View source for RA-18-0234, (Bsep), Unit Nos. 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-269, Allow Administrative Means of Position Verification for Locked or Sealed Valves.

{{Adams
| number = ML18353A951
| issue date = 12/14/2018
| title = (Bsep), Unit Nos. 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-269, Allow Administrative Means of Position Verification for Locked or Sealed Valves.
| author name = Gideon W
| author affiliation = Duke Energy Progress, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person = 
| case reference number = RA-18-0234
| document type = Letter type:RA, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 28
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 December 14, 2018 Serial: RA-18-0234                                                                    10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
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 Application to Revise Technical Specifications to Adopt TSTF-269, "Allow Administrative Means of Position Verification for Locked or Sealed Valves 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 (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed change, consistent with the NRC-approved Technical Specification Task Force Traveler 269 (i.e., TSTF-269-A, Revision 2), modifies requirements for repetitive verification of the status of locked, sealed, or secured components to allow the verification to be by administrative means.
The Enclosure to this letter provides a description and assessment of the proposed change.
Unit 1 and 2 TS Mark-Ups are provided in Enclosure Attachments 1 and 2, respectively. The revised (i.e., typed) Unit 1 and 2 TS pages are included as Enclosure Attachments 3 and 4, respectively. In addition, Unit 1 TS Bases Mark-Ups, directly related to the proposed change, are provided in Attachment 5 for information.
Approval of the proposed amendment is requested one year from completion of the NRC 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 regulatory commitments.
Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.

U.S. Nuclear Regulatory Commission Page 2 of 3 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on December 14, 2018.
William R. Gideon SBY/sby

==Enclosure:==

Description and Assessment of the Proposed Change Attachment 1. Unit 1 Technical Specifications - Mark-Ups Attachment 2. Unit 2 Technical Specifications - Mark-Ups Attachment 3. Unit 1 Technical Specifications - Revised Pages Attachment 4. Unit 2 Technical Specifications - Revised Pages Attachment 5. Unit 1 Technical Specification Bases - Mark-Ups (For Information Only)

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with Enclosure):
U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Dennis J. Galvin (Mail Stop OWFN 8B1A) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)
Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

RA-18-0234 Enclosure Page 1 of 5 Description and Assessment of the Proposed Change

==Subject:==
Application to Revise Technical Specifications to Adopt TSTF-269, "Allow Administrative Means of Position Verification for Locked or Sealed Valves 1.0    

==SUMMARY==
DESCRIPTION 2.0    DETAILED DESCRIPTION 2.1   Description of Proposed Change 2.2   Description of Variances

==3.0    TECHNICAL EVALUATION==

==4.0    REGULATORY EVALUATION==

4.1   Applicable Regulatory Requirements/Criteria 4.2   Precedent 4.3   No Significant Hazards Consideration Determination Analysis 4.4   Conclusions

==5.0    ENVIRONMENTAL CONSIDERATION==

==6.0    REFERENCES==

ATTACHMENTS:
: 1. Unit 1 Technical Specifications - Mark-Ups
: 2. Unit 2 Technical Specifications - Mark-Ups
: 3. Unit 1 Technical Specifications - Revised Pages
: 4. Unit 2 Technical Specifications - Revised Pages
: 5. Unit 1 Technical Specification Bases - Mark-Ups (For Information Only)

