RA-21-0239, Application to Revise Technical Specifications to Adopt TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling

From kanterella
Jump to navigation Jump to search

Application to Revise Technical Specifications to Adopt TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling
ML21336A716
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 12/02/2021
From: Krakuszeski J
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-21-0239
Download: ML21336A716 (21)
v • d • e


Text

John A. Krakuszeski Vice President Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 December 2, 2021 Serial: RA-21-0239 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-580, Revision 1, "Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling" 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-580, Revision 1, "Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling." The proposed change provides a Technical Specifications (TS) exception to entering Mode 4 if both required Residual Heat Removal (RHR) shutdown cooling subsystems are inoperable.

The Enclosure provides a description and assessment of the proposed changes. Attachments 1 and 2 of the Enclosure provide the existing TS pages marked-up to show the proposed changes for Units 1 and 2, respectively. Attachments 3 and 4 provide revised (clean) TS pages for Units 1 and 2, respectively. Attachment 5 provides the existing Unit 1 TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

Duke Energy requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of completion of the NRCs 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. Lee Grzeck, Manage - Nuclear Fleet Licensing (Acting), at (980) 373-1530.

U.S. Nuclear Regulatory Commission Page 2 of 2 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on 12/02/2021.

Sincerely, John A. Krakuszeski MAT/mat

Enclosure:

Description and Assessment Attachments

1. Proposed Technical Specification Changes (Mark-Up) - Unit 1
2. Proposed Technical Specification Changes (Mark-Up) - Unit 2
3. Revised Technical Specification Pages - Unit 1
4. Revised Technical Specification Pages - Unit 2
5. Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only) cc:

Ms. Laura Dudes, Regional Administrator, Region II Mr. Luke Haeg, Project Manager Mr. Gale Smith, NRC Senior Resident Inspector Chair - North Carolina Utilities Commission Mr. David Crowley, Radioactive Materials Branch Manager, Radiation Protection Section, NC DHHS (david.crowley@dhhs.nc.gov)

RA-21-0239 Enclosure Page 1 of 3 Description and Assessment

1.0 DESCRIPTION

Duke Energy Progress, LLC (Duke Energy) requests adoption of TSTF-580, Revision 1, "Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling." The proposed change provides a Technical Specifications (TS) exception to entering Mode 4 if both required Residual Heat Removal (RHR) shutdown cooling subsystems are inoperable.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Duke Energy has reviewed the safety evaluation for TSTF-580, Revision 1, provided to the Technical Specifications Task Force in a letter dated July 11, 2021. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-580, Revision 1. Duke Energy has concluded that the justifications presented in TSTF-580, Revision 1, 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.

Adoption of TSTF-566-A, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

was approved by the NRC for BSEP on March 18, 2021 (i.e., ADAMS Accession No. ML20309A784).

2.2 Optional Changes and Variations Duke Energy is proposing the following variations from the TS changes described in TSTF-580, Revision 1, or the applicable parts of the NRC staffs Safety Evaluation:

The BSEP TS use different numbering than the Standard Technical Specifications (STS) on which TSTF-580 was based. Specifically, the following difference exists.

This difference is administrative and does not affect the applicability of TSTF-580, Revision 1, 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-580, Revision 1, "Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling." The proposed change provides a Technical Specifications (TS) exception to entering Mode 4 if both required Residual Heat Removal (RHR) shutdown cooling subsystems are 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-21-0239 Enclosure 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 provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are 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.

The proposed change would also exempt entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable and other operating modes of the RHR System are inoperable, such as Low Pressure Coolant Injection (LPCI) and RHR suppression pool cooling, and both subsystems of the support system for the RHR System heat exchangers, the RHR Service Water (RHRSW) System, are inoperable.

The TS for those RHR operating modes and the RHRSW System require entering Mode 4 when both required subsystems are inoperable. Those operating modes and systems are not initiators to any accident previously evaluated but are used to mitigate the consequences of an accident previously evaluated. However, the consequences of an accident previously evaluated resulting from remaining in Mode 3 versus Mode 4 when RHR shutdown cooling subsystems are inoperable are not significantly increased because there would be no dependable method to remove post-accident decay heat in Mode 4 if both required RHR shutdown cooling subsystems are inoperable.

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 provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are inoperable. The proposed change does not affect the design function or operation of the RHR System or the RHRSW System. No new equipment is being installed as a result of the proposed change. The proposed change affects the actions taken when both required RHR shutdown cooling subsystems are 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.

