RA-20-0361, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, Dated September 24, 2020, ADAMS Accession Number ML20272A091

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Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, Dated September 24, 2020, ADAMS Accession Number ML20272A091
ML20323A405
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/17/2020
From: Krakuszeski J
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0361
Download: ML20323A405 (7)
v • d • e


Text

e.l_-, DUKE

~ ENERGY November 17, 2020 Serial: RA-20-0361 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 John A. Krakuszeski Vice President Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 10 CFR 50.90

Subject:

Supplement to Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC)

Enhancements" Reference Letter from John A. Krakuszeski (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements," dated September 24, 2020, ADAMS Accession Number ML20272A091 Ladies and Gentlemen:

By [[letter::RA-20-0165, Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements|letter dated September 24, 2020]] (i.e., Reference), Duke Energy Progress, LLC (Duke Energy), submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The LAR proposed adoption of TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements." The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control." The purpose of this submittal is to supplement the Duke Energy's September 24, 2020, LAR.

Section 2.2 of the TSTF-582 LAR included the following sentence:

Similarly, BSEP TS Table 3.3.5.3-1 does include Functions equivalent to STS Table 3.3.5.2-1 Function 1.b, "Core Spray Pump Discharge Flow - Low (Bypass)," and Function 2.b, "Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)."

The sentence should read:

Similarly, BSEP TS Table 3.3.5.3-1 does not include Functions equivalent to STS Table 3.3.5.2-1 Function 1.b, "Core Spray Pump Discharge Flow - Low (Bypass)," and Function 2.b, "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)."

A corrected page is included in Enclosure 1. This page replaces the page included in the September 24, 2020, TSTF-582 LAR.

U.S. Nuclear Regulatory Commission Page 2 of 2 The Completion Time for proposed Required Action A.2.2. of TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation," was inadvertently omitted from Unit 2 only. The Completion Time for this Required Action is Immediately. Enclosure 2 includes updated marked-up and revised Unit 2 pages that include the Completion Time. These pages replace those provided in the September 24, 2020, TSTF-582 LAR.

Duke Energy has determined that the information provided in this supplement does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared for the proposed amendment.

This document contains no new regulatory commitments. Please refer any questions regarding this submittal to Mr. Art Zaremba, Director - Nuclear Fleet Licensing, at (980) 373-2062.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 17, 2020.

Sincerely, John A. Krakuszeski MAT/mat

Enclosures:

cc:

1. Corrected Page 2 of 7 for Enclosure 1 of RA-20-0165
2. Updated Unit 2 Technical Specification Page 3.3-48a (Marked-up and Revised}

Ms. Laura Dudes, Regional Administrator, Region II Mr. Andrew Hon, Project Manager Mr. Gale Smith, NRC Senior Resident Inspector Chair - North Carolina Utilities Commission Mr. W. Lee Cox, Ill Section Chief, Radiation Protection Section, NC DHHS

RA-20-0361 Corrected Page 2 of 7 for Enclosure 1 of RA-20-0165

RA-20-0165 Page 2 of 7 The BSEP TS requirements differ from the STS on which TSTF-582 was based but these differences do not affect the applicability of TSTF-582 justification to the BSEP TS. Specifically, the following differences exist.

As discussed in TSTF-582, BSEP does not have an Emergency Core Cooling System (ECCS) manual initiation signal. Crediting manual starting of pumps and manual valve alignment to permit the required ECCS injection/spray subsystem to inject into the Reactor Pressure Vessel (RPV) was approved as a variation to TSTF-542 (i.e. Amendments 283 and 311 for BSEP Units 1 and 2, respectively, issued on April 13, 2018 (ML18039A444)). Similarly, BSEP TS Table 3.3.5.3-1 does not include Functions equivalent to STS Table 3.3.5.2-1 Function 1.b, "Core Spray Pump Discharge Flow - Low (Bypass)," and Function 2.b, "Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)." As a result of the above variations, requirements equivalent to STS TS 3.3.5.2, Condition D and SR 3.3.5.2.3 were not included in BSEP TS 3.3.5.3. Also, existing BSEP SR 3.5.2.8 is currently worded as proposed by TSTF-582. Each of these differences were approved as variations to TSTF-542 and do not impact the applicability of TSTF-582 to the BSEP TS.

TSTF-582, "RPV WIC Enhancements," states:

The ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense-in-depth against an unexpected draining event. The changes in TSTF-542 did not assume automatic actuation of the ECCS subsystem. TS 3.5.2, Required Action D.1 requires an additional method of water injection and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. However, LCO 3.5.2 does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal.

LCO 3.8.2, "AC Sources - Shutdown," requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5. SR 3.8.2.1 lists the TS 3.8.1, "AC Sources -

Operating," SRs that are applicable in Modes 4 and 5. In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were not excluded from SR 3.8.2.1.

TSTF-582 revises Technical Specification (TS) 3.8.2, "AC Sources - Shutdown," Surveillance Requirement (SR) 3.8.2.1, to exclude SRs that verify the ability of the diesel generators to automatically start and load on an ECCS initiation signal or loss of offsite power signal.

The NRC Safety Evaluation for TSTF-582 (ADAMS Accession No. ML20219A333, dated August 13, 2020), Section 3.6, "Alternating Current Sources - Shutdown, STS 3.8.2," states:

STS 3.5.2, "Reactor Pressure Vessel Water Inventory Control (RPV WIC)," does not require automatic ECCS initiation to mitigate a draining event in Modes 4 and 5, and the ECCS initiation signal related to the automatic ECCS initiation is removed from the STS.

RA-20-0361 Updated Unit 2 Technical Specification Page 3.3-48a (Marked-up and Revised)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48a Amendment No. 311 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.3-1 for the channel.

Immediately AB. One or more channels inoperable.As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

A.1 Initiate action to place channel in trip.

OR A.2.1B.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2B.2 Initiate action to Ccalculate DRAIN TIME.

Immediately Immediately Immediately C.

As required by Required Action A.1 and referenced in Table 3.3.5.3-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (continued)

RPV Water Inventory Control Instrumentation 3.3.5.3 Brunswick Unit 2 3.3-48a Amendment No. 311 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Initiate action to place channel in trip.

OR A.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately (continued)

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