View source for RA-20-0127, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2

{{Adams
| number = ML20209A551
| issue date = 07/27/2020
| title = Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2
| author name = Krakuszeski J
| 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-20-0127
| document type = Letter type:RA, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 16
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:John A. Krakuszeski Vice President Brunswick Nuclear Plant 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 July 27, 2020 Serial: RA-20-0127                                                                  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-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2" 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-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." Technical Specifications Task Force (TSTF) Traveler TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.2, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content. The TSTF-568 proposed change to TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," in TSTF-568 is not applicable to BSEP and is not included. 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. provides Unit No. 1 TS Bases pages marked-up to show the proposed changes 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. 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 27, 2020.
Sincerely, 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-20-0127 Enclosure 1 Page 1 of 3 Description and Assessment

==1.0    DESCRIPTION==

Duke Energy Progress, LLC (Duke Energy) requests adoption of TSTF-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.2, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.
2.0    ASSESSMENT 2.1    Applicability of Safety Evaluation Duke Energy has reviewed the safety evaluation for TSTF-568 provided to the Technical Specifications Task Force in a {{letter dated|date=December 17, 2019|text=letter dated December 17, 2019}}. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-568. Duke Energy has concluded that the justifications presented in TSTF-568 and the safety evaluation prepared by the NRC staff are applicable to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2; and justify this amendment for the incorporation of the changes to BSEP TS 3.6.3.2.
2.2    Optional Changes and Variations Duke Energy is proposing the following variations from the TS changes described in TSTF-568 or the applicable parts of the NRC staff's safety evaluation.
The proposed change to TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," in TSTF-568 is not applicable to BSEP and is not included.
The BSEP TS use different numbering than the STS on which TSTF-568 was based.
Specifically, STS 3.6.3.2, "Primary Containment Oxygen Concentration," is BSEP TS 3.6.3.1, "Primary Containment Oxygen Concentration." This difference is administrative and does not affect the applicability of TSTF-568 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-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.
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-20-0127 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 Applicability and Actions of TS 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. Primary containment oxygen concentration is not an initiator to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not affected by the proposed change.
Primary containment oxygen concentration is assumed in the mitigation of some accidents previously evaluated. The Applicability of TS 3.6.3.1 is changed from Mode 1 when thermal power is greater than 15% to Modes 1 and 2. This expands the Applicability of the TS and will not have an effect on the consequences of an accident. The existing Applicability exceptions are removed and replaced with a longer Completion Time of 72 hours. The consequences of an event that could be affected by primary containment oxygen concentration are no different during the proposed Completion Times than the consequences of the same event during the existing Completion Times. A note referencing Limiting Condition for Operation (LCO) 3.0.4.c is added to the Actions to permit entering the Applicability with the LCO not met. The note replaces the existing Applicability exceptions. This change is administrative and has no effect on the consequences of an accident.
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 Applicability and Actions of TS 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators that would have been considered a design basis accident in the Updated Final Safety Analysis Report (UFSAR) are created because the Nuclear Regulatory Commission has determined that hydrogen generation is not risk significant for design basis accidents.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

RA-20-0127 Enclosure 1 Page 3 of 3
: 3.       Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. No safety limits are affected. No Limiting Conditions for Operation or Surveillance limits are affected.
The primary containment oxygen concentration TS requirements assure sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety.
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 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-20-0127 Enclosure 2 Proposed Technical Specification Changes (Mark-Up) -
Unit 1

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1      Primary Containment Oxygen Concentration LCO 3.6.3.1           The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:        MODES 1 and 2. during the time period:
: a. From 24 hours after THERMAL POWER is > 15% RTP following startup, to
: b. 24 hours prior to a scheduled reduction of THERMAL POWER to
                           < 15% RTP.
ACTIONS COMPLETION CONDITION                         REQUIRED ACTION                              TIME A. Primary containment oxygen A.1             -------------NOTE--------------     24 72 hours concentration not within                   LCO 3.0.4.c is applicable.
limit.                                     -----------------------------------
Restore oxygen concentration to within limit.
B. Required Action and              B.1       Be in MODE 3.Reduce                 8 12 hours associated Completion Time                 THERMAL POWER to not met.                                    15% RTP.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                             FREQUENCY SR 3.6.3.1.1        Verify primary containment oxygen concentration is               In accordance with within limits.                                                   the Surveillance Frequency Control Program Brunswick Unit 1                               3.6-26                                Amendment No. 276

RA-20-0127 Enclosure 3 Proposed Technical Specification Changes (Mark-Up) -
Unit 2

