the associated setpoint analysis. Some of these analysis were completed during the performance of the 24 month drift evaluation, and therefore, data obtained from the drift study was utilized in the setpoint analysis. Changes to the setpoint values are identified as "LF" discussion of changes. If the calculated drift for an instrument fell outside the allowance for drift, the surveillance test interval was changed to a frequency which was supported by the projected drift or was extended to a 24 month Channel Calibration Frequency based on other justifications. If an instrument was not in service long euugh to establish a calculated drift number, the surveillance interval was i

extended to a 24 month interval based on other, more frequent testing or justification j

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obtained from the instrument manufacturer.

STEP 5 i

" Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation."

CP&L EVALUATION As discussed in the previous sections, the calculated drift values were compared to drift allowances in the setpoint analysis developed in support of the improved Technical Specification submittal. In all cases, it was found that the calculated drift fell within the assumptions of the setpoint analysis or the SR Frequency was not increased, or the SR Frequency was increased based on other justification. Therefore, in no case was it necessary to change the existing safe shutdown analysis to accommodate a larger drift error.

STEP 6

Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for Channel Checks, Channel Functional Tests, and Channel Calibrations."

CP&L EVALUATION As part of the implementation of the improved Technical Specification project, all surveillance test procedures are being reviewed and updated to incorporate the necessary changes to the surveillance test procedures. The changes implemented as a result of the development of new setpoint analysis will also be incorporated into the surveillance procedure prior to the implementation of the improved Technical Specifications and the 24 month operating cycle surveillance test frequency.

STEP 7

Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety."

CP&L EVALUATION Instruments with Technical Specification calibration surveillance frequencies extended to 24 months will be monitored to identify occurrences of instruments found outside of Allowable Value. As-found and as-left calibration data will be recorded for each calibration activity. When as-found conditions are outside allowable value, an evaluation will be performed to determine if the assumptions made to extend the calibration frequency are still valid and to evaluate the effect on plant safety.

As described in the above discussion, CP&L has completed the evaluations necessary to justify a change in surveillance intervals needed to support a 24 Month Fuel Cycle, and CP&L A4-6

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l has determined that these evaluations conform to guidance provided in Generic Letter 91-04.

l The specific evaluations for each BNP CTS SR being changed is contained in the associated ITS conversion discussion of change identified as "LD.x" and "LE.x" In addition, a No l

Significant Hazards Evaluation, in accordance with 10 CFR 50.92, has been performed for the j

changes annotated as "LDs" and "LEs".

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ATTACHMENT 5 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS NEW ITS AND MORE RESTRICTIVE CTS SURVEILLANCE REQUIREMENTS i

4 As a part of the overall conversion effort, CP&L is volunteering to adopt numerous new Surveillance Requirements (SRs). The new SRs are grouped into two categories (Category A and Category B SRs). Category A SRs are those SRs which are new in their entirety compared to current Brunswick Plant Technical Specifications. Category B SRs are those current SRs which have been revised with ITS in some manner to be more restrictive than the current Technical Specifications require. This attachment provides a Listing of More Restrictive Surveillance Requirements divided into Category A and Category B types.

4 CATEGORY A NEW SURVElLLANCE REQUIREMENTS SR NUMBER TITLE CHANGE ITS SR 3.1.4.3 is added which requires scram time Control Rod Scram Timing at testing of the affected control rods with any reactor 3.1.4.3 any Reactor Pressure steam dome pressure be performed prior to declaring the control rods OPERABLE.

d 3.1.6.1 Verifies control rods comply with the BPWS.

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A Surveillance is added (ITS SR 3.3.1.1.7) to CTS Table 4.3.1 1 for the IRM Neutron Flux - High APRM to IRM Overlap Test Function and the APRM Neutron Flux-High, Startup j

3.3.1.1.7 Requirements Function. This Surveillance verifies proper overlap j

between the APRMs and IRMs when entering MODE 2 from MODE 1 (during a plant shutdown).

A Surveillance is added (ITS SR 3.3.1.1.14) to CTS Table 4.3.1 1 for the APRM Flow Biased Simulated

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3.3.1.1.14 Thermal Power - High Function (Function 2.b). This Time C ns a er fi tn surveillance verifies the APRM filter time constant is s 7 seconds once per 24 months.

SRM CHANNEL A requirement to perform a CHANNEL CAllBRATION 3 3.1.2.7 CALIBRATION Requirement every 24 months on SRM instrumentation (ITS SR during Refueling 3.3.2.1.7)is added for SRMs during MODE 5.

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CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE RBM Upscale Function A Surveillance is added (ITS SR 3.3.2.1.4) to verify 3.32.1.4 Interlock Surveillance each RBM Upscale Function is automatically enabled Requirement at the correct power level.

A Surveillance is added (ITS SR 3.3.2.1.5) to verify RWM Function interlock 3.3.2.1.5 the RWM Function is automatically enabled at the Surveillance Requirement correct power level.

Reactor Mode Switch -

ITS SR 3.3.2.1.6 is added to provide appropriate 33.2.1.6 Shutdown Position Surveillance Requirements for the Reactor Mode Surveillance Requirement Switch in Shutdown Position Function.

FW and Main Turbine High 3.3.2.2.1 Level Instrumentation Added CHANNEL CHECK Surveillance.

CHANNEL CHECK FW and Main Turbine High 3.3.2.2.2 Level Instrumentation Added CHANNEL CAllBRATION Surveillance.

CHANNEL CALIBRATION FW and Main Turbine High Level instrumentation LOGIC Added LOGIC SYSTEM FUNCTIONAL TEST 3.3.2.2.3 SYSTEM FUNCTIONAL Surveillance.

TEST Added CHANNEL CHECK Surveillance for Post Accident Monitoring Suppression Chamber Pressure and PCIV Position 3.3.3.1.1 instrumentation CHANNEL Functions in PAM Instrumentation Technical CHECK Specification.

Added CHANNEL CALIBRATION Surveillance for Post Accident Monitoring Suppression Chamber Pressure and PCIV Position 3.3.3.1.3 Instrumentation CHANNEL nctions in PAM Inr,trumentation Technical CAllBRATION Specification.

Drywell and Suppression A CHANNEL CHECK requirement is added (ITS SR Chambe ydrogen and 3.3.3.1.1 3.3.3.1.1) for '.ne drywell and suppression chamber hydrogen ar.d oxygen analyzers.

CHANNEL CHECK Added 24 hout CHANNEL CHECK Surveillance for 3.3.5.1.1 HPCI High Water Level Function in the ECCS H

E CHE K Instrumentation Technical Specification.

ECCS Instrumentation Added 92 day CHANNEL FUNCTIONAL TEST 3.3.5.1.2 CHANNEL FUNCTIONAL Surveillance for HPCI High Water Level Function in TEST the ECCS Instrumentation Technical Specification.

Added 92 day Trip Unit Calibration Surveillance for E

E 3.3.5.1.3 HPCI High Water Level Function in the ECCS U C Instrumentation Technical Specification.

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j CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE Added 2$ month CHANNEL CALIBRATION ECCS Instrumentation 3.3.5.1.4 Surveillance for HPCI High Water Level Function in

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CHANNEL CAllBRATION the ECCS Instrumentation Technical Specification.

l ECCS Instrumentation Added LOGIC SYSTEM FUNCTIONAL TEST 3.3.5.1.5 LOGIC SYSTEM Surveillance for HPCI High Water Level Function in FUNCTIONAL TEST the ECCS Instrumentation Technical Specification.

ITS SR 3.4.1.1 is provided to define what constitutes Recirculation Pump Speed

" matched speeds" and to verify that recirculation loop 3.4.1.1 Match Criteria Verification speeds meet the required match criteria once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

A new Surveillance Requirement (ITS SR 3.4.3.2) is 3.4.3.2 SRV Manual Actuation added which requires the SRVs to be manually actuated every 24 months.

RHR Shutdown Cooling - Hot Added a requirement to verify that one RHR SDC i

3.4.7.1 Shutdown Surveillance sulasystem is in operation or one recirculation pump is Requirement in operation.

l RHR Shutdown Cooling -

Added a requirement to verify that one RHR SDC 3.4,8.1 Cold Shutdown Surveillance subsystem is in operation or one recirculation pump is Requirement in operation.

ITS SR 3.4.9.6 is added to ensure the vessel head is Verification of Vessel Head 3.4.9.6 n t tensioned at too low a temperature once per Tensioning 30 minutes.

ITS SR 3.4.9.7 is added to ensure the vessel head Verification of Vessel Head 3.4.9.7 temperature does not exceed the minimum allowed Temperature temperature once per 30 minutes.

ITS SR 3.4 9.8 is added to ensure the vessel flange Venfication of Vessel Flange 3.4.9.8 temperature does not exceed the minimum allowed Temperature temperature once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

A new Surveillance Requirement (ITS SR 3.5.1.3)

Verification of ADS 3

which verifies the ADS pneumatic supply header Pneumatic Supply Pressure pressure is > 95 psig every 31 days is added.

ITS SR 3.5.2.1 is added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months '.nat Venfication of LPCI pump the suppression pool level is adequate to rnntain net 3.5.2.1 NPSH during shutdown positive suction head (NPSH) to the required LPCI subsystem.

j ITS SR 3.6.1.3.3 verifies circuit continuity of the TIP Shear Valve Continuity 3.6.1.3.3 transversing incore probe (TIP) shear isolation valve Test explosive charges.

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CATEGORY A NEW SURVElLLANCE REQUIREMENTS l

i SR NUMBER TITLE CHANGE TIP Shear Valve Explosive ITS SR 3.6.1.3.8 functionally tests the TIP shear valve 3.6.1.3.8 Squib Test explosive squib.

Verification of Suppression ITS SR 3.6.1.5.2 is provided to verify each vacuum 3.6.1.5.2 Chamber-to-Drywell Vacuum breaker is closed every 14 days.

Breaker Position Heat Sink Level 3.7.2.1 ITS SR 3.7.2.1 is added to verify UHS level.

i 3.7.2.2 ITS SR 3.7.2.2 is added to verify UHS temperature.

T p a u e V i cation I

Surveillance Requirement is added to verify every 24 Control Room AC System months that each control room AC subsystem is j

3.7.4.1 OPERABILITY Verification capable of maintaining the assumed humidity and removing the assumed heat load.

Main Turbine Bypass System Surveillance Requirement is added to verify monthly 3'7'6'1 Surveillance Requirements that each turbine bypass valve will open.

SumeWance Reqdmment is aMed to ve@ eyery 24 Main Turbine Bypass System 3.7.6.2 months that the Main Turbine Bypass System is Functional Test functionally OPERABLE.

Surveillance Requirement is added to verify every 24 TURBlNE BYPASS SYSTEM 3'7 m nths that the Main Turbine Bypass System can RESPONSE TIME Test respond in the time assumed in the safety analyses.

Check For Water ITS SR 3.8.1.5 is added to check for and remove any 3.8.1.5 Accumulation in DG Fuel Oil water accumulation in each DG fuel oil engine Engine Mounted Tanks mounted tank once every 31 days.

Automatic Transfer Test from ITS SR 3.8.1.8.a is added to verify every 24 months 3.8.1.8.a the Main Generator to the that on a main generator trip, the automatic transfer SAT from the UAT (normal mode) to the SAT will occur.

A new SR, ITS SR 3.8.1.12, is added for the test mode 3.8.1.12 DG Test Mode Override Test override feature associated with each DG once per 24 months.

j A new requirement to verify total particulates are s 10 Diesel Fuel Oil Particulate 3.8.3.2 mg/l every 31 days has been added to the Diesel Fuel Testing Oil Testing Program (ITS 5.5.9.c).

Check For Water ITS SR 3.8.3.3 is added to check for and remove any Accumulation in DG Day Fuel water accumulation in each DG day fuel oil storage 3.8.3.3 Oil Storage and the Main tank and the main fuel oil storage tank once every Fuel Oil Storage Tanks 31 days.

