Text

Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems
	ML20203M352
Person / Time
Site:	Brunswick
Issue date:	07/21/2020
From:	Krakuszeski J; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-20-0142
	Download: ML20203M352 (31)
	v • d • e

John A. Krakuszeski el_'-> DUKE Vice President Brunswick Nuclear Plant

~ ENERGY 8470 River Rd SE Southport, NC 28461 o: 910.832 .3698 July 21, 2020 Serial: RA-20-0142 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: 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

Subject:

Application to Revise Technical Specifications to Adopt TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems" Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC (Duke Energy), is submitting a request for an amendment to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

Duke Energy requests adoption of TSTF-566, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," which is an approved change to the Improved Standard Technical Specifications (ISTS), for the BSEP, Unit Nos. 1 and 2, Technical Specifications (TS). The proposed amendment revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable.

Enclosure 1 provides a description and assessment of the proposed changes. Enclosures 2 and 3 provide the existing TS pages marked-up to show the proposed changes for Units 1 and 2, respectively. Enclosures 4 and 5 provide revised (typed) TS pages for Units 1 and 2, respectively. Enclosure 6 provides Unit No. 1 TS Bases pages marked-up to show the proposed changes for information only.

Approval of the proposed amendment is requested within six months of completion of the NRC's acceptance review. Once approved, the amendment shall be implemented within 120 days.

In accordance with 10 CFR 50.91, Duke Energy is providing a copy of the proposed license amendment to the designated representative for the State of North Carolina.

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.

U.S. Nuclear Regulatory Commission Page 2 of 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 21, 2020.

Sincerely, qcJJ--[\_. ~

John A. Krakuszeski MAT/mat

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up) - Unit 1

3. Proposed Technical Specification Changes (Mark-Up) - Unit 2

4. Revised Technical Specification Pages - Unit 1

5. Revised Technical Specification Pages - Unit 2

6. Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only) cc:

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-20-0142 Enclosure 1 Page 1 of 3 Description and Assessment

1.0 DESCRIPTION

Duke Energy Progress, LLC (Duke Energy) requests adoption of TSTF-566, "Revise Actions for Inoperable RHR Shutdownn Cooling Subsystems," which is an approved change to the Improved Standard Technical Specifications (ISTS), for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Duke Energy has reviewed the safety evaluation for TSTF-566 provided to the Technical Specifications Task Force in a letter dated February 21, 2019. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-566. Duke Energy has concluded that the justifications presented in TSTF-566 and the safety evaluation prepared by the NRC staff are applicable to BSEP, Unit Nos. 1 and 2, and justify this amendment for the incorporation of the changes to the BSEP TS.

2.2 Optional Changes and Variations Duke Energy is proposing the following variation from the TS changes described in TSTF-566.

The BSEP TS use different numbering than the Standard Technical Specifications (STS) on which TSTF-566 was based. Specifically, STS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," is BSEP TS 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," and STS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," is TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." This difference is administrative and does not affect the applicability of TSTF-566 to the BSEP TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Duke Energy Progress, LLC (Duke Energy), requests adoption of TSTF-566, "Revise Actions for Inoperable RHR Shutdownn Cooling Subsystems," which is an approved change to the Improved Standard Technical Specifications (ISTS), for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment revises the TS actions applicable when a residual heat removal (RHR) shutdown cooling subsystem is inoperable.

Duke Energy has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

RA-20-0142 Enclosure 1 Page 2 of 3

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the actions to be taken when an RHR shutdown cooling subsystem is inoperable. The RHR System in the shutdown cooling mode performs the important safety function of removing decay heat from the reactor coolant system during shutdown. The RHR System in the shutdown cooling mode is not an initiator of any accident previously evaluated or assumed to mitigate any accident previously evaluated. The design and function of the RHR System are not affected by the proposed change.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the actions to be taken when an RHR shutdown cooling subsystem is inoperable. The proposed change does not affect the design function or operation of the RHR shutdown cooling subsystems. No new equipment is being installed as a result of the proposed change. The proposed change only affects the actions taken when an RHR shutdown cooling subsystem is inoperable, so no new failure mechanisms are created.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the actions to be taken when an RHR shutdown cooling subsystem is inoperable. The proposed change does not change any specific values or controlling parameters that define margin in the design or licensing basis. No safety limits are affected by the proposed change. The RHR System in the shutdown cooling mode removes decay heat from the reactor coolant system during shutdown. The proposed change does not affect any design or safety limits associated with the RHR System.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

RA-20-0142 Enclosure 1 Page 3 of 3 Based on the above, Duke Energy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

4. ENVIRONMENTAL CONSIDERATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

RA-20-0142 Enclosure 2 Proposed Technical Specification Changes (Mark-Up) -

Unit 1

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 Initiate action to restore Immediately shutdown cooling required RHR shutdown subsystems inoperable. cooling subsystem(s) to OPERABLE status.

AND (continued)

Brunswick Unit 1 3.4-14 Amendment No. 233

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.21 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of decay heat removal is 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 AND A.3 Be in MODE 4.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

CB. No RHR shutdown cooling CB.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 CB.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 CB.3 Monitor reactor coolant Once per hour temperature and pressure.

Brunswick Unit 1 3.4-15 Amendment No. 203

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. 203

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME CB. No RHR shutdown cooling CB.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 CB.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. 276

RA-20-0142 Enclosure 3 Proposed Technical Specification Changes (Mark-Up) -

Unit 2

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 Initiate action to restore Immediately shutdown cooling required RHR shutdown subsystems inoperable. cooling subsystem(s) to OPERABLE status.