RA-21-0239 Enclosure Page 3 of 3

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

Response: No The proposed change provides a TS exception to entering Mode 4 if both required RHR shutdown cooling subsystems are 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 proposed change applies when both required RHR shutdown cooling subsystems are inoperable, so no design or safety limits associated with the operation of the RHR System are affected.

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

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 A review has determined that the proposed amendment 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 amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 amendment 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 amendment.

RA-21-0239 Enclosure Attachment 1 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 3.4-14 Amendment No. 304

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. Two required RHR C.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter D. Required Action and --------------------NOTE--------------------

associated Completion Time LCO 3.0.3 and all other LCO of Condition C not met. Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore Immediately one RHR shutdown cooling subsystem to OPRABLE status.

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

operation.

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

Brunswick Unit 1 3.4-15 Amendment No. 304

RA-21-0239 Enclosure Attachment 2 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 3.4-14 Amendment No. 332

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. Two required RHR C.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter D. Required Action and --------------------NOTE--------------------

associated Completion Time LCO 3.0.3 and all other LCO of Condition C not met. Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore Immediately one RHR shutdown cooling subsystem to OPRABLE status.

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

operation.

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

Brunswick Unit 2 3.4-15 Amendment No. 332

RA-21-0239 Enclosure Attachment 3 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown cooling of decay heat removal is subsystem inoperable. available. AND Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter B. Required Action and B.1 Initiate Action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem to OPERABLE status.

(continued)

Brunswick Unit 1 3.4-14 Amendment No. 304

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. Two required RHR C.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter D. Required Action and --------------------NOTE--------------------

associated Completion Time LCO 3.0.3 and all other LCO of Condition C not met. Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore Immediately one RHR shutdown cooling subsystem to OPRABLE status.

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

operation.

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

Brunswick Unit 1 3.4-15 Amendment No. 304

RA-21-0239 Enclosure Attachment 4 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 required RHR A.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown cooling of decay heat removal is subsystem inoperable. available. AND Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter B. Required Action and B.1 Initiate Action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem to OPERABLE status.

(continued)

Brunswick Unit 2 3.4-14 Amendment No. 332

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. Two required RHR C.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown cooling of decay heat removal is subsystems inoperable. available for each AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter D. Required Action and --------------------NOTE--------------------

associated Completion Time LCO 3.0.3 and all other LCO of Condition C not met. Required Actions requiring a MODE change to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status.

D.1 Initiate action to restore Immediately one RHR shutdown cooling subsystem to OPRABLE status.

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

operation.

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

Brunswick Unit 2 3.4-15 Amendment No. 332

RA-21-0239 Enclosure Attachment 5 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 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. This will provide assurance of continued heat removal capability.

(continued)

Brunswick Unit 1 B 3.4.7-3 Revision No. 115

RHR Shutdown Cooling SystemHot Shutdown B 3.4.7 BASES ACTIONS A.1 (continued)

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

INCLUDE INSERT 1 HERE EC.1, EC.2, and EC.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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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. 115

INSERT 1 C.1 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. This will provide assurance of continued heat removal capability.

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 Reactor Water Cleanup System, or an inoperable but functional RHR shutdown cooling subsystem.

D.1 If the required alternate methods of decay heat removal cannot be verified within one hour, immediate action must be taken to restore at least one RHR shutdown cooling subsystem to OPERABLE status. The immediate Completion Time reflects the importance of restoring a method of heat removal.

Required Action D.1 is modified by a Note indicating that all required MODE changes to MODE 4 may be suspended until one RHR shutdown cooling subsystem is restored to OPERABLE status. In this case, LCO 3.0.3 and other Required Actions directing entry into MODE 4 could force the unit into a less safe condition in which there may be no adequate means to remove decay heat. It is more appropriate to allow the restoration of one of the RHR shutdown cooling subsystems before requiring entry into a condition in which that subsystem would be needed and exiting a condition where other sources of cooling are available.

When at least one RHR subsystem is restored to OPERABLE status, the Completion Times of LCO 3.0.3 or other Required Actions resume at the point at which they were suspended.

Retrieved from "https://kanterella.com/w/index.php?title=RA-21-0239,_Application_to_Revise_Technical_Specifications_to_Adopt_TSTF-580,_Revision_1,_Provide_Exception_from_Entering_Mode_4_with_No_Operable_RHR_Shutdown_Cooling&oldid=3402801"