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CATEGORY A NEW SURVEILLANCE REQUIREMENTS I

SR NUMBER TITLE CHANGE Verification of Opposite Unit ITS SR 3.8.4.8 is added to ensure that the opposite I

Surveillance Performance unit's DC sources are properly tested during MODES 3.8.4.8 Associated with DC Sources-1,2, and 3; and that the proper SRs are applicable for Operating each unit's DC sources.

ITS SR 3.8.5.2 is added to ensure that the opposite Verification of Opposite Unit unit's DC sources are properly tested during MODES Surveillance Performance 3.8.5.2 4 and 5, and during movement of irradiated fuelin Associated with DC Sources-secondary containment; and that the proper SRs are i

Shutdown applicable for each unit's DC sources.

Control Rod Notch Insertion ITS GR 3.9.5.1 is added to verify weekly that any 3.9.5.1 Test During Refueling withdrawn control rods are capable of inserting.

Added a requirement to verify that one RHR SDC RHR-High Water Level subsystem is in operation during refueling with the 3m Surveillance Requirement reactor level high.

Added a requirement to verify that one RHR SDC RHR-Low Water Level 3.9.8.1 subsystem is in operation during refueling with the Surveillance Requirement reactor level low.

Surveillance added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , during Fully inserted Control Rod reactor mode switch interlock testing, all control rods 3.10.2.1 Verification during Mode inserted in core cells containing one or more fuel Switch Testing assemblies.

Verification of No Core Surveillance added to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , during 3.10.2.2 Alterations during Mode reactor mode switch interlocn testing, no CORE Switch Testing ALTERATIONS in progress.

Performance of Appropriate Added a Surveillance Requirement to perform b

3.10.3.1 applicable Surveillance Requirements for LCO 3.9.2, Rd dra H

LCO 3.9.4, LCO 3.9.5, LCO 3.3.8.2, and LCO 3.3.1.1.

Shutdown Disarmed Control Rod Added a Surveillance to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that all Verification during Single control rods in the 5X5 array centered on the 3.10.3.2 Control Rod Withdrawal-Hot withdrawn control rod are disarmed when withdrawing Shutdown a control rod during hot shutdown.

Fully Inserted Control Rod Added a Surveillance to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that all Verification during Single control rods, except the one withdrawn control rod, are 3'10.3.3 Control Rod Withdrawal-Hot fully inserted when withdrawing a control rod during Shutdown hot shutdown..

Performance of Appropriate Added a Surveillance Requirement to perform SRs during Single Control 3.10.4.1 a licable Surveillance Requirements for LCO 3.9.4 d

and LCO 3.9.5, and Function 7 of LCO 3.3.1.1.

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CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE Control Rod Block Added a Surveillance to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that a Verification during Single control rod block is inserted when removing a single 3.10.5.3 Control Rod Removal-control rod during refueling.

Refueling Verification of No Core Surveillance added to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , when Alterations during Single 3.10.5.5 removing a single control rod during refueling, no CORE ALTERATIONS in progress.

fu in Surveillance added every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , when removing i

Spiral Reload Sequence 3.10.6.3 multiple control rods during refueling, to verify Verification compliance with an approved spiral reload sequence.

Verification of No Core Surveillance added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , when 3.10.8.4 Alterations during SDM Test-performing a SDM test during refueling, no CORE j

Refueling ALTERATIONS in progress.

CRD Charging Header Surveillance added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , when 3.10.8.6 Pressure Verification during performing a SDM test during refueling, CRD charging SDM Test-Refueling header pressure.

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CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE An additional Surveillance Frequency for SDM verification (Prior to each in-vessel fuel movement.

3.1.1.1 SDM Verification during fuelloading sequence)is also added to CTS 4.1.1.a (ITS SR 3.1.1.1).

CTS 4.1.1.a allows the option of verifying SHUTDOWN MARGIN 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Unit 1) and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Unit 2) prior to the first startup after completing CORE 3.1.1.1 SDM Verification ALTERATIONS instead of during the startup. ITS requires once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after criticality following fuel movement within the reactor pressure vessel or control rod replacement.

ITS SR 3.1.4.1 requires control rod scram time testing Control Rod Scram Time for all control rods following each reactor shutdown a 3.1.4.1 Testing All Control Rods 120 days instead of > 120 days as allowed by CTS 4.1.3.2.a.

I A Note is added to CTS 4.1.3.2 (ITS SR 3.1.4.1) that Control Rod Scram Time requires the CRD pumps be isolated from the 3'1'4.1 Testing All Control Rods associated control rod scram accumulator during a single control rod time scram time surveillance.

A Note is added to CTS 4.1.3.3 (ITS SR 3.1.4.2) that Control Rod Scram Time requires the CRD pumps be isolated from the 3.1.4.2 Testing Of Representative associated control rod scram accumulator during a Sample single control rod time scram time surveillance.

A Note is added to CTS 4.1.3.4 (ITS SR 3.1.4.4) that Control Rod Scram Time requires the CRD pumps be isolated from the 3.1.4.4 Testing Affected Control associated control rod scram accumulator during a Rods single control rod time scram time surveillance.

The acceptance criteria associated with the control rod Control Rod Scram Time 3.1.4.2, and scram times (ITS Table 3.1.4-1) have been made Tests 3.1.4.4 more restrictive.

ITS SR 3.1.5.1 includes the acceptance criteria (2 940 Weekly Control Rod scram

. 51 Psig) to the weekly control rod scram accumulator test Accumulator Test consistent with current Brunswick plant practice.

The est acceptance criteria has been made more 3.1.7.2 ut on pe a ure Verification AS-7

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CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE The Surveillance (lTS SR 3.1.7.5) that determines boron solution concentration anytime water or boron is added to the SLC solution or when the solution i

Jemperature drops below the limit is modified to Standby Liquid Control Boron include a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period to perform the 3.1.7.5 Solution Concentration Surveillance. ITS SR 3.1.7.5 also more clearly defines Verification the Frequency of CTS 4.1.5.b.3 associated with solution temperature outside limits by requiring j

verification that boron concentration is within limits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after restoring temperature to within limits.

The SLC pump flow and pressure are currently tested per the IST Program once per 92 days. Therefore, the Sl P 3.1.7.6 Frequency of this Surveillance (in ITS SR 3.1.7.6)is essur revised to be "in accordance with the Inservice Testing Program"instead of once per 18 months.

CTS Table 4.3.1-1 Notes (m) and (n) that allow the reactor mode switch to be moved to another position l

Weekly APRM CHANNEL without making a MODE change for the purpose of 3.3.1.1.4 FUNCTIONAL TEST performing Surveillances on the APRM Startup High Function (Function 2.a) and APRM inoperative Function (Function 2.d) are eliminated in ITS.

CTS Table 4.3.1-1 Notes (m) and (n) that allow the reactor mode switch to be moved to another position Qu rterly APRM CHANNEL without making a MODE change for the purpose of 3.3.1'1.9 FUNCTIONAL TEST performing Surveillances on the APRM Startup High Function (Function 2.a) and APRM inoperative Function (Function 2.d) are eliminated in ITS.

A Surveillance is added (ITS SR 3.3.1.1.16) to verify 30% Bypass Verificaten the automatic enabling of the Turbine Stop 3.3.1.1.16 associated with RPS TSV Valve - Closure RPS Function and Turbine Control i

and TCV Closure Functions Valve Fast Closure, Control Oil Pressure - Low RPS Function at a 30% RTP.

i CTS 4.3.5.4.b verifies SRM count rate is a 3 cps prior to withdrawal of control rods. A requirement to 3.3.1.2.4 SRM Count Rate Verification perform the SRM count rate within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to control rod withdrawal (ITS SR 3.3.1.2.4) is added to ensure the surveillance data is reasonably current.

The allowance to waive verifying SRM count rate has been modified to only allow the note to be used when 3.3.1.2.4 SRM Count Rate Verification no other fuel assemblies are in the associated core quadrant.

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CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE CTS 4.1.4.1.1 requires a CHANNEL FUNCTIONAL TEST to be performed on the RWM prior to withdrawal of control rods for the purpose of making the reactor RWM CHANNEL critical. The Note to ITS SR 3.3.2.1.2 requires a 3.3.2.1.2 FUNCTIONAL TEST CHANNEL FUNCTIONAL TEST to be performed on the RWM after withdrawal of any control rod when RTP is s 10%, not just when the withdrawal is for the purpose of making the reactor critical.

Drywell and Suppression The CHANNEL CAllBRATION requirement Chamber Hydrogen and (SR 3.3.3.1.2) for the drywell and suppression 3.3.3.1.2 Oxygen Analyzer CHANNEL chan ".er hydrogen and oxygen analyzers is specified CALIBRATION as once per 92 days.

The Frequency of performing the CHANNEL A BMM for Nnchons 3.c and 6.a of US taw 3.3.6.1.4 is on nstru ntation 3.3.6.1-1 has been changed from every 18 months to CHANNEL CAllBRATION every 92 days.

This change modifies current Item 2 and item 4.a of CTS Table 4.4.5-1 (ITS SR 3.4.6.1) to change the Dose Equivalent 1-131 3.4.6.1 frequency for Isotopic analys,s for Dose Equivalent I-i Isotopic Analysis 131 concentration from at least once per 31 days to at least once per 7 days.

CTS 4.4.1.1.1 only requires performance of the i

recirculation pump discharge valve and bypass valve functional tests during a Cold Shutdown which Recirculation Pump exceeds 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months if not performed in the previous 3.5.1.5 Discharge and Bypass Valve 31 days. The ITS frequency of SR 3.5.1.5 requires Functional Test the valves to be tested prior to each startup (before exceeding 25% RTP)if not tested within the previous i

31 days (the frequency stated in ITS SR 3.5.1.5).

l A Note is added to CTS 4.5.3.1.a (ITS SR 3.5.2.2.b) eve e cadon for mat ody aHows one CS s2 system to be ahgned to i

3.5'2'2'b Core Spray the CST during operations with the potential for draining the vessel (OPDRVs).

The requirement to verify the RCIC pump flow rate in CTS 4.7.4.c.2 is modified in ITS SR 3.5.3.4 to include 3.5.3.4 RCIC Flow Test the criteria of verifying pump flow against a system head corresponding to reactor operating pressure.

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CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE The CTS 4.6.5.1.b requires that one Standby Gas Treatment (SGT) subsystem be tested every 18 m nths to verify the capability to maintain a 1/4 inch of Secondary Containment vacuum in secondary containment. ITS SR 3.6.4.1.1 3.6.4.1.1 Drawdown Test requires both st.bsystems be tested in the course of two outages - as represented by the STAGGERED TEST BASIS requirement of the Frequency.

The Ventilation Filter Testing Program provides more Standby Gas Treatment restrictive acceptance criteria for the SGT System

.3.2 Subsystem Filter Testing heaters.

A requirement to verify the automatic starting of each Service Water System

.5 NSW pump on an actual or simulated initiation signal Automatic Actuation Test is added to CTS 4.7.1.2.b (ITS SR 3.7.2.5).

CREV subsystem flowrate acceptance criteria are Roo Pohe fresuree"t added to CTS 4.7.2.d.4 (ITS SR 3.7.3.3) and the 3.7.3.3 radiation / smoke protection mode is specified.

CTS 4 i i 47.2.c requires verification that the release rate from noble gases from the main condenser air Main Condenser Air Ejector ejector is within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following an 3.7.5.1 Release Rate Verification increase of greater than 50%. The amount ofincrease is changed from greater than 50% to also include an increase equivalent to 50% in ITS SR 3.7.5.1.

Note

to CTS 4.8.1.1.2.a.4 allows the option to either precede the start with a prelube period or use other warmup procedures during DG starts. ITS SR 3.8.1.2 3.8.1.2 Monthly DG Start Test Note 1 (CTS 4.8.1.1.2.a.4 Note *) requires that if a l

slow start is performed, it will be preceded by a prelube period and a warmup period.

Voltage and frequency requirements are added to DG 3.8.1.2 Monthly DG Start Test tests required by CTS 4.8.1.1.2.a.4 (and

Note) and 4.8.1.1.2.d.3.b).

