Text

Issuance of Amendment Nos. 304 and 332 Revise Technical Specification 3.4.7 and 3.4.8 to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystem
	ML20309A784
Person / Time
Site:	Brunswick
Issue date:	03/18/2021
From:	Andrew Hon; Plant Licensing Branch II
To:	Krakuszeski J; Duke Energy Progress
	Hon A J-NRR/DORL 301-415-8480
References
	EPID: L-2020-LLA-0166
	Download: ML20309A784 (26)
	v • d • e

March 18, 2021 Mr. John A. Krakuszeski Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd. SE (M/C BNP001)

Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 304 AND 332 RE: REVISE TECHNICAL SPECIFICATIONS 3.4.7 AND 3.4.8 TO ADOPT TSTF-566, REVISE ACTIONS FOR INOPERABLE RHR SHUTDOWN COOLING SUBSYSTEM (EPID L-2020-LLA-0166)

Dear Mr. Krakuszeski:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 304 and 332 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2. The amendments consist of changes to the technical specifications (TSs) in response to your application dated July 21, 2020.

The amendments adopt Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems. The amendments revise TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, and TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown.

J. Krakuszeski A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register Notice.

Sincerely,

/RA/

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

Enclosures:

1. Amendment No. 304 to License No. DPR-71

2. Amendment No. 332 to License No. DPR-62

3. Safety Evaluation cc: Listserv

DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 304 Renewed License No. DPR-71

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

A. The application for amendment filed by Duke Energy Progress, LLC (the licensee),

dated July 21, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

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

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 304, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

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

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Undine S. Undine S. Shoop Date: 2021.03.18 Shoop 14:53:08 -04'00' Undine S. Shoop, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachments:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: March 18, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 304 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace page 6 of Renewed Facility Operating License No. DPR-71 with the attached page 6.

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

Remove Page Insert Page 3.4-14 3.4-14 3.4-15 3.4-15 3.4-17 3.4-17 3.4-18 3.4-18

6 (c) Transition License Conditions

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

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

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

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

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

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 304, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 304

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling SystemHot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES -------------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each required AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

Brunswick Unit 1 3.4-14 Amendment No. 304233

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. Required Action and B.1 Initiate Action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem(s) to OPERABLE status.

C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one AND recirculation pump to operation.

No recirculation pump in operation. AND C.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

Brunswick Unit 1 3.4-15 Amendment No. 304233

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling SystemCold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES -------------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each shutdown cooling subsystem.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem(s) to OPERABLE status.

(continued)

Brunswick Unit 1 3.4-17 Amendment No. 304203

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsystem in operation. circulating by an alternate discovery of no method. reactor coolant AND circulation No recirculation pump in AND operation.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one required RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 1 3.4-18 Amendment No. 304276

DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 332 Renewed License No. DPR-62

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

A. The application for amendment filed by Duke Energy Progress, LLC (the licensee), dated July 21, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

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

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 332, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

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

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Undine S. Undine S. Shoop Date: 2021.03.18 Shoop 14:54:04 -04'00' Undine S. Shoop, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachments:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: March 18, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 332 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace page 6 of Renewed Facility Operating License No. DPR-62 with the attached page 6.

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

Remove Page Insert Page 3.4-14 3.4-14 3.4-15 3.4-15 3.4-17 3.4-17 3.4-18 3.4-18

6 (c) Transition License Conditions

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

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

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

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

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

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 332, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 332

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling SystemHot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES -------------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each required AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter (continued)

Brunswick Unit 2 3.4-14 Amendment No. 3320

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. Required Action and B.1 Initiate action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem(s) to OPERABLE status.

C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one AND recirculation pump to operation.

No recirculation pump in operation. AND C.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

Brunswick Unit 2 3.4-15 Amendment No. 332260

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling SystemCold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES -------------------------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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

Separate Condition entry is allowed for each shutdown cooling subsystem.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or two required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable required RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem(s) to OPERABLE status.

(continued)

Brunswick Unit 2 3.4-17 Amendment No. 332233

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsystem in operation. circulating by an alternate discovery of no method. reactor coolant AND circulation No recirculation pump in AND operation.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one required RHR shutdown cooling subsystem In accordance with or recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled the Surveillance with water. Frequency Control Program Brunswick Unit 2 3.4-18 Amendment No. 332233

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 304 AND 332 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62 DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By application dated July 21, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20203M352), Duke Energy Progress, LLC (Duke Energy or the licensee) submitted a license amendment request (LAR) for Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The amendment would revise technical specification (TS) actions for inoperable residual heat removal (RHR) shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation (LCOs).