AND (continued)

Brunswick Unit 2 3.4-14 Amendment No. 260

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.12 Verify an alternate method 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of decay heat removal is 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 AND A.3 Be in MODE 4.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

CB. No RHR shutdown cooling CB.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 CB.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 CB.3 Monitor reactor coolant Once per hour temperature and pressure.

Brunswick Unit 2 3.4-15 Amendment No. 233

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. 233

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME CB. No RHR shutdown cooling CB.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 CB.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. 304

RA-20-0142 Enclosure 4 Revised Technical Specification Pages - Unit 1

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. 233

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. 233

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. 203

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. 276

RA-20-0142 Enclosure 5 Revised Technical Specification Pages - Unit 2

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. 260

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. 260

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. 233

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. 233

RA-20-0142 Enclosure 6 Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only)

RHR Shutdown Cooling SystemHot Shutdown B 3.4.7 BASES APPLICABILITY condensing the steam in the main condenser. Additionally, in MODE 2 (continued) below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCSOperating") do not allow placing an RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling SystemCold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR)High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR)Low Water Level."

ACTIONS A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1, A.2, and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. Tthe overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided.

With both required RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability. This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

(continued)

Brunswick Unit 1 B 3.4.7-3 Revision No. 41

RHR Shutdown Cooling SystemHot Shutdown B 3.4.7 BASES ACTIONS A.1, A.2, and A.3 (continued)

The required cooling capacity of the alternate method should be sufficient ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods are described in plant procedures and include (but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem.

However, due to the potentially reduced reliability of the alternate methods of decay heat removal, it is also required to reduce the reactor coolant temperature to the point where MODE 4 is entered.

B.1 If the required alternate method(s) of decay heat removal cannot be verified within one hour, immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

CB.1, CB.2, and CB.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by an RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

(continued)

Brunswick Unit 1 B 3.4.7-4 Revision No. 41

RHR Shutdown Cooling SystemCold Shutdown B 3.4.8 BASES ACTIONS A.1 (continued) decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of these alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will provide assurance of continued heat removal capability.

The required cooling capacity of the alternate method should be sufficient ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods are described in plant procedures and include (but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem.

B.1 If the required alternate method(s) of decay heat removal cannot be verified within one hour, immediate action must be taken to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The Required Action will restore redundant decay heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

CB.1 and CB.2 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, and until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by an RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

(continued)

Brunswick Unit 1 B 3.4.8-4 Revision No. 31

RHRHigh Water Level B 3.9.7 BASES ACTIONS A.1 (continued) reduced decay heat removal capability. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of the alternate method must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit operating procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods that can be used include (but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem. The required cooling capacity of the alternate method should be ensured by verifying (by calculation or demonstration) its capability to maintain or reduce temperature. Alternate methods are described in plant procedures. The method used to remove the decay heat should be the most prudent choice based on unit conditions.

B.1, B.2, B.3, and B.4 If no RHR shutdown cooling subsystem is OPERABLE and an alternate method of decay heat removal is not available in accordance with Required Action A.1, actions shall be taken immediately to suspend operations involving an increase in reactor decay heat load by suspending loading of irradiated fuel assemblies into the RPV.

Additional actions are required to minimize any potential fission product release to the environment. This includes ensuring secondary containment is OPERABLE; one standby gas treatment subsystem is OPERABLE; and secondary containment isolation capability is available in each associated penetration flow path not isolated that is assumed to be isolated to mitigate radioactive releases (i.e., one secondary containment isolation damper and associated instrumentation are OPERABLE or other acceptable administrative controls to assure isolation capability. These administrative controls consist of stationing a dedicated operator, who is in continuous communication with the control room, at the controls of the isolation device. In this way, the penetration can be rapidly isolated when a need for secondary containment isolation is indicated). This may be performed as an administrative check, by (continued)

Brunswick Unit 1 B 3.9.7-3 Revision No. 31

RHRLow Water Level B 3.9.8 BASES ACTIONS A.1 (continued) similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, verification of the functional availability of this alternate method(s) must be reconfirmed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. This will ensure continued heat removal capability.

Alternate decay heat removal methods are available to the operators for review and preplanning in the unit operating procedures. The required cooling capacity of the alternate method should be sufficient to maintain or reduce temperature. Decay heat removal by ambient losses can be considered as, or contributing to, the alternate method capability.

Alternate methods that can be used include (but are not limited to) the Spent Fuel Pool Cooling System, the Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem. The required cooling capacity of the alternate methods(s) should be ensured by verifying (by calculation or demonstration) their capacity to maintain or reduce temperature. Alternate methods are described in plant procedures. The method used to remove decay heat should be the most prudent choice based on unit conditions.

B.1, B.2, and B.3 With the required decay heat removal subsystem(s) inoperable and the required alternate method(s) of decay heat removal not available in accordance with Required Action A.1, additional actions are required to minimize any potential fission product release to the environment. This includes ensuring secondary containment is OPERABLE; one standby gas treatment subsystem is OPERABLE; and secondary containment isolation capability is available in each associated penetration flow path not isolated that is assumed to be isolated to mitigate radioactive releases (i.e., one secondary containment isolation damper and associated instrumentation are OPERABLE or other acceptable administrative controls to assure isolation capability. These administrative controls consist of stationing a dedicated operator, who is in continuous communication with the control room, at the controls of the isolation device. In this way, the penetration can be rapidly isolated when a need for secondary containment isolation is indicated). This may be performed as an administrative check, by examining logs or other information to determine whether the components are out of service for maintenance or other reasons. It is not necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the components.

(continued)

Brunswick Unit 1 B 3.9.8-3 Revision No. 31

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

RA-20-0142, Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems

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RA-20-0142, Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems

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Subject:

Enclosures:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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