Two Notes are added to CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3). Note 3 precludes this surveillance from being performed on more than one DG at a time.

i 3.8.1.3 Monthly DG Lnad Run Note 4 requires this SR to be immediately preceded by a successful performance of ITS SR 3.8.1.2 or SR 3.8.1.7 (DG start Surveillances)

A5-10

.sp.

CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE The DG loading requirement associated with CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3) is increased from 1750 kW to a range of a 2800 kW and s 3500 kW.

3.8.1.3 Monthly DG Load Run Also, the DG run time for CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3) is increased from 15 minutes to 60 minutes.

DG Engine-mounted Tank The test acceptance criteria has been made more 3.8'1'4 Level Verification restrictive.

Voltage and frequency requirements are added ;o DG 3.8.1.7 DG Timed Start Test tests required by CTS 4.8.1.1.2.a.4 (and

Note) and 4.8.1.1.2.d.3.b).

Limitations on the operating power factor are added to 3.8.1.9 DG Load Reject Test CTS 4.8.1.1.2.d.2, single load rejection test (as Note 2 to SR 3.8.1.9).

An upper DG load limit is added to ITS SR 3.8.1.11 3.8.1.11 DG Fu!! Load Run (CTS 4.8.1.1.2.d.5).

Limitations on the operating power factor are added to 3.8.1'11 DG Full Load Run CTS 4.8.1.1.2.d.5. the full load run test (SR 3.8.1.11).

i The wording associated with CTS 4.8.1.1.2.d.7 is DG Load Sequence Interval changed from " load sequence time within 10% of the 3'8'1'13 Test required value" to " load sequence time within 10% of t

i design interval."in ITS SR 3.8.1.13.

l Voltage and frequency requirements are added to DG 3.8.1.14 LOCA/ LOOP Test tests required by CTS 4.8.1.1.2.a.4 (and

Note) and 4.8.1.1.2.d.3.b).

The DG 10 second start time is added to CTS i

3.8.1.14.c LOCA/ LOOP est 4.8.1.1.2.d.3.b (ITS SR 3.8.1.14.c).

DG Fuel Oil Storage and Day The test acceptance criteria has been made more 3'8'3~1 Tank Volume Verification restrictive.

i CTS 4.8.2.3.2 requires verification that the total i

4 bauey tesnal vohage is greateman or equal to 129 Weekly Battery Voltage vo s on SoaMarge RS SR 3.8A1 reqdres 3.8.4.1 Check verification that the total battery terminal voltage is

> 130 V on float charge.

A5-11 4

A

-,n.

CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE CTS 4.8.2.3.2.b.2 requires verification that inter-cell and terminal connection resistance is less than 150 x

~

10 ohms. Discussion of Change LA.2 relocates 4

r

-), arterly Battery Cell these limits to the Bases. However, these limits are 3.8.4.2 h.irconnection revised in the Bases such the connection resistance ee nabon during the verification must be less than 20% above the established benchmark value for inter-cell and terminal connections.

Additional Frequencies are added and state "12 months when battery shows degradation or has Battery Performance reached 85% of the expected life with capacity <

]

3.8.4.7 Discharge Test 100% of manufacturer's rating" and "24 months when battery has reached 85% of the ypected life with capacity > 100% of manufactureds rating."

Additionallimitations are imposed on CTS Table 4.8.2.3.2-1 footnote (b) (ITS Table 3.8.6-1, i

Weekly Battery Pilot Cell footnote (c)). Tnese new limitations restrict the use of 3~8'6'1 Parameter Verification replacing specific gravity checks with charging current checks to 7 days when the battery is on float charge following a battery charge only.

Additional limitations are imposed on CTS Table 4.8.2.3.2-1 footnote (b) (ITS Table 3.8.6-1, Quarterly Battery Cell footnote (c)). These new limitations restrict the use of 3.8.6.2 Parameter Verification replacing specific gravity checks with charging current checks to 7 days when the battery is on float charge following a battery charge only.

The CTS Table 4.8.2.3.2-1 footnote (c) allowance to Quarterly Battery Cell necme Camgoy B CoaWoRage Hmuor Parameter Verification temperature,s deleted.

i TS SR 3.9.1.1 requires the performance of a Refuel Interlock CHANNEL 3.9.1.1 CHANNEL FUNCTIONAL TEST to demonstrate the FUNCTIONAL TEST OPERABILITY of the refuel position interlocks.

CTS 4.9.1.2 requires the refueling interlocks to be Refuel Position One-Rod-Out demonstrated OPERABLE but does not provide 3.9.2.2 Interlock CHANNEL specific testing requirements. ITS SR 3.9.2.2 requires FUNCTIONAL TEST a weekly CHANNEL FUNCTIONAL TEST.

CTS 4.1.3.5 requires the control rod scram Control Rod Scram accumulators be determined OPERABLE once per 7 3.9.5.2 Accumulator Pressure days. ITS SR 3.9.5.2 includes the acceptance criteria Verification During Refueling (a 940 psig) consistent with current Brunswick plant practice.

l l

A5-12 4

ATTACHMENT 6 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS REVISION TO UNIT 2 OPERATING LICENSE This attachment provides the proposed changes to the Unit 2 Operating License to allow single recirculation loop operation. The proposed change would delete the Unit 2 license condition that currently does not allow single recirculation loop operation for an extended period. The basis for this proposed change is provided in the L.1 Discussion of Change (DOC) for ITS Specification 3.4.1. A copy of the marked-up and typed Unit 2 Operating License are also attached.

1

l "6tJP WJ 2.

Ogediaj U c cas e_

l.

e a

described within the program within the two year monitoring period, or Phase HI following initiation of Phase H, is required the licensee will r

either comply with a request to proceed to Phase H (or Phase IH) or i

immadiately request and be granted a hearing on the issue of whether i

the data on which the staff's request is based justifies the initiation of l

Phase H (or Phase IH) under the program for seismic monitoring 1

l agreed to by the licensee and the NRC staff. Nothing herein will be l

construed as precluding changes in the program by the licensee which do not adversely affect the quantity ofinformation derived from the j

monitoring program. NRC will be informed of any such changes in the i

quarterly report. -

l (4)

Equalizer Valve Restriction i

i The valves in the equaliver piping between the recirculation loops shall

]

be closed at all times during reactor operations.

i (5)

(DJirr iMan i nan Inanerable WJ b A~&=> Wa.C 3 0** **P*

s."

jag, if one ulati loop am m,Jervice.

ith the becomes out servicef plantjt$11 be p in a hot utdown condition thin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Testing conditicps shall be owed in which one or both1fecirculatio'n loops a9 ut of service for the 6

prposes of tests (not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months )f (6)

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10CFR73.55 (51 FR 27817 and 27822) and to the authority of 10CFR50.90 and 10CFR50.54(p). The plans, which contain Safeguards Information protected under 10CFR73.21 are entitled: " Brunswick Steam Electric Plant Industrial Security Plan," with revisions submitted through September 23,1987;

" Brunswick Steam Electric Plant Security Personnel Training and Qualification Plan," with revisions through January 20,1987; and

" Brunswick Steam Electric Plant Safeguards Contingency Plan," with revisions submitted through March 27,1986. Changes made in accordance with 10CFR73.55 shall be implemented in accordance with the schedule set forth therein.

By. IJl

described within the program within the two year monitoring period, or Phase III following initiation of Phase II, is required the licensee will either comply with a request to proceed to Phase II (or Phase III) or

. immediately request and be granted a hearing on the issue of whether the data on which the staff's rtquest is based justifies the initiation of Phase II (or Phase III) under the program for seismic monitoring agreed to by the licensee and the NRC staff. Nothing herein will be construed as precluding changes in the program by the licensee which do not adversely affect the quantity of information derived from the monitoring program. NRC will be informed of any such changes in the quarterly report.

(4)-

Eauali7er Valve Restriction The valves in the equalizer piping between the recirculation loops shall be closed at all times during reactor operation:i.

(5)

Deleted by Amendment No. [ ]

I (6)

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10CFR73.55 (51 FR 27817 and 27822) and to the authority of 10CFR50.90 and 10CFR50.54(p). The plans, which contain Safeguards Information protected under 10CFR73.21 are entitled: " Brunswick Steam Electric Plant Industrial Security Plan," with revisions submitted through September 23,1987;

" Brunswick Steam Electric Plant Security Personnel Training and Qualification Plan," with revisions through January 20,1987; and

" Brunswick Steam Electric Plant Safeguards Contingency Plan," with' revisions submitted through March 27,1986. Changes maae in accordance with 10CFR73.55 shall be implemented in accordance with the schedule set forth therein.

D CP&L Corolino Power & Light Company William R. Campbell PO Box 10429 Vice President Southport NC 28461 0429 Brunswick Nuclear Plant SERIAL: BSEP 96-0414 10 CFR 50.90 TSC 96TSB02 NOV 011996 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These proposed amendments revise the Brunswick Plant Technical Specifications to a format consistent with NUREG-1433, Revision 1, ' Standard Technical Specifications for General Electric Plants, BWR 4."

The proposed amendmeni also extends the frequency of selected Surveillance Requirements to 24 months to support conversion of the Brunswick Plant to a 24-month fuel cycle.

The detailed description and justification for the proposed Technical Specification amendment consists of 15 volumes. A detailed description of the contents and organiza! ion of the 15

)

volumes is included as Attachments 1 through 4 of this letter. These attachments include:

i, Brunswick Unit 1 and Unit 2 Improved Technical Specification (ITS)

Submittal Synopsis, which describes the organization and content of the submittal and i

the organization and content of each of the 15 volumes. This attachment is designed to facilitate distribution of each section within the NRC and to familiarize reviewers with the content and organization of each section., Brunswick Un t 1 and Unit 2 ITS Conversion Document Status, which describes and provides the status of pending changes, including changes to be submitted, to the Brunswick Current Technical Specifications (CTS) that are incorporated i

into this amendment request. This attachment also provides a list of the proposed generic changes to NUREG-1433, Revisions 1, that are incorporated into the Brunswick ITS amendment request. In addition, Attachment 2 includes anticipated changes to the i

Brunswick CTS that may be submitted during the course of NRC review. This information is intended to facilitate Brunswick and NRC document control during the Brunswick ITS Tel 910 457 2496 Fox 910 457 2803

o Document Control Desk BSEP 96-0414 / Page 2 review and approval process.

A'tachment 5, Significant Deviations From NUREG-1433 and Brunswick CTS. The purpose of this attachment is to identify those changes which are beyond the scope of both NUREG-1433 and the Brunswick CTS and either have or are being submitted separately from this license amendment request., Evaluations Used to Justify 24-Month Surveillance Requirement Frequencies. This attachment provides a detailed description of the methodology used to justify the extension of the frequency of selected Surveillance Requirements to 24 months to support conversion of the Brunswick Plant to a 24-month fuel cycle.

As a part of the overall conversion effort, CP&L is adopting numerous new Surveillance Requirements (SRs). The new SRs are grouped into two categories (Category A and Category B SRs). Category A SRs are those SRs which are new in their entirety compared to current Brunswick Plant Technical Specifications. Category B SRs are those current SRs which have Deen revised with ITS in some manner to be more restrictive than the current Technical Specifications require.

1 provides a Listing of More Restrictive and New Surveillance Requirements divided into Category A and Category B types. CP&L will be reviewing each Category A and B SR to determine which will not be current upon ITS implementation, based on the projected Brunswick ITS implementation date. CP&L intends to have as many of these more restrictive surveillances current upon ITS implementation as practical; however, due to difficulties in determining the exact status of the plant and the variables associated with implementation (e.g.,

whether or not all of the more restrictive changes will be approved as currently written), CP&L proposes that the Category A changes are assumed to be performed and met, in accordance with ITS SR 3.0.1, upon implementation of the ITS. Accordingly, the initial due date for each I

Category A SR will be determined based on: 1) the ITS implementation date,2) the ITS frequency of the SR and 3) SR 3.0.2. CP&L also proposes that the more restrictive Category B SRs are assumed to be performed and met, in accordance with ITS SR 3.0.1, upon implementation of the ITS. Accordingly, the due date for each Category B SR will be l

determined based on: 1) the last completion date of the associated CTS SR,2) the ITS frequency of the SR and 3) SR 3.0.2.