The proposed changes are based on Technical Specifications Task Force (TSTF) traveler TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, dated January 19, 2018 (ADAMS Accession No. ML18019B187). The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation (SE) approving TSTF-566, Revision 0, on February 21, 2019 (ADAMS Accession No. ML19028A287).

The licensee has proposed variations from the TS changes described in TSTF-566, Revision 0.

The variations are described in Section 2.2.1 of this SE and evaluated in Section 3.3.

2.0 REGULATORY EVALUATION

2.1 DESCRIPTION

OF RESIDUAL HEAT REMOVAL SHUTDOWN COOLING SYSTEM Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to 212°F in preparation for performing Refueling or Cold Shutdown maintenance operations.

The RHR System has two loops, with each loop consisting of two motor-driven pumps, a heat exchanger, and associated piping and valves. There are two RHR shutdown cooling subsystems per RHR System loop. Both loops have a common suction from the same recirculation loop. The four redundant, manually controlled shutdown cooling subsystems of the Enclosure 3

RHR System provide decay heat removal. Each pump discharges the reactor coolant, after circulation through the respective heat exchanger, to the reactor via the associated recirculation loop. The RHR heat exchangers transfer heat to the RHR Service Water System. Any one of the four RHR shutdown cooling subsystems can provide the required decay heat removal function.

Technical Specification 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, is applicable on Mode 3 with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure. Technical Specification 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, is applicable in Mode 4. They both require two operable RHR shutdown cooling subsystems and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem in operation.

2.2 PROPOSED CHANGE

S TO THE TECHNICAL SPECIFICATIONS The licensee proposed to revise TS actions for inoperable RHR shutdown cooling subsystems in the RHR shutdown cooling system LCOs, consistent with TSTF-566, Revision 0.

The proposed changes would revise TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, and TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, for BSEP Unit 1 and Unit 2. The proposed changes are described below.

2.2.1 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of BSEP TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, require the operators to initiate action to restore RHR shutdown cooling subsystem(s) to operable status (Required Action A.1) immediately, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.2) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and be in Mode 4 (Required Action A.3) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The licensee proposed to move Required Action A.1 to new Condition B (as Required Action B.1) and delete Required Action A.3. The LAR also proposed to add a recurring completion time (CT) to current Required Action A.2 of once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. The proposed changes also renumber current Required Action A.2 as A.1 since Required Actions A.1 and A.3 are removed from Condition A.

The licensee also proposed a new Condition B for when the required action and associated CT of Condition A are not met. New Condition Bs Required Action B.1 is moved from current Required Action A.1 and requires operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

Current Required Action A.2 was renumbered as A.1, since Required Actions A.1 and A.3 were deleted. Current Condition B and its required actions were renamed C, C.1, C.2, and C.3, respectively, since new Condition B was added.

2.2.2 Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, require the operators to verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.1) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

The licensee proposed a new Condition B for when the required action and associated CT of Condition A are not met, which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

Current Condition B and its required actions were renamed C, C.1, and C.2, respectively, since new Condition B was added.

2.2.1 Variations from TSTF-566 The BSEP TSs utilize different numbering than the Standard Technical Specifications (STS) on which TSTF-566 was based. Specifically, STS 3.4.8, "RHR Shutdown Cooling System -Hot Shutdown" is TS 3.4.7 in the BSEP TS and STS 3.4.9, "RHR Shutdown Cooling System -Cold Shutdown" is TS 3.4.8 in the BSEP TS. These differences are editorial and do not affect the applicability of TSTF-566 to the proposed LAR.

2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include in the application proposed TSs.

The regulation at 10 CFR 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The regulation at 10 CFR 50.40(a) states, in part, that the TS shall provide reasonable assurance that the health and safety of the public will not be endangered.

The regulation at 10 CFR 50.36(a)(1) states, in part: A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the

NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable reference STS (i.e., the current STS), as modified by NRC-approved travelers.

U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 30, 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively).

3.0 TECHNICAL EVALUATION

3.1 PROPOSED CHANGE

S TO RESIDUAL HEAT REMOVAL (RHR) SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN The licensee proposed to modify TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown. The technical evaluation of each change follows.

3.1.1 Evaluation of Changes to Condition A The licensee proposed to add a recurring CT to current Required Action A.2 of once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. Current Required Action A.2 requires verification that an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The NRC staff finds this change is acceptable, since it requires continuous verification of alternate methods of decay heat removal every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and provides assurance of continued heat removal capability.

