RA-22-0110, Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - Ritstf.

Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - Ritstf.

ML22084A620
Person / Time
Site:	Brunswick
Issue date:	03/25/2022
From:	Krakuszeski J Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-22-0110
Download: ML22084A620 (7)

Text

r.. DUKE John A. Krakuszeski Vice President

• ~ ENERGY Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 March 25, 2022 Serial: RA-22-0110 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:

Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b Ladies and Gentlemen:

By letter dated April 1, 2021 (ADAMS Accession No. ML21091A053), as supplemented by letters dated April 26,2021 and November 1, 2021 (ADAMS Accession Nos. ML21116A161 and ML21305A891, respectively), Duke Energy Progress, LLC (Duke Energy) requested an amendment to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Technical Specifications (TS). The proposed amendment would modify TS requirements to permit the use of Risk-Informed Completion Times in accordance with TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b, (ADAMS Accession No. ML18183A493).

In Attachments 1 and 2 of the November 1, 2021, supplement Duke Energy inadvertently omitted a portion of the markup for TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs) to align with TSTF-505, Revision 2. Specifically, BSEP TS 3.6.1.3 has the requirement to isolate the affected penetration flow path when one or more penetration flow paths with one PCIV inoperable. This is followed by the requirement to periodically verify the affected penetration flow path is isolated. By adding the flexibility to use a Risk-Informed Completion Time (RICT) to determine the time to isolate the penetration, the periodic verification must then be based on the time following isolation. Therefore, the enclosure to this letter revises the TS 3.6.1.3 markup to account for the time change caused by RICT implementation. The markup of all other TS provided in the November 1, 2021 supplement remain valid.

Duke Energy has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in the original license amendment request (LAR). The additional information provided in this LAR supplement does not impact the conclusion that the proposed license amendment does not involve a significant hazards consideration. The additional information also does not impact the conclusion that there is no need for an environmental assessment to be prepared in support of the proposed amendment.

There are no regulatory commitments made in this submittal.

U.S. Nuclear Regulatory Commission RA-22-0110 In accordance with 10 CFR 50.91, Duke Energy is notifying the State of North Carolina of the supplement to this LAR by transmitting a copy of this letter and enclosure to the designated State Official.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Nuclear Fleet Licensing (Acting), at (980) 373-1530.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on March 25, 2022.

Sincerely, John A. Krakuszeski JLV/jlv

Enclosure:

Markup of Technical Specification 3.6.1.3 for Primary Containment Isolation Valves 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

U.S. Nuclear Regulatory Commission RA-22-0110 ENCLOSURE MARKUP OF TECHNICAL SPECIFICATION 3.6.1.3 FOR PRIMARY CONTAINMENT ISOLATION VALVES

PCIVs 3.6.1.3 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 ------------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means. following isolation Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)

Brunswick Unit 1 3.6-8 Amendment No. 296

PCIVs 3.6.1.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. --------------NOTE-------------- B.1 Isolate the affected 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two PCIVs. and de-activated automatic

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valve, closed manual valve, or blind flange.

One or more penetration flow paths with two PCIVs inoperable except for MSIV leakage not within limit.

C. --------------NOTE-------------- C.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one closed valves (EFCVs) only one PCIV. and de-activated automatic

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valve, closed manual valve, AND or blind flange.

One or more penetration 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for EFCVs flow paths with one PCIV inoperable.

AND C.2 ------------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means. following isolation Verify the affected Once per 31 days penetration flow path is isolated.

(continued)

Brunswick Unit 1 3.6-9 Amendment No. 296

PCIVs 3.6.1.3 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. (continued) A.2 ------------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative following isolation means.

Verify the affected Once per 31 days penetration flow path is for isolation isolated. devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)

Brunswick Unit 2 3.6-8 Amendment No. 324

PCIVs 3.6.1.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. --------------NOTE-------------- B.1 Isolate the affected 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Only applicable to penetration flow path by penetration flow paths with use of at least one closed two PCIVs. and de-activated automatic

---

valve, closed manual valve, or blind flange.

One or more penetration flow paths with two PCIVs inoperable except for MSIV leakage not within limit.

C. --------------NOTE-------------- C.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one closed valves (EFCVs) only one PCIV. and de-activated automatic

---

valve, closed manual AND valve, or blind flange.

One or more penetration 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for flow paths with one PCIV AND EFCVs inoperable.

C.2 ------------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative following isolation means.

Verify the affected Once per 31 days penetration flow path is isolated.

(continued)

Brunswick Unit 2 3.6-9 Amendment No. 324