CP&L has determined that the approach discussed above will maintain compliance with the ITS and also provide the flexibility needed to implement the numerous new and more restrictive SRs which we have included as a part of our conversion to the Improved Standard Technical Specifications. provides the proposed changes to the Unit 2 Operating License to allow single recirculation loop operation. Included in this attachment is a mark-up of the Unit 2 license condition and a discussion of the change.

implementation of the proposed amendments is tentatively scheduled for the fourth quarter of 1997 and is based on: 1) the training schedules for licensed and non-licensed personnel,

4 Document Control Desk BSEP 96-0414 / Page 3

2) timing of the implementation with respect to refueling outages,3) the licensed operator examination schedule,4) the time required for procedure revisions and development of new programs,5) implementation of power uprate of both units, and 6) implementation of the Long-Term Thermal Hydraulic Instability resolution at the Brunswick Plant. Brunswick Plant ITS implementation is also predicated on NRC issuance of a Safety Evaluation by July 1997, along with issuance of Safety Evaluations for the pending changes, including those changes to be submitted, which have been incorporated into the ITS (see Attachment 2). CP&L will inform the NRC staff when the ITS implementation actions are complete.

Carolina Power & Light Company has determined that the proposed changes do not involve a significant hazards consideration. The evaluations for making this determination are included with each specification. CP&L has also provided an environmental evaluation for each specification which demonstrates that the proposed amendments meet the eligibility for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

an environmental assessment of the proposed changes is not required.

Carolina Power & Light Company is providing, in accordance with 10 CFR 50.91(b), Mr. Dayne H. Brown of the State of North Carolina with a copy of the proposed license amendments.

Please refer any questions regarding this submittal to Mr. Mark Turkal at (910) 457-3066.

Sincerely, t

(

William R. Campbell KAH/kah Attachments: 1 Through 6

Enclosure:

Improved Technical Specifications Conversion Document - Brunswick Units 1 and 2 (15 Volumes) i i

6 Document Control Desk BSEP 96-0414 / Page 4 William R. Campbell, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power & Light Company.

ta b IIotary (S(a))

My commission expires:

th W pc:

U. S. Nuclear Regulatory Commission ATTN.: Mr. Stewart D. Ebneter, Regional Administrator 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323-0199 Mr. C. A. Patterson NRC Senior Resident inspector - Brunswick Units 1 and 2:

U.S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738 l

The Honorable H. Wells Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Dayne H. Brown Director - Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources P.O. Box 27687 Raleigh, NC 27611-7687 U.S. Nuclear Regulatory Commission (6 copies)

ATTN.: Mr. Christopher 1. Grimes (Mail Stop OWFN 11 E22) 11555 Rockville Pike Rockville, MD 20852-2738

\\

ATTACHMENT 1 BRUNSWICK STEAM ELdCTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS IMPROVED TECHNICAL SPECIFICATION (ITS) SUBMITTAL SYNOPSIS The CP&L Brunswick Plant Improved Technical Specification (ITS) submittal consists 15 volumes. This attachment describes each component of the Brunswick Plant ITS submittal, and their organization within each volume. This attachment is designed to facilitate distribution l

of each Brunswick ITS section within the NRC and to familiarize reviewers with the content and organization of each section. A description of each volume included in the Brunswick Plant ITS submittal follows.

Volume 1:

1 Volume 1 contains the Application of the Technical Specification Selection Criteria and a Relocation Matrix. This document lists each of the Brunswick Plant Current Technical i

Specifications (CTS) and shows the results of CP&L's application of the 10 CFR 50.36 criteria for retention of requirements in Technical Specifications. For each of the Brunswick Plant CTS, this document identifies whether or not the requirement is retained in the Brunswick ITS, and the basis for its retention or exclusion. For those CTS items that did not meet the selection criteria and have not been reta:.ned in the proposed ITS, a detailed explanation of the application of the selection critaria and justification for relocation is provided. The Relocation Matrix provides the document location for each relocated CTS requirement.

Volumes 2 through 15:

Volumes 2 through 15 contain the Brunswick Improved Technical Specifications and associated supporting documentation for the proposed amendment request. The volumes are ordered on a Chapter /Section basis, as follows, to facilitate distribution to NRC staff reviewers:

Volume 2:

Brunswick ITS Chapter 1.0, Use and Application Chapter 2.0, Safety Limits Section 3.0, Limiting Condition for Ope'ation Applicability and Surveillance Requirement Applicability Volume 3:

Brunswick ITS Sections 3.1, Reactivity Control Systems 3.2, Power Distribution Limits Volumes 4. 5. & 6:

Brunswick ITS Section 3.3, instrumentation Volume 7:

Brunswick ITS Section 3.4, Reactor Coolant System A1-1

Molume 8 Brunswick ITS Saction 3.5, Emergency Core Cooling Systems and Reactor Core Isolation Cooling System Volumes 9 & 10:

Bnmswick ITS Section 3.6, Containment Systems Volume 11:

Brunswick ITS Section 3.'/, Plant Systems Volumes 12 & 13:

Brunswick ITS Section 3.8, Electrical Systems Volume 14:

Brunswick ITS Sections 3.9, Refueling Operations 3.10, Special Operations Volume 15:

Brunswick ITS Chapter 4.0, Design Features Chapter 5.0, Administrative Controls Each volume contains the Unit 1 and Unit 2 Brunswick ITS Specifications and Bases, a mark-up of the Brunswick CTS, a discussion of changes to the Brunswick CTS, the No Significant Hazards Evaluations for each of the changes to the CTS, Environmental Assessments for changes to the CTS, and mark-up of NUREG-1433, Revision 1 to indicate the Brunswick ITS and justifications for deviations from the NUREG. Each Chapter /Section in a volume is organized as follows:

Tab: Brunswick Unit 1 Imoroved Technical Soecifications This tab contains the proposed Brunswick Unit 1 Improved Technical Specifications.

Tab; Brunswick Unit 1 Imoroved Technical Soecification Bases (as aoolicable)

This tab contains the proposed Brunswick Unit 1 Improved Technical Specification Bases.

Tab: Brunswick Unit 2 Imoroved Technical Soecifications This tab contains the proposed Brunswick Unit 2 Improved Technical Specifications.

Tab: Brunswick Unit 2 Imoroved Technical Soecifications Bases (as aoolicable)

This tab contains the proposed Brunswick Unit 2 Improved Technical Specification Bases.

Tab : Markuo of Brunswick Unit 1 and Unit 2 Current Technical Soecifications and Discussion of Chances Beino Made to the Brunswick CTS This tab contains a copy of the Brunswick Unit 1 and Unit 2 CTS pages annotated to provide a cross-reference to the equivalent Brunswick ITS requirement, showing the disposition of the existing requirements into the Brunswick ITS.

The annotated copy of the Brunswick CTS pages are marked with sequentially numbered

" clouds" which provide a cross-reference to a Discussion of Changes (DOCS) between the Brunswick CTS and the Brunswick ITS. The ITS number is noted on the top right corner of each CTS page, identifying tb9 ITS LCO where the CTS requirement is located.

Items on the CTS page that are located in one or more ITS locations or sections have the A1-2

appropriate location (s) noted adjacent to the items. When the ITS requirement differs from the CTS requirement, the CTS being revised is annotated with an alpha-numeric designator. This designator relates to the appropriate DOC. Each DOC provides a justification for the proposed change. The DOC for each ITS section immediately folicws the marked up CTS pages. The alpha-numeric designator also relates the proposed change to the applicable No Significant Hazards Evaluation (NSHE). An Environrnental Assessment is also provided for each specification.

The alpha-numeric designator is based on the category of the change and a sequential number within that category. The changes to the Brunswick CTS are categorized as follows:

A ADMINISTRATIVE - associated with restructuring, interpretation, and complex rearranging of requirements, and other changes not substantially revising an existing requirement. There is a single No Significant Hazards Evaluation (NSHE) for this category.

M TECHNICAL CHANGES - MORE RESTRICTIVE - changes to the CTS being proposed in converting to the ITS, resulting in added restrictions or eliminating flexibility. There is a single NSHE for this category.

L TECHNICAL CHANGES - LESS RESTRlCTIVE - changes where requirements are relaxed, relocated, eliminated, or new flexibility is provided.

There are two groups of changes " Generic" and " Specific"in this category.

Each " Specific" LESS RESTRICTIVE change has a corresponding unique No Significant Hazards Evaluation (NSHE). The " Generic" LESS RESTRICTIVE changes are subdivided into 6 subcategories, each of which is identified uniquely as either LA, LB, LC, LD, LE, or LF changes. Each subcategory of

" Generic" LESS RESTRICTIVE change is justified by a single NSHE. The subcategories and their designation are as follows:

The "LA" changes consist of relocation of details out of the CTS and into the Bases, UFSAR, QA Manual, procedures, or other plant controlled documents. Typically, this involves details of system design and function or procedural details on methods of conducting a surveillance.

The "LB" changes are related to the extension of an instrument Completion Time or Surveillance Frequency in accordance with NRC approved vendor topical reports.

The "LC" changes reflect elimination of various instrumentation requirements, where the instrument is an alarm or an indication-only instrument function that does not otherwise meet the NRC Technical Specification selection criteria.

The "LD" changes reflect extension of the refueling outage surveillance interval from 18 months to 24 months for surveillances other than Channel Calibrations.

A1-3

i The "LE" changes reflect extension of the refueling outage surveillance interval from 18 months to 24 months for Channel Calibration surveillances.

l The "LF" changes reflect modifying the instrumentation Allowable Values to be consistent with the current calculations performed in accordance with the plant specific setpoint methodology.

R RELOCATED - specific requirements that do not meet the NRC Technical Specification selection criteria. These items are being relocated to other plant documents as part of the conversion to ITS. There is a single NSHE for this category.

Tab: Markuo of NUREG-1433. Revision 1 Technical Soecifications and Justifications for Qgviations This tab contains a copy of NUREG-1433, Revision 1, Technical Specifications which have been annotated to indicate deviations between the NUREG (as modified by generic changes identified in Attachment 2 of this letter) and the proposed Brunswick ITS.

Justifications for each of the deviations are provided with the individual ITS Chapters / Sections. The annotated copy of NUREG-1433, Revision 1, and the discussion of the deviations are cross-referenced by " clouds" which are numbered sequentially for each Chapter /Section.

Each line item in the annotated copy of NUREG-1433, Revision 1, Technical Specifications contains a cross-reference to the equivalent Brunswick CTS requirement and/or discussion of change, as appropriate. This cross-reference is intended to provide reviewers with a quick reference to the equivalent CTS section.

Tab: Markuo of NUREG-1433. Revision 1 Technical Soecifications Bases and Justifications for Deviations This tab contains a copy of NUREG-1433, Revision 1, Technical Specifications Bases which have been annotated to indicate deviations between the NUREG Bases (as modified by generic changes identified in Attachment 2 of this letter) and the proposed Brunswick ITS Bases. Justifications for the deviations are provided with the individual 3

ITS Chapters / Sections. The annotated copy of NUREG-1433, Revision 1, and the j

discussion of the deviations are cross-referenced by " clouds" which are numbered sequentially for each Chapter /Section.

Tab: No Sianificant Hazards Evaluations This tab contains the required 10 CFR 50.92 No Significant Hazards Evaluations (NSHEs) for the proposed changes and demonstrates that the changes associated with the corresponding ITS section do not constitute a significant hazard consideration. As described for the DOC, the NSHEs are categorized as Administrative, Relocated, More Restrictive, Less Restrictive - Generic, and Less Restrictive - Specific, and are identified by an alpha-numeric designator relating the marked-up CTS and the DOC to the

)

applicable NSHE.