The licensee also proposed to delete current Required Action A.3, which requires the plant to be in Mode 4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one or two RHR shutdown cooling subsystems are inoperable.

Current Required Action A.3 requires operators to reduce the reactor coolant system temperature to the point where Mode 4 is entered, due to the potentially reduced reliability of the alternate methods of decay heat removal. However, if there is no operable RHR shutdown cooling subsystem and the plant is in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition (typically less than 200°F) within the CT. In addition, in a typical Boiling Water Reactor (BWR) design, the RHR shutdown cooling system has a heat rejection capability many times greater than alternate methods available. Therefore, for periods in which there is high decay heat load, the BWR design does not include any system which can satisfy Required Action A.3. The NRC staff finds the deletion of current Required Action A.3 is acceptable because, at below the RHR cut in permissive pressure, the remaining required action will continue to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

Current Required Action A.2 is renumbered as A.1, since Required Actions A.1 and A.3 are removed from Condition A. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.1.2 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met. New Condition Bs required action, B.1, is moved from current Required Action A.1 and requires operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately. The NRC staff finds that relocating the required

action from A.1 to new Required Action B.1 is acceptable because other ways of removing decay heat are available, such as natural circulation, the spent fuel pool cooling system, the reactor water cleanup system, and an inoperable, but functional, RHR shutdown cooling subsystem.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT immediately is defined in Section 1.3 of the BSEP TSs as, the Required Action should be pursued without delay and in a controlled manner.

New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B, with its Required Action B.1, provides an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.1.3 Evaluation of Changes to Existing Condition B Current Required Action A.2 was renumbered as A.1, since Required Actions A.1 and A.3 were deleted. Current Condition B and its required actions were renamed C, C.1, C.2, and C.3, respectively, since new Condition B was added. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.1.4 Conclusion of Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown The NRC staff concludes the proposed changes are acceptable since the TS continues to meet the requirements of 10 CFR 50.40(a) because it provides reasonable assurance that the health and safety of the public will not be endangered.

3.2 PROPOSED CHANGE

S TO RESIDUAL HEAT REMOVAL (RHR) SHUTDOWN COOLING SYSTEM - COLD SHUTDOWN The licensee proposed to modify TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown. The technical evaluation of each change follows.

3.2.1 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met, which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT immediately is defined in Section 1.3 of the TSs as, the Required Action should be pursued without delay and in a controlled manner. New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems

are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B with its Required Action B.1 provide an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths, and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.2.2 Evaluation of Changes to Existing Condition B Current Condition B and its required actions were renamed C, C.1, and C.2, respectively, since new Condition B was added. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.2.3 Conclusion of Proposed Changes to Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown The NRC staff concludes the proposed changes are acceptable since the TS continues to meet the requirements of 10 CFR 50.40(a) because it provides reasonable assurance that the health and safety of the public will not be endangered.

3.3 VARIATIONS FROM TSTF-566 The licensee described variations from TSTF-566 in Section 2.2 of the LAR. The licensee provided justification for the proposed variations. The BSEP TSs utilize different numbering than the STS on which TSTF-566 was based. The NRC staff determined these differences are editorial and do not affect the applicability of TSTF-566 to the proposed LAR.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the North Carolina State official was notified of the proposed issuance of the amendment on November 23, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area, as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, which was published in the Federal Register on September 8, 2020 (85 FR 55507), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

6.0 CONCLUSION

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

Principal Contributors: M. Hamm, NRR Date: March 18, 2021

ML20309A784 OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/LA NRR/DSS/STSB/BC NAME AHon BAbeywickrama VCusumano DATE 11/04/2020 11/9/2020 10/20/2020 OFFICE NRR/DSS/SNSB/BC OGC - NLO NRR/DORL/LPLII-2/BC NAME SKrepel TJones UShoop DATE 11/06/2020 12/08/2020 03/18/2021 OFFICE NRR/DORL/LPLII-2/PM NAME AHon DATE 03 /18 /2021

v t e Letter Sequence Approval
EPID:L-2020-LLA-0166, TSTF-566 (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2020-07-21 [Table View]

ML20309A784

Text

SUBJECT:

Dear Mr. Krakuszeski:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 DESCRIPTION

2.2 PROPOSED CHANGE

3.0 TECHNICAL EVALUATION

3.1 PROPOSED CHANGE

3.2 PROPOSED CHANGE

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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