RA-18-0234 Enclosure Page 2 of 5 1.0     Summary Description Duke Energy Progress, LLC (Duke Energy), is requesting a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendments, consistent with the NRC-approved Technical Specification Task Force Traveler (TSTF) 269, Revision 2 (i.e., Reference 6.1), modify requirements for repetitive verification of the status of locked, sealed, or secured components to allow the verification to be by administrative means. TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves was approved by the NRC on July 26, 1999.
2.0     Detailed Description 2.1     Description of Proposed Change The proposed change modifies Technical Specification (TS) 3.6.1.3, Primary Containment Isolation Valves (PCIVs), and TS 3.6.4.2, Secondary Containment Isolation Dampers (SCIDs). These specifications require penetration flow paths with inoperable isolation devices be isolated and periodically verified to be isolated. Consistent with TSTF-269-A, Revision 2, notes are proposed to be added to TS 3.6.1.3, Required Actions A.2 and C.2, and TS 3.6.4.2, Required Action A.2, to allow isolation devices that are locked, sealed, or otherwise secured to be verified using administrative means.
Unit 1 and Unit 2 TS Mark-Ups are provided in Attachments 1 and 2 respectively; Attachments 3 and 4 provide the revised, typed TS pages. In addition, Unit 1 TS Bases Mark-Ups directly related to the proposed change are provided in Attachment 5 for information.
2.2     Description of Variances TSTF-269 also modified Specification 3.6.1.3, Required Action E.2, which is optional in the Standard BWR/4 Technical Specifications (i.e., Reference 6.2). The equivalent of Condition E does not appear in the BSEP TSs. This variation does not affect the applicability of TSTF-269 to the proposed license amendments.
3.0     Technical Evaluation The purpose of the periodic verification that a penetration with an inoperable isolation valve continues to be isolated is to detect and correct inadvertent repositioning of the isolation device.
However, the function of locking, sealing, or securing an isolation device is to ensure that the device is not inadvertently repositioned. Therefore, it is sufficient to assume that the initial establishment of component status (e.g., isolation valves closed) was performed correctly and subsequent periodic re-verification need only be a verification of the administrative control that ensures that the component remains in the required state. It is unnecessary and undesirable to remove the lock, seal, or other means of securing the component solely to perform an active verification of the required state as it would increase the chance of mispositioning due to the frequent manipulation.

RA-18-0234 Enclosure Page 3 of 5 4.0      Regulatory Analysis 4.1      Applicable Regulatory Requirements/Criteria The regulations of Title 10 of the Code of Federal Regulations (10 CFR), Technical Specifications, establish the requirements related to the content of the TSs. Section 50.36(c)(2) states:
When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
There is no regulatory requirement that specifies what remedial actions are to be taken when a limiting condition for operation is not met. The proposed changes remove an operational restriction not needed for safety. The proposed changes are consistent with the Standard BWR/4 Technical Specifications (i.e., Reference 6.2).
4.2      Precedent An example of a plant-specific NRC approval of the changes in TSTF-269-A, Revision 2, is McGuire Nuclear Station, Units 1 and 2, Amendment Numbers 298/277, dated September 18, 2017 (ADAMS Accession No. ML17240A354).
4.3      No Significant Hazards Consideration Analysis Duke Energy Progress, LLC (Duke Energy), is requesting a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendments, consistent with the NRC-approved Technical Specification Task Force Traveler (TSTF) 269, Revision 2 (i.e., Reference 6.1), modify requirements for repetitive verification of the status of locked, sealed, or secured components to allow the verification to be by administrative means. TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves was approved by the NRC on July 26, 1999.
Duke Energy has evaluated whether 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:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response:       No The proposed change modifies Technical Specification (TS) 3.6.1.3, Primary Containment Isolation Valves (PCIVs) and TS 3.6.4.2, Secondary Containment Isolation Dampers (SCIDs). These specifications require penetration flow paths with inoperable isolation devices be isolated and periodically verified to be isolated.
Consistent with TSTF-269-A, Revision 2, notes are proposed to be added to TS 3.6.1.3, Required Actions A.2 and C.2, and TS 3.6.4.2, Required Action A.2, to allow isolation devices that are locked, sealed, or otherwise secured to be verified using administrative means.

RA-18-0234 Enclosure Page 4 of 5 The proposed change does not affect any plant equipment, test methods, or plant operation, and is not an initiator of any analyzed accident sequence. The inoperable containment penetrations will continue to be isolated, and hence perform their isolation function. Operation in accordance with the proposed TSs will ensure that all analyzed accidents will continue to be mitigated as previously analyzed.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response:       No The proposed change does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. Furthermore, the change does not alter the assumptions made in the safety analysis. 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 change involve a significant reduction in a margin of safety?
Response:       No The proposed change will not affect operation of plant equipment or the function of any equipment assumed in the accident analysis. Affected containment penetrations will continue to be isolated as required by the existing TSs. Therefore, the proposed change does not involve a significant reduction in safety margin.
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.
4.4      Conclusions In conclusion, based on the discussion 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 NRC 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.
5.0      Environmental Consideration The proposed change would alter 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,

RA-18-0234 Enclosure Page 5 of 5 pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
6.0   References 6.1   TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves.
6.2   NUREG-1433, Revision 4, Standard Technical Specifications General Electric Plants, BWR/4, dated April 2012.