]

A1-4

This tab also includes an Environmental Assessment for each ITS specification and demonstrates that the proposed amendments meet the eligibility for categorical exclusion :

set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an

.env ronmen a assessmen ot f the proposed changes is not required.

i tl i

I 1

t 1

i e

4 i

o

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l A1-5

ATTACHMENT 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS BRUNSWICK ITS CONVERSION DOCUMENT STATUS This attachment identifies 1) a listing of CTS changes that are pending approval from the NRC which have been included in the Brunswick Plant ITS submittal, including changes which will be submitted,2) generic NUREG changes which have been included in the Brunswick Plant ITS submittal,3) approved generic NUREG changes which have not been included in the Brunswick Plant ITS, and 4) the submittals that CP&L intends to make during the course of the NRC review of the Brunswick Plant ITS which have not been included in the Brunswick Plant ITS submittal.

1.

Technical Soecification Chanae Reauests Pendina NRC Acoroval Which Have Been included in the Brunswick Plant ITS Submittal TSC 87TSB16:

Generic Letter 87-09 Implementation TSC 91TSB13:

Generic Letter 91-09 Implementation i

TSC 94TSB14:

Deletion of Requirements for Suppression Chamber Average Temperature Monitoring Instrumentation TSC 94TSB16:

Power Uprate J

TSC 95TSB32:

Unit 1 Fuel Cycle 11 Reload Licensing TSC 96TSB03:

Thermal Hydraulic Instability Long-Term Resolution - Enhanced Option I-A Stability Technical Specifications 2.

Technical Soecification Chance Reauests Which Have Been included in the Brunswick i

Plant ITS Submittal And Are Exoected To Be Submitted By November 22.1996 TSC 95TSB06:

Pressure-Temperature Limits Curves TSC 95TSB36:

Reactivity Anomalies TSC 96TSB01:

Drywell Air Temperature TSC 96TSB07:

Suppression Chamber Water Volume TSC 96TSB09:

Instrumentation Allowable Value Revision A2-1 1

\\

l 3.

Technical Soecification Task Force (TSTF) Generic Chanaes incoroorated in The Brunswick Plant ITS Submittal TSTF-05:

Deletes Safety Limit violation notification requirements.

4 1

TSTF-17:

Extension of testing frequency of containment airlock interlock mechanism from 184 days to 24 months, i

F TSTF-32:

Slow / Stuck Control Rod separation critena.

TSTF-33:

Specification 3.1.3, Required Action A.2 Completion Time Note.

.TSTF-34:

Delete requirements to disarm the associated CRD when two or moie withdrawn control rods are stuck.

TSTF-35:

Recirculation pump start RPV temperature limits verification Note.

TSTF-36: Addition of LCO 3.0.3 N/A to shutdown electrical power specifications.

TSTF-38:

Revise visual surveillance of batteries to specify that inspection is for performance degradation.

1 i

4.

TSTF Acoroved Generic Chanaes Not incoroorated in The Brunswick ITS Submittal 1

l TSTF-60; RCS Leakage Detection Instrumentation LCO 3.0.4 N/A Note.

TSTF-106: Diesel Fuel Oil Testing Program Clarification.

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Technical Soecification Chances Which The Brunswick Plant Currentiv Plans To Submit To The NRC Staff Durina The Brunswick ITS Review Period Not included in The Brunswick Plant ITS Submittal l

96TSB05: 4.16kV / BOP E-Bus Allowed Outage Time Revision i

97TSB01: Unit 2 Fuel Cycle 13 Reload Licensing 96TSB10: EDG Compliance With Safety Guide 9 A

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ATTACHMENT 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS SIGNIFICANT ITS DEVIATIONS FROM THE BRUNSWICK CTS AND NUREG-1433. REV.1 This attachment provides a list of the Brunswick Plant ITS changes which represent significant deviations from both NUREG-1433, Revision 1, and the Brunswick Plant current Technical Specifications.

1.

Enhanced Op'. ion I-A Stability Tet hnical Specifications provided in ITS 3.2.3, 3.3.1.1, 3.3.1.3, and 5.6.5. These changes are also submitted in a separate Technical Specification Change Request (96TSB03).

2.

Pressure Temperature Limits Curves are updated in ITS 3.4.9. These changes are also submitted in a separate Technical Specification Change Request (96TSB06) 3.

ECCS Allowed Outage Times in ITS 3.5.1 are revised to reflect the current licensing basis SAFER /GESTR analyses desccibed in the UFSAR.

j 4.

CAD System requirements in current Technical Specification 3/4.6.6.2 are relocated based on the current Brunswick Plant specific licensing basis related to Generic Letter 84-09.

5.

Service Water System Allowed Outage Times are revised in ITS 3.7.2 to reflect more consistent applicaticn of current approved analyses.

6.

Ultimate Heat Sink Temperature Limits and Allowed Outage Times in ITS 3.7.2 are provided which are more restrictive than current Technical Specification requirements but which reflect current administrative practice.

7.

Control Room Emergency Ventilation System Actions are revised in ITS 3.7.3 to be consistent with existing plant specific analyses.

8.

Primary Containment Leakage Rate Testing Program are updated in ITS 5.5.12 to reflect currently approved exemptions to 10 CFR 50, Appendix J.

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ATTACHMENT 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS JUSTIFICATION OF 24-MONTH SURVEILLANCE REQUIREMENT FREQUENCIES 1.

PURPOSE:

To accommodate a planned change to a 24 Month Fuel Cycle for the Brunswick Nuclear Units 1 and 2, Carolina Power & Light (CP&L) is integrating the necessary changes to the BNP Units 1 and 2 Technical Specifications into the documents being used to convert to NUREG 1433, Standard Technical Specification for General Electric BWR 4. To facilitate the review of the 24 Month Fuel Cycle portion of this submittal, the following overview document is being provided to identify the scope of changes and the methodology used to justify the changes.

The proposed Technical Specification changes were evaluated in accordance with the guidance provided in NRC Generic Letter No. 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24 Month Fuel Cycle," dated April 2,1991.

II.

SCOPE:

The 24 Month Fuel Cycle portion of this submittalincludes a justification, when the SR Frequency is being changed, for all existing BNP Current Technical Specification (CTS)

Surveillance Requirements (SRs) that are being retained in the BNP Improved Technical Specifications (ITS) which have a BNP CTS Frequency of 18 months. In addition, some instrument's which are currently being calibrated on a quarterly basis are a!so being extended to a 24 month Channel Calibration Frequency using this same methodology.

These changes have been divided into two categories. The categories are: (1) changes involving the Channel Calibration Frequency identified as " Instrumentation Changes" (identified in the ITS Conversion document discussion of changes as "LEs"), and (2) other changes identified as "Non-Instrumentation Changes" (identified in the ITS Conversion document discussion of changes as "LDs").

Ill.

METHODOLOGY:

In Generic Letter 91-04, dated April 2,1991, the Nuclear Regulatory Commission (NRC) provides generic guidance for evaluating going to a 24 Month Surveillance Test interval for Technical Specification SRs. Generic Letter 91-04 specifies the steps for the evaluation needed to justify a 24 month surveillance interval. The following defines each step outlined by the NRC and provides a description of the methodology used by CP&L to complete the evaluation for each specific Technical Specification SR line item.

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A.

Non-Instrumentation (LDs):

Generic Letter 91-04 identifies three steps to evaluate Non-Instrumentation:

STEP 1:

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" licensees should evaluate the effect on safety of the change in surveillance intervals to l

accommodate a 24 month fuel cycle."

CP&L EVALUATION CP&L has evaluated each SR being changed. This evaluation provides a specific justification for each BNP CTS non-instrumentation SR which is being retained in BNP ITS. The evaluation is summarized in the discussion of change identified as "LDs". The following information provides a description of the purpose of surveillance testing and a general description of the methodology utilized.

The purpose of surveillance testing is to verify through the performance of the specified l

SRs that the tested Technical Specification Function / Feature will perform as assumed in l

the associated safety analysis or in accordance with the associated Function's design.

By periodically testing the Technical Specification Function / Feature, the availability of the associated Function / Feature is confirmed. As such, with the extension of BNP's operating cycle and the associated extension of the refueling cycle surveillance test interval (Frequency), a longer period of time will exist between performances of the surveillance test. If a failure resulting in the loss of a Safety Function occurs during the operating cycle and that failure would be detected only by the performance of the periodic Technical Specification SR, then the increase in the surveillance testing interval would result in a decrease in the associated Function's availability and thus have a potential impact on safety.

CP&L evaluated each associated SR to demonstrate that the potential impact, if any, on avaibbility is small as a result of the change to a 24 month Frequency. The evaluations were based on the fact that the Function / Feature is tested on a more frequent basis during the operating cycle (e.g., functionally tested quarterly), is designed to be single failure proof, or is highly reliable.

STEP 2

" Licensees should confirm that historical maintenance and surveillance data do not invalidate this conclusion".

CP&L EVALUATION 1

CP&L has evaluated the surveillance test history of the affected SRs. This evaluation consisted of a review of the surveillance test results. Only SR test failures were evaluated because failures detected by other plant activities such as Preventative l

Maintenance Tasks or Surveillance Tests that are more frequent than 18 months were assumed to continue to detect failures. This review of surveillance test history validated the conclusion that the impact, if any, on system availability will be small as a result of the change to a 24 Month Fuel Cycle.

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STEP 3

" Licensees should confirm that the performance of surveillance's at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis."

CP&L EVALUATION f

As part of the evaluation of each SR, CP&L reviewed the impact of these changes against assumptions in BNP licensing basis. In general, these changes have no impact

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on the plant licensing basis. However, in some cases, the change may require a change l

to commitments described in the BNP Updated Final Safety Analysis Report (UFSAR). If changes were required they are identified in the associated Discussion of Changes.

B.

Instrumentation (Channel Calibrations (LEs)):

Generic Letter 91-04 identifies seven steps for the evaluation of instrumentation changes j

(LEs).

1 STEP 1

' Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval."

CP&L EVALUATION CP&L evaluated the effect of longer calibration intervals on the TS instrumentation by performing a review of the surveillance test history for all instrumentation including, where necessary, instrument drift. The failure history evaluation and drift study demonstrates, except on rare occasion that, instrument crift has not exceeded the current allowable limits. In performing the drift study an effort was made to retrieve all recorded Channel Calibration data for associated instruments, when available, for the past several operating cycles. By obtaining all recorded calibration data for the past several cycles of operation, a true representation of instrument drift can be determined.

STEP 2

Confirm that the values of drift for each instrument type (make, model, and range) and j

application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data."

CP&L EVALUATION CP&L has performed a drift evaluation, where necessary, using calibration data obtained from surveillance tests of affected BNP ITS instrument by make, model number, and range.

The CP&L drift evaluation was performed using a computer model for drift determination j

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developed by General Electric (GE) and based on NEDC-31336, "GE Instrument Setpoint Methodology" This document was submitted to the NRC, and approved.

The Boiling Water Reactor Owners' Group (BWROG) committee for Calibration Interval

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Extension determined that the drift module of the GE Instrument Setpoint Methodology could be used to determine instrument drift for periods longer than 18 months based on actualinstrument performance in plant environments. GE, under the direction of the j

BWROG Calibration Interval Extension committee, developed the " General Electric Instrument Trending Analysis System"(GEITAS). This quality assured program has been

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used to determine the drift for other plants including Limerick Generating Station and i

Peach Bottom Atomic Power Station, which both received approval for the extension of Channel Calibration SRs using this program.

A copy of the verified and validated GEITAS program was obtained from GE and was used to project the thirty month drift number. The as-found and as-left data was taken i

from instrument calibration surveillance tests and was analyzed. The analysis included a review of the data points to determine any data points which would not provide a true indication of instrument drift, a change in the input / output relationship over time. If adjustments or elimination of data points were made, these changes were placed into one of the following seven (7) categorizes: (1)" Clerical Data Entry problem" (Review identified typographical data entry error. Data point was adjusted to correct the error.),

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(2)" Technician data entry problem" (Review identified an obvious transposition error by the Technician entering the data. Data point was eliminated based on the data entry error.), (3)"New instrument" (Review identified that new instrument was installed. Data point "As-found" data was zerced because this data would not be reflective of drift. Any repetitive instrument failures would be identified in the Surveillance Test History Review.),

(4)" Chronic instrument problem" (Review of the data indicated repetitive bad data points for a single instrument with excessive changes in the input / output relationship, while all other instruments in the same application did not exhibit the same characteristics. This instrument's data was eliminated based on a unique instrument problem. Any repetitive instrument failures would be identified in the Surveillance Test History Review.), (5)"Out of Calibration Test Equipment" (Review indicated that the instrument was calibrated with an out of calibration instrument. Data point was eliminated based on the fact that any recorded change could not be correlated to the performance of the instrument), (6)" Poor Calibration Methodology", (Review of the calibration methodology identified that the method of calibration would result in inconsistent and untrendable calibration results.