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1      Primary Containment Oxygen Concentration LCO 3.6.3.1           The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:        MODES 1 and 2.during the time period:
: a. From 24 hours after THERMAL POWER is > 15% RTP following startup, to
: b. 24 hours prior to a scheduled reduction of THERMAL POWER to
                           < 15% RTP.
ACTIONS COMPLETION CONDITION                         REQUIRED ACTION                              TIME A. Primary containment oxygen A.1             -------------NOTE--------------     24 72 hours concentration not within                   LCO 3.0.4.c is applicable.
limit.                                     -----------------------------------
Restore oxygen concentration to within limit.
B. Required Action and              B.1       Be in MODE 3.Reduce                 8 12 hours associated Completion Time                 THERMAL POWER to not met.                                    15% RTP.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                             FREQUENCY SR 3.6.3.1.1        Verify primary containment oxygen concentration is               In accordance with within limits.                                                   the Surveillance Frequency Control Program Brunswick Unit 2                               3.6-26                                Amendment No. 304

RA-20-0127 Enclosure 4 Revised Technical Specification Pages - Unit 1

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1      Primary Containment Oxygen Concentration LCO 3.6.3.1           The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:        MODES 1 and 2.
ACTIONS COMPLETION CONDITION                       REQUIRED ACTION                              TIME A. Primary containment oxygen A.1           -------------NOTE--------------     72 hours concentration not within                 LCO 3.0.4.c is applicable.
limit.                                   -----------------------------------
Restore oxygen concentration to within limit.
B. Required Action and             B.1      Be in MODE 3.                       12 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                           FREQUENCY SR 3.6.3.1.1        Verify primary containment oxygen concentration is             In accordance with within limits.                                                 the Surveillance Frequency Control Program Brunswick Unit 1                             3.6-26                                Amendment No. 276

RA-20-0127 Enclosure 5 Revised Technical Specification Pages - Unit 2

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1      Primary Containment Oxygen Concentration LCO 3.6.3.1           The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:        MODES 1 and 2.
ACTIONS COMPLETION CONDITION                       REQUIRED ACTION                              TIME A. Primary containment oxygen A.1           -------------NOTE--------------     72 hours concentration not within                 LCO 3.0.4.c is applicable.
limit.                                   -----------------------------------
Restore oxygen concentration to within limit.
B. Required Action and             B.1      Be in MODE 3.                       12 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                           FREQUENCY SR 3.6.3.1.1        Verify primary containment oxygen concentration is             In accordance with within limits.                                                 the Surveillance Frequency Control Program Brunswick Unit 2                             3.6-26                                Amendment No. 304

RA-20-0127 Enclosure 6 Proposed Technical Specification Bases Changes (Mark-Up) - Unit 1 (For Information Only)

Primary Containment Oxygen Concentration B 3.6.3.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1  Primary Containment Oxygen Concentration BASES BACKGROUND          The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration < 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration.
For example, an event that rapidly generates hydrogen from zirconium metal water reaction could result in excessive hydrogen in primary containment, but oxygen concentration will remain < 5.0 v/o and no combustion can occur. This LCO ensures that oxygen concentration does not exceed 4.0 v/o during operation in the applicable conditions.
APPLICABLE          The Reference 1 calculations assume that the primary containment is SAFETY ANALYSES inerted when a Design Basis Accident (DBA) loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment.
Primary containment oxygen concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 2).
LCO                 The primary containment oxygen concentration is maintained < 4.0 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.
APPLICABILITY       The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODES 1 and 2, since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.
Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus.
Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible during a scheduled power reduction to  15% RTP. As long as reactor power is  15% RTP, the potential for an event that generates significant hydrogen and oxygen the potential for an event that generates significant hydrogen and oxygen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first (continued)
Brunswick Unit 1                          B 3.6.3.1-1                            Revision No. 66

Primary Containment Oxygen Concentration B 3.6.3.1 BASES APPLICABILITY    24 hours of a startup, or within the last 24 hours before a scheduled (continued)     power reduction  15% RTP, is low enough that these "windows," when the primary containment is not inerted, are also justified. The 24 hour time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.
ACTIONS          A.1 If oxygen concentration is  4.0 v/o at any time while operating in MODE 1 or 2, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 72 24 hours. The 72 24 hour Completion Time is allowed when oxygen concentration is  4.0 v/o because of the availability of other hydrogen and oxygen mitigating systems and the low probability and long duration of an event that would generate significant amounts of hydrogen and oxygen occurring during this period.
A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.
This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus.
Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Modes 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.
B.1 If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, power must be reduced to MODE 3  15% RTP within 12 8 hours. The 12 8 hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE     SR 3.6.3.1.1 REQUIREMENTS The primary containment must be determined to be inerted by verifying that oxygen concentration is < 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES       1.      UFSAR, Section 6.2.5.
: 2.      10 CFR 50.36(c)(2)(ii).
Brunswick Unit 1                       B 3.6.3.1-2                            Revision No. 94}}