RA-18-0234 Enclosure Attachment 1 Unit 1 Technical Specifications - Mark-Ups

NOTES 1.
: 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

NOTES 1.
: 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

NOTES 1.
: 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

RA-18-0234 Enclosure Attachment 2 Unit 2 Technical Specifications - Mark-Ups

NOTES 1.
: 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

NOTES 1.
: 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

NOTES 1.
: 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

RA-18-0234 Enclosure Attachment 3 Unit 1 Technical Specifications - Revised Pages

PCIVs 3.6.1.3 ACTIONS CONDITION     REQUIRED ACTION                      COMPLETION 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.
Verify the affected                 Once per 31 days penetration flow path is            for isolation devices isolated.                           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. 203

PCIVs 3.6.1.3 ACTIONS (continued)
CONDITION                         REQUIRED ACTION                      COMPLETION TIME B.  --------------NOTE--------------     B.1  Isolate the affected                2 hours 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 hours 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 valve,         AND or blind flange.
One or more penetration                                                       12 hours 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.
Verify the affected                 Once per 31 days penetration flow path is isolated.
(continued)
Brunswick Unit 1                                3.6-9                              Amendment No. 203

SCIDs 3.6.4.2 ACTIONS CONDITION                        REQUIRED ACTION                      COMPLETION 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.
Verify the affected                 Once per 92 days penetration flow path is isolated.
B.  --------------NOTE---------------    B.1  Isolate the affected                4 hours Only applicable to                        penetration flow path by penetration flow paths with               use of at least one closed two isolation dampers.                    and de-activated automatic
    ------------------------------------      damper, closed manual damper, or blind flange.
One or more penetration flow paths with two SCIDs inoperable.
C. Required Action and                  C.1  Be in MODE 3.                       12 hours associated Completion Time of Condition A or B not met          AND in MODE 1, 2, or 3.
C.2  Be in MODE 4.                       36 hours (continued)
Brunswick Unit 1                              3.6-31                               Amendment No. 252

RA-18-0234 Enclosure Attachment 4 Unit 2 Technical Specifications - Revised Pages

PCIVs 3.6.1.3 ACTIONS CONDITION     REQUIRED ACTION                      COMPLETION 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.
Verify the affected                 Once per 31 days penetration flow path is            for isolation devices isolated.                           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. 233

PCIVs 3.6.1.3 ACTIONS (continued)
CONDITION                         REQUIRED ACTION                      COMPLETION TIME B.  --------------NOTE--------------     B.1  Isolate the affected                2 hours 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 hours 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 valve,         AND or blind flange.
One or more penetration                                                       12 hours 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.
Verify the affected                 Once per 31 days penetration flow path is isolated.
(continued)
Brunswick Unit 2                                3.6-9                              Amendment No. 233

SCIDs 3.6.4.2 ACTIONS CONDITION                          REQUIRED ACTION                      COMPLETION 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.
Verify the affected                 Once per 92 days penetration flow path is isolated.
B.  -------------NOTE----------------- B.1      Isolate the affected                4 hours Only applicable to                          penetration flow path by penetration flow paths with                 use of at least one closed two isolation dampers.                      and de-activated automatic
    --------------------------------------      damper, closed manual damper, or blind flange.
One or more penetration flow paths with two SCIDs inoperable.
C. Required Action and                    C.1  Be in MODE 3.                       12 hours associated Completion Time of Condition A or B not met            AND in MODE 1, 2, or 3.
C.2  Be in MODE 4.                       36 hours (continued)
Brunswick Unit 2                                3.6-31                               Amendment No. 280

RA-18-0234 Enclosure Attachment 5 Unit 1 Technical Specification Bases - Mark-Ups (For Information Only)

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