Data points calibrated using these techniques were eliminated based on the fact that any recorded change could not be correlated to the performance of the instrument.), and (7)" Poor Calibration Techniques", (Review identified that poor calibration techniques were used. Data point was eliminated based on the fact that any recorded change could not be correlated to the performance of the instrument.) All eliminated data points were individually evaluated and independently verified to meet these categories if they were adjusted or eliminated. Poor Calibration Methodology and Poor Calibration Techniques have been corrected through procedure revisions, training and increased supervisory over sight. The analysis produced values at intervals from one to thirty months or greater. The drift value was then compared with the drift uncertainty associated with the specific instrument setpoint analysis.

The results of the GEITAS evaluations showed acceptable 30 month drift values that were within setpoint analysis drift allowances in those cases where there was a sufficient A4-4

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f amount of historical data to satisfy the computer algorithms and the majority of the as-j found and as-left values were within acceptable limits.

in some cases, a different methodology was utilized to demonstrate that the drift was acceptable. These cases included instruments that were recently installed or where the GEITAS program could not be applied. For each instrument where the GE program was not utilized to evaluate the drift data, a summary of the methodology is contained in the specific discussion of change ("LE.x").

STEP 3

" Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications."

CP&L EVALUATION In accordance with the methodology described in the previous section, the magnitude of instrument drift has been determined with a high degree of probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument make and model number. As required by the GEITAS software, a review was performed to ensure that there were greater than 30 data points in the data set used to perform the statistical analysis. If less than 30 data points were used in the data set, a discussion is provided in the associated discussion of change (LE.x) to provide further support for the change to a 24 month Channel Calibration frequency. The associated instruments for each affected BNP ITS SR are listed in the corresponding discussion of change ("LEs").

1 STEP 4

" Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints.

If the drift errors result in revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety i

analysis assumptions are not exceeded."

CP&L EVALUATION The calculated drift value was compared to the allowances for the associated instruments as calculated in the associated setpoint analysis. Some of these analysis were completed during the performance of the 24 month drift evaluation, and therefore, data j

obtained from the drift study was utilized in the setpoint analysis. Changes to the setpoint i

values are identified as *LF" discussion of changes. If the calculated drift for an i

instrument fell outside the allowance for drift, the surveillance test interval was changed to a frequency which was supported by the projected drift or was extended to a 24 month Channel Calibration Frequency based on other justifications. If an instrument was not in service long enough to establish a calculated drift number, the surveillance interval was extended to a 24 month interval based on other, more frequent testing or justification i

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obtained from the instrument manufacturer.

STEP 5

" Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation."

CP&L EVALUATION As discussed in the previous sections, the calculated drift values were compared to drift allowances in the setpoint analysis developed in support of the improved Technical Specification submittal. In all cases, it was found that the calculated drift fell within the assumptions of the setpoint analysis or the SR Frequency was not increased, or the SR Frequency was increased based on other justification. Therefore in no case was it necessary to change the existing safe shutdown analysis to accommodate a larger drift error.

STEP 6

" Confirm that all conditions and assumptions of the setpoint and safety analyses have i

been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for Channel Checks, Channel Functional Tests, and Channel Calibrations."

CP&L EVALUATION As part of the implementation of the Improved Technical Specification project, all surveillance test procedures are being reviewed and updated to incorporate the necessary changes to the surveillance test procedures. The changes implemented as a l

result of the development of new setpoint analysis will also be incorporated into the surveillance procedure prior to the implementation of the improved Technical 5

Specifications and the 24 month operating cycle surveillance test frequency.

STEP 7

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" Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety."

CP&L EVALUATION Instruments with Technical Specification calibration surveillance frequencies extended to j

24 months will be monitored to identify occurrences of instruments found outside of Allowable Value. As-found and as-left calibration data will be recorded for each calibration activity. When as-found conditions are outside allowable value, an evaluation will be performed to determine if the assumptions made to extend the calibration frequency are still valid and to evaluate the effect on plant safety.

As described in the above discussion, CP&L has completed the evaluations necessary to justify a change in surveillance intervals needed to support a 24 Month Fuel Cycle, and CP&L A4-6 l

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has determined that these evaluations conform to guidance provided in Generic Letter 91-04.

i The specific evaluations for each BNP CTS SR being changed is contained in the associated ITS conversion discussion of change identified as "LD.x" and "LE.x". In addition, a No l

Significant Hazards Evaluation, in accordance with 10 CFR 50.92, has been performed for the i

changes annotated as "LDs" and "LEs".

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ATTACHMENT 5 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS NEW ITS AND MORE RESTRICTIVE CTS SURVEILLANCE REQUIREMENTS As a part of the overall conversion effort, CP&L is volunteering to adopt numerous new Surveillance Requirements (SRs). The new SRs are grouped into two categories (Category A and Category B SRs). Category A SRs are those SRs which are new in their entirety compared to current Brunswick Plant Technical Specifications. Category B SRs are those current SRs which have been revised with ITS in some manner to be more restrictive than the current Technical Specifications require. This attachment provides a Listing of More Restrictive Surveillance Requirements divided into Category A and Category B types.

CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE ITS SR 3.1.4.3 is added which requires scram time Control Rod Scram Timing at testing of the affected control rods with any reactor 3.1.4.3 any Reactor Pressure steam dome pressure be performed prior to declaring i

the control rods OPERABLE.

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Ba dP hdrawal 3.1.6.1 Verifies control rods comply with the BPWS.

e u=nce in A Surveillance is added (ITS SR 3.3.1.1.7) to CTS Table 4.3.1 1 for the IRM Neutron Flux - High APRM to IRM Overlap Test Function and the APRM Neutron Flux - High, Startup 3.3.1.1.7 Requirements Function. This Surveillance verifies proper overlap between the APRMs and IRMs when entering MODE 2 from MODE 1 (during a plant shutdown).

A Surveillance is added (ITS SR 3.3.1.1.14) to CTS Table 4.3.1-1 for the APRM Flow Biased Simulated hime C ns an Thermal Power - High Function (Function 2.b). This 3.3.1.1.14 ef tn surveillance verifies the APRM filter time constant is s 7 seconds once per 24 months.

SRM CHANNEL A requirement to perform a CHANNEL CAllBRATION 3.3.1.2.7 CAllBRATION Requirement every 24 months on SRM instrumentation (ITS SR during Refueling 3.3.2.1.7)is added for SRMs during MODE 5.

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CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE I

RBM Upscale Function A Surveitlance is added (ITS SR 3.3.2.1.4) to venfy 3.3.2.1.4 Interlock Surveillance each RBM Upscale Function is automatically enabled Requirement at the correct power level.

f A Surveillance is added (ITS SR 3.3.2.1.5) to verify 3.3.2.1.5 the RWM Function is automatically enabled at the u ei anc Req r ment correct power level.

Reactor Mode Switch -

ITS SR 3.3.2.1.6 is added to provide appropriate 3.3.2.1.6 Shutdown Position Surveillance Requirements for the Reactor Mode Surveillance Requirement Switch in Shutdown Position Function.

FW and Main Turbine High 3.3.2.2.1 Levelinstrumentation Added CHANNEL CHECK Surveiliance.

CHANNEL CHECK FW and Main Turbine High 3.3.2.2.2 LevelInstrumentation Added CHANNEL CAllBRATION Surveillance.

CHANNEL CAllBRATION FW and Main Turbine High Levelinstrumentation LOGIC Added LOGIC SYSTEM FUNCTIONAL TEST 3.3.2.2.3 SYSTEM FUNCTIONAL Surveillance.

TEST Added CHANNEL CHECK Surveillance for Post Accident Monitoring Suppression Chamber Pressure and PCIV Position 3.3.3.1.1 Instrumentation CHANNEL Functions in PAM Instrumentation Technical CHECK Specification.

Added CHANNEL CAllBRATION Surveillance for Post Accident Monitoring Suppression Chamber Pressure and PCIV Position 3.3.3.1.3 Instrumentation CHANNEL Functions in PAM Instrumentation Technical CAllBRATION y

Specification.

Drywell and Suppression A CHANNEL CHECK requirement is added (ITS SR 3

Chamber Hydrogen and 3.3.3.1.1 3.3.3.1.1) for the drywell and suppression chamber hydrogen and oxygen analyzers.

C AN E HE K Added 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CHANNEL CHECK Surveillance for 3 3.5.1.1 HPCI High Water Level Function in the ECCS CHAN E CHE K Instrumentation Technical Specification.

ECCS Instrumentation Added 92 day CHANNEL FUNCTIONAL TEST 3.3 5.1.2 CHANNEL FUNCTIONAL Surveillance for HPCI High Water Level Function in TEST the ECCS Instrumentation Technical Specification.

Added 92 day Trip Unit Calibration Surveillance for ECCS Instrumentation Trip 3.3.5 1.3 HPCI High Water Level Function in the ECCS Unit Calibration Instrumentation Technical Specification.

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l CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE Added 24 month CHANNEL CAllBRATION ECCS Instrumentation 3.3.5.1.4 Surveillance for HPCI High Water Level Function in CHANNEL CAllBRATION the ECCS Instrumentation Technical Specification.

ECCS Instrumentation Added LOGIC SYSTEM FUNCTIONAL TEST 3.3.5.1.5 LOGIC SYSTEM Surveillance for HPCI High Water Level Function in FUNCTIONAL TEST the ECCS Instrumentation Technical Specification.

ITS SR 3.4.1.1 is provided to define what constitutes Recirculation Pump Speed

" matched speeds" and to verify that recirculation loop 3.4.1.1 Match Criteria Venfication speeds meet the required match criteria once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

A new Surveillance Requirement (ITS SR 3.4.3.2)is 3.4.3.2 SRV Manual Actuation added which requires the SRVs to be manually actuated every 24 months.

RHR Shutdown Cooling - Hot Added a requirement to verify that one RHR SDC 3.4.7.1 Shutdown Surveillance subsystem is in operation or one recirculation pump is Requirement in operation.

RHR Shutdown Cooling -

Added a requirement to verify that one RHR SDC 3.4.8.1 Cold Shutdown Surveillance subsystem is in operation or one recirculation pump is Requirement in operation.

TS SR 3.4.9.6 is added to ensure the vessel head is Venfication of Vessel Head 3.4.9.6 n t tensioned at too low a temperature once per Tensioning 30 minutes.

ITS SR 3.4.9.7 is added to ensure the vessel head Verification of Vessel Head 3.4.9.7 temperature does not exceed the minimum allowed Temperature temperature once per 30 minutes.

ITS SR 3.4.9.8 is added to ensure the vessel flange Verification of Vessel Flange 3.4.9.8 temperature does not exceed the minimum allowed

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.i.e paMe temperature once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

A new Surveillance Requirement (ITS SR 3.5.1.3)

Verification of ADS 3.5.1.3 which verifies the ADS pneumatic supply header Pneumatic Supply Pressure pressure is a 95 psig every 31 days is added.

ITS SR 3.5.2.1 is added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that Venfication of LPCI pump the suppression poollevelis adequate to maintain net 3.5.2.1 NPSH during shutdown positive suction head (NPSH) to the required LPCI subsystem.

l ITS SR 3.6.1.3.3 verifies circuit continuity of the TIP Shear Valve Continuity 3.6.1.3.3 transversing incore probe (TIP) shear isolation valve Test explosive charges.

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CATEGORY A NEW SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE TIP Shear Valve Explosive ITS SR 3.6.1.3.8 functionally tests the TIP shear valve i

3.6.1.3.8 Squib Test explosive squib.

Venfication of Suppression ITS SR 3.6.1.5.2 is provided to verify each vacuum i

3.6.1.5.2 Chamber-to-Drywell Vacuum breaker is closed every 14 days.

Breaker Position Heat Sink Level 3.7.2.1 ITS SR 3.7.2.1 is added to venfy UHS level.

3.7.2.2 ITS SR 3.7.2.2 is added to venfy UHS temperature.

T au V if cation Surveillance Requirement is added to verify every 24 i

Control Room AC System months that each control room AC subsystem is 3.7.4.1 OPERABILITY Venfication capable of maintaining the assumed humidity and removing the assumed heat load.

I Main Turbine Bypass System Surveillance Requirement is added to verify monthly i

3.7.6.1 Surveillance Requi.ements that each turbine bypass valve will open.

Surveillance Requirement is added to verify every 24 Main Turbine Bypass System 3.7.6.2 months that the Main Turbine Bypass System is i

Functional Test functionally OPERABLE.

Surveillance Requirement is added to venfy every 24 TURBlNE BYPASS SYSTEM 3.7 1 3 m nths that the Main Turbine Bypass System can RESPONSE TIME Test respond in the time assumed in the safety analyses.

Check For Water ITS SR 3.8.1.5 is added to check for and remove any 3.81.5 Accumulation in DG Fuel Oil water accumulation in each DG fuel oil engine Engine Mounted Tanks mounted tank once every 31 days.

Automatic Transfer Test from ITS SR 3.8.1.8.a is added to verify every 24 months 3.8.1.8 a the Main Generator to the that on a main generator trip, the automatic transfer SAT from the UAT (normal mode) to the SAT will occur.

A new SR, ITS SR 3.8.1.12, is added for the test mode 3.8.1.12 DG Test Mode Override Test override feature associated with each DG once per 24 months.

A new requirement to venfy total particulates are s 10 Diesel Fuel Oil Particulate 3.83.2 mg/l every 31 days has been added to the Diesel Fuel Testing Oil Testing Program (ITS 5.5.9.c).

Check For Water ITS SR 3.8.3.3 is added to check for and remove any Accumulation in DG Day Fuel water accumulation in each DG day fuel oil storage 3.8~3.3 Oil Storage and the Main tank and the main fuel oil storage tank once every Fuel Oil Storage Tanks 31 days.

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t CATEGORY A NEW SURVEILLANCE REQUIREMENTS l

SR NUMBER TITLE CHANGE Venfication of Opposite Unit ITS SR 3.8.4,8 is added to ensure that the opposite Surveillance Performance unit's DC sources are properly tested during MODES I

3.8.4.8 Associated with DC Sources-1,2, and 3; and that the proper SRs are applicable for i

Operating each unit's DC sources.

ITS SR 3.8.5.2 is added to ensure that the opposite Verification of Opposite Unit unit's DC sources are properly tested during MODES Surveillance Performance 4 and 5, and during movement of irradiated fuel in Associated with DC Sources-secondary containment; and that the proper SRs are Shutdown a licable for each unit's DC sources.

Control Rod Notch Insertion ITS SR 3.9 5.1 is added to verify weekly that any 3 9.5.1 Test During Refueling withdrawn control rods are capable of insertir:g.

Added a requirement to venfy that one RHR SDC RHR-High Water Level 3.9.7.1 subsystem is in operation during refueling with the Surveillance Requirement reactor level high.

j Added a requirement to venfy that one RHR SDC RHR-Low Water Level 3 9.8.1 subsystem is in operation during refueling with the r

Surveillance Requirement reactor levellow.

Surveillance added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , during Fully inserted Control Rod reador moh swM Wod tesdng, au coWol Ms 3.10.2.1 Verification during Mode inserted in core cells containing one or more fuel Switch Testing assemblies.

Verification of No Core Surveillance added to venfy every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , during 3.10 2.2 Alterations during Mode reactor mode switch interlock testing, no CORE Switch Testing ALTERATIONS in progress.

Performance of Appropriate Added a Surveillance Requirement to perform S s dunng Ssgle Control 3.10.3.1 a licable Surveillance Requirements for LCO 3.9 2, 0

LCO 3 9.4, LCO 3 9.5, LCO 3.3.8 2, and LCO 3.3.1.1.

t Disarmed Control Rod Added a Surveillance to venfy every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that all Venfication during Single control rods in the 5XS array centered on the 3.10.3.2 Control Rod Withdrawal-Hot withdrawn control rod are disarmed when withdrawing Shutdown a control rod during hot shutdown.

Fully inserted Control Rod Added a Surveillance to venfy every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that all Verification during Single control rods, except the one withdrawn control rod, are 3.10.3.3 Control Rod Withdrawal-Hot fully inserted when withdrawing a control rod during Shutdown hot shutdown..

Performance of Appropriate Added a Surveillance Requirement to perform SRs during Single Control applicable Surveillance Requirements for LCO 3.9.4 3.10.4.1 Rod Withdrawal-Cold and LCO 3 9.5, and Function 7 of LCO 3.3.1.1.

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CATEGORY A i

NEW SURVEILLANCE REQUIREMENTS i

SR NUMBER TITLE CHANGE

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Control Rod Block Added a Surveillance to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that a Verification during Single control rod block is inserted when removing a single

. 0.5.3 Control Rod Removal-control rod during refueling.

Refueling Surveillance added to verify every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , when j

Verification of No Core Alterations during Singfe removing a single control rod during refueling, no 3.10.5.5 CORE ALTERATIONS in progress.

l 7u n Surveillance added every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , when removing Spiral Reload Sequence multiple control rods during refueling, to verify 3.10.6.3 Verification compliance with an approved spiral reload sequence.

Verification of No Core Surveillance added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , when 3.10.8.4 Alterations during SDM Test -

performing a SJM test during refueling, no CORE Refueling ALTERATIONS in progress.

CRD Charging Header Surveillance added to verify every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , when 3.10 8.6 Pressure Verification during performing a SDM test during refueling, CRD charging SDM Test - Refueling header pressure.

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CATEGORYB MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE An additional Surveillance Frequency for SDM verification (Prior to each in-vessel fuel movement 3.1.1.1 SDM Verification during fuelloading sequence)is also added to CTS 4.1.1.a (ITS SR 3.1.1.1)

CTS 4.1.1.a allows the option of verifying SHUTDOWN MARGIN 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Unit 1) and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Unit 2) prior to the first startup after comoteting CORE 3.1.1.1 SDM Verification ALTERATIONS instead of during the starNr. ITS requires once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after criticaliT fo. low'ng fuel movement within the reactor pressure vessel c/

control rod replacement.

I ITS SR 3.1.4.1 requires control rod scram time testing Control Rod Scram Time for all control rods following each reactor shutdown >

3 1 4.1 Testing AllControlRods 120 days instead of > 120 days as allowed by CTS 4.1.3.2.a.

A Note is added to CTS 4.1.3.2 (ITS SR 3.1.4.1) that Control Rod Scram Time requires the CRD pumps be isolated from the 3'1'4'1 Testing All Control Rods associated control rod scram accumulator during a single control rod time scram time surveillance.

A Note is added to CTS 4.1.3.3 (ITS SR 3.1.4.2) that Control Rod Scram Time requires the CRD pumps be isolated from the 3.1.4.2 Testing Of Representative associated control rod scram accumulator during a Sample single control rod time scram time surveilla ice.

A Note is added to CTS 4.1.3 4 (ITS SR 3.1.4 4) that Control Rod Scram Time requires the CRD pumps be isolated from the 3.1.4.4 Testing Affected Control associated control rod scram accumulator during a RMs single control rod time scram time surveillance.

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The acceptance criteria associated with the control rod Control Rod Scram Time 3.1.4.2, and scram times (ITS Table 3.1.4-1) have been made Tests 3.1.4.4 more restrictive.

ITS SR 3.1.5.1 includes the acceptance criteria (2 940 Weekly Control Rod scram 3151 psig) to the weekly control rod scram accumulator test Accumulator Test consistent with current Brunswick plant practice.

fes ret e 3.1.7.2 So ut on pe a e Verification AS-7

CATEGORYB MORE RESTRICTIVE CHANGES TO CTS SURVE!LLANCE REQUIREMENTS SR NUMBER TITLE CHANGE The Surveillance (ITS SR 3.1.7.5) that determines boron solution concentration anytime water or boron is added to the SLC solution or when the solution temperature drops below the limit is modified to Standby Liquid Control Boron include a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period to perform the 3.1.7.5 Solution Concentration Surveillance. ITS SR 3.1.7.5 also more clearly defines Venfication the Frequency of CTS 4.1.5.b.3 associated with solution temperature outside limits by requiring venfication that boron concentration is within limits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after restoring temperature to within limits.

The SLC pump flow and pressure are currently tested per the IST Program once per 92 days. Therefore, the i

6'C Pum F w and 3.1.7.6 Frequency of this Surveillance (in ITS SR 3.1.7.6) is e

revised to be "in accordance with the Inservice Testing Program"instead of once per 18 months.

CTS Table 4.3.1-1 Notes (m) and (n) that allow the reactor mode switch to be moved to another position Weekly APRM CHANNEL without making a MODE change for the purpose of 3'3'1'1'4 FUNCTIONAL TEST performing Surveillances on the APRM Startup High Function (Function 2.a) and APRM inoperative Function (Function 2.d) are eliminated in ITS.

CTS Table 4.3.1-1 Notes (m) and (n) that allow the reactor mode switch to be moved to another position Quarterly APRM CHANNEL without making a MODE change for the purpose of 3'3'1'1'9 FUNCTIONAL TEST performing Surveillances on the APRM Startup High Function (Function 2.a) and APRM inoperative Function (Function 2.d) are eliminated in ITS.

A Surveillance is added (ITS SR 3.3.1.1.16) to verify 30% Bypass Verification the automatic enabling of the Turbine Stop 3.3.1.1.16 associated with RPS TSV Valve - Closure RPS Function and Turbine Control and TCV Closure Functions Valve Fast Closure, Control Oil Pressure - Low RPS Function at 2 30% RTP.

CTS 4.3.5.4.b verifies SRM count rate is a 3 cps prior to withdrawal of control rods. A requirement to 3.3.1.2.4 SRM Count Rate Venfication perform the SRM count rate within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to control rod withdrawal (ITS SR 3.3.1.2.4) is added to ensure the surveillance data is reasonably current.

l The allowance to waive venfying SRM count rate has been m dified to only allow the note to be used when 3.3.1.2 4 SRM Count Rate Verification no other fuel assemblies are in the associated core quadrant.

AS-8

CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE CTS 4.1.4.1.1 requires a CHANNEL FUNCTIONAL TEST to be performed on the RWM prior to withdrawal of control rods for the purpose of making the reactor RWM CHANNEL critical. The Note to ITS SR 3.3.2.1.2 requires a 3.3.2.1.2 FUNCTIONAL TEST CHANNEL FUNCTIONAL TEST to be performed on the RWM after withdrawal of any control rod when RTP is s 10%, not just when the withdrawal is for the purpose of making the reactor critical.

Drywell and Suppression The CHANNEL CAllBRATION requirement Chamber Hydrogen and (SR 3.3.3.1.2) for the drywell and suppression 3.3.3.1.2 Oxygen Analyzer CHANNEL chamber hydrogen and oxygen analyzers is specified CALIBRATION as once per 92 days.

The Frequency of performing the CHANNEL CALIBRATION for Functions 3.c and 6.a of ITS Table 3 3.6.1.4 Is on nst u ntation 3.3.6.1-1 has been changed from every 18 months to CHANNEL CALIBRATION every 92 days.

This change modifies current item 2 and item 4.a of CTS Table 4.4.5-1 (ITS SR 3.4.6.1) to change the Dose Equivalent (-131 3.4.6.1 frequency for isotopic analysis for Dose Equivalent l-Isotopic Analysis 131 concentration from at least once per 31 days to at least once per 7 days.

CTS 4.4.1.1.1 only requires performance of the recirculation pump discharge valve and bypass valve functional tests during a Cold Shutdown which Recirculation Pump exceeds 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months if not performed in the previous 3.5.1.5 Discharge and Bypass Valve 31 days. The ITS frequency of SR 3.5.1.5 requires Functional Test the valves to be tested prior to each startup (before exceeding 25% RTP) if not tested within the previous 31 days (the frequency stated in ITS SR 3.5.1.5).

A Note is added to CTS 4.5.3.1.a (ITS SR 3.5.2.2.b)

CST Level Verification for that only allows one CS subsystem to be aligned to j

3.5.2.2.b Core Spray the CST during operations with the potential for draining the vessel (OPDRVs).

The requirement to venfy the RCIC pump flow rate in CTS 414r2 is modM in US SR 3.5.3.4 to McWe 3.5.3.4 RCIC Flow Test the criteria of verifying pump flow against a system head corresponding to reactor operating pressure.

j A5-9

CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS l

SR NUMBER TITLE CHANGE The CTS 4.6.5.1.b requires that one Standby Gas Treatment (SGT) subsystem be tested every 18 m nths to verify the capability to maintain a 1/4 inch of Secondary Containment vacuum in secondary containment. ITS SR 3.6.4.1.1 3.6.4.1.1 Drawdown Test requires both subsystems be tested in the course of two outages - as represented by the STAGGERED TEST BASIS requirement of the Frequency.

The Ventilation Filter Testing Program pro; ides more Standby Gas Treatment restrictive acceptance criter% for the SGT System 3.6.4.3.2 Subsystem Filter Testing heaters.

A requirement to verify the automatic starting of each Service Water System NSW pump on an actual or simulated initiation signal Automatic Actuation Test is added to CTS 4.7.1.2.b (ITS SR 3.7.2.5).

l CREV subsystem flowrate acceptance criteria are Control Room Positive 3.7.3.3 added to CTS 4.7.2.d.4 (ITS SR 3.7.3.3) and the radiation / smoke protection mode is specified.

CTS 4.11.2.7.2.c requires venfication that the release rate from noble gases from the main condenser air Main Condenser Air Ejector ejector is within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following an 3'7'5'1 Release Rate Verification increase of greater than 50%. The amount of increase is changed from greater than 50% to also include an increase equivalent to 50% in ITS SR 3.7.5.1.

Note

to CTS 4.8.1.1.2.a.4 allows the option to either precede the start with a prelube period or use other warmup procedures during DG starts. ITS SR 3.8.1.2 3.8.1.2 Monthly DG Start Test Note 1 (CTS 4.8.1.1.2.a.4 Note *) requires that if a i

slow start is performed, it will be preceded by a prelube period and a warmup period.

Voltage and frequency requirements are added to DG 3.8.1.2 Monthly DG Start Test tests required by CTS 4.8.1.1.2.a.4 (and

Note) and j

4.8.1.1.2.d.3.b).

Two Notes are added to CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3). Note 3 precludes this surveillance from being performed on more than one DG at a time.

3.8.1.3 Monthly DG Load Run Nets 4 requires this SR to be immediately preceded by a successful performance of ITS SR 3.8.1.2 or SR 3.8.1.7 (DG start Surveillances).

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CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE The DG loading requirement associated with CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3) is increased from 1750 kW to a range of a 2800 kW and s 3500 kW.

3.8.1.3 Monthly DG Load Run Also, the DG run time for CTS 4.8.1.1.2.a.5 (ITS SR 3.8.1.3) is increased from 15 minutes to 60 minutes.

DG Engine-mounted Tank The test acceptance enteria has been made more 3.8.1.4 Level Verification restrictive.

Voltage and frequene) requireme.nts are added to DG j

3.8.1.7 DG Timed Start Test tests required by CTS 4.8.1.1.2.a.4 (and

Note) and 4.8.1.1.2.d.3.b).

Limitations on the operating power factor are added to 3.8.1.9 DG Load Reject Test CTS 4.8.1.1.2.d.2, single load rejection test (as Note 2 to SR 3.8.1.9).

An upper DG load limit is added to ITS SR 3.8.1.11 3 8.1.11 DG Full Load Run (CTS 4.8.1.1.2.d.5).

Limitations on the operating power factor are added to 3.8.1.11 DG Full Load Run CTS 4.8.1.1.2.d.5. the full load run test (SF. 3.8.1.11).

The wording associated with CTS 4.8.1.1.2.d.7 is DG Load Secuence interval changed from " load sequence time within 10% of the 3.8.1.13 Test required value" to " load sequence time within 10% of design interval."in ITS SR 3.8.1.13.

Voltage and frequency requirements are added to DG 3.8.1.14 LOCA/ LOOP Test tests required by CTS 4.8.1.1.2.a.4 (and

Note) and 4.8.1.1.2.d.3.b).

The DG 10 second start time is added to CTS 3.8.1.14.c LOCA/ LOOP Test 4.8.1.1.2.d.3 b (ITS SR 3.8.1.14.c).

DG Fuel Oil Storage and Day The test acceptance enteria has been made more 3~8'3'1 Tank Volume Venfication restrictive.

CTS 4.8.2.3.2 requires verification that the total battery terminal voltage is greater than or equal to 129 Weekly Battery Voltage volts on float charge. ITS SR 3.8.4.1 requires 3.8.4.1 Check verification that the total battery terminal voltage is

> 130 V on float charge.

i A5-11 i

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CATEGORY B MORE RESTRICTIVE CHANGES TO CTS SURVEILLANCE REQUIREMENTS SR NUMBER TITLE CHANGE CTS 4.8.2.3.2.b.2 requires verification that inter-cell and terminal connection resistance is less than 150 x 108 ohms. Discussion of Change LA.2 relocates Quarterly Battery Cell these limits to the Bases. However, these limits are 3.8.4.2 Interconnection revised in the Bases such the connection resistance erm nadon during the verification must be less than 20% above the established benchmark value for inter-cell and terminal connections.

Additional Frequencies are added and state "12 months when battery shows degradation or has Battery Performance reached 85% of the expected life with capacity <

3.8.4.7 Discharge Test 100% of manufacturer's rating" and "24 months when battery has reached 85% of the expected life with capacity > 100% of manufacturer's rating."

Additional limitations are imposed on CTS Table 4.8.2.3.2-1 footnote (b) (ITS Table 3.8.6-1, Weekly Battery Pilot Cell footnote (c)). These new limitations restrict the use of 3.8.6.1 Parameter Venfication replacing specific gravity checks with charging current checks to 7 days when the battery is on float charge following a battery charge only.

Additional limitations are imposed on CTS Table 4.8.2.3.2-1 footnote (b) (ITS Table 3.8.6-1, Quarterly Battery Cell footnote (c)). These new limitations restrict the use of 3.8.6.2 Parameter Venfication replacing specific gravity checks with charging current checks to 7 days when the battery is on float charge following a battery charge only.

The CTS Table 4.8.2.3.2-1 footnote (c) allowance to Quarterly Battery Cell 3.86.2 correct the Category B float voltage limit for Parameter Verification temperature is deleted.

ITS SR 3.9.1.1 requires the performance of a

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3 9.1.1 CHANNEL FUNCTIONAL TEST to demonstrate the N

NAL T

OPERABILITYpf the refuel position interlocks.

CTS 4.9.1.2 requires the refueling interlocks to be Refuel Position One-Rod-Out demonstrated OPERABLE but does not provide 3 9.2.2 Interlock CHANNEL specific testing requirements. ITS SR 3.9.2.2 requires FtlNCTIONAL TEST a weekly CHANNEL FUNCTIONAL TEST.

CTS 4.1.3.5 requires the control rod scram Control Rod Scram accumulators be determined OPERABLE once per 7 3.9.5.2 Accumulator Pressure days. ITS SR 3.9.5.2 includes the acceptance criteria Venfication During Refueling

(> 940 psig) consistent with current Brunswick plant practice.

AS-12

ATTACHMENT 6 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND.DPR-62 REQUEST FOR LICENSE AMENDMENTS REVISION TO UNIT 2 OPERATING LICENSE l

i This attachment provides the proposed changes to the Unit 2 Operating License to allow single i

recirculation loop operation. The proposed change would delete the Unit 2 license condition that currently does not allow single recirculation loop operation for an extended period. The basis for this proposed change is provided in the L.1 Discussion of Change (DOC) for ITS Specification 3.4.1. A copy of the marked-up and typed Unit 2 Operating License are also l

attached.

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13rJP LW 2.

I

o p %g u c w s y_

described within the program within the two year monitoring period, or Phase III following initiation of Phase II, is required the licensee will i

o either comply with a request to proceed to Phase II (or Phase III) or immediately request and be granted a hearing on the issue of whether l

the data on which the staff's request is based justifies the initiation of Phase II (or Phase III) under the program for seistriic monitoring i

agreed to by the licensee and the NRC staff. Nothing herein will be construed as precluding changes in the program by the licensee which do not adversely affect the quantity of informatien derived from the i

monitoring program. NRC will be informed of any such changes in the quarterly report.

(4)

Ennative Valve Faerietian

'Ihe valves in the equalien piping bet w the recirculation loops shall be closed at all times during reactor operations.

(5)

(9Jin 'J* dan I aan Iw-rable

).Aut g A~ A-. - W..C 3 shall be

'tical both

' ulation och are in

'ce.

sth the ag, if one

_ dad _ loop mes out service plant be p in a hot utdown ition thin 24 pours. T g conditiojat'shall be owed in which one or rectreulajion loops are,dut of service for the (purposes of (not to exceed 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,s)f (6)

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miecallanenus Amendments and Search Requirernents revisions to 10CFR73.55 (51 FR 27817 and 27822) and to the authority of 10CFR50.90 and 10CFR50.54(p). 'Ihe plans, which contain Safeguards Information protected under 10CFR73.21 are entitled: " Brunswick Steam Electric Plant Industrial Security Plan," with revisions submitted through September 23,1987;

" Brunswick Steam Electric Plant Security Paowl Training and Qualification Plan," with revisions through January 20,1987; and

" Brunswick Steam Electric Plant Safeguards Contingency Plan," with revisions submitted through March 27,1986. Changes made in accordance with 10CFR73.55 shall be implemented in accordance with the schedule set forth therein.

3 l oE I 7

e

?

5 described within the program within the two year monitoring period, or j

i Phase III following initiation of Phase II, is required the licensee will l

cither comply with a request to proceed to Phase II (or Phase III) or l

immediately request and be granted a hearing on the issue of whether the data on which the staff's request is based justifies the initiation of Phase II (or Phase III) under the program for seismic monitoring l

agreed to by the licensee and the NRC staff. Nothing herein will be l

construed as precluding changes in the program by the licensee which.

do not adversely affect the quantity of information derived from the l

i-monitoring program. NRC will be informed of any such changes in the j

quanerly report.

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'(4)

Eaualizer Valve Restriction i

The valves in the equahzer pipmg between the recirculation loops shall j

be closed at all times during reactor operations.

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(5)

Deleted by Amendment No. [ ]

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(6)

The licensee shall fully implement and maintain in effect all provisions l

of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and i

l Search Requirements revisions to 10CFR73.55 (51 FR 27817 and l

27822) and to the authority of 10CFR50.90 and 10CFR50.54(p). The plans, which contain Safeguards Information protected under i

10CFR73.21 are entitled: " Brunswick Steam Electric Plant Industrial Security Plan," with revisions submitted through September 23,1987;

" Brunswick Steam Electric Plant Security Personnel Training and Qualification Plan," with revisions through January 20,1987; and

" Brunswick Steam Electric Plant Safeguards Contingency Plan," with revisions submitted through March 27,1986. Changes made in accordance with 10CFR73.55 shall be implemented in accordance with the schedule set forth therein.

-

BSEP-96-0414, Application for Amends to Licenses DPR-71 & DPR-62,revising TSs to Format Consistent w/NUREG-1433,rev 1.Vols 1-15 of Improved TSs Encl

Text

Enclosure:

Enclosure:

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