BSEP 04-0098, Request for License Amendments Deletion of Hydrogen and Oxygen Analyzer Requirements Consolidated Line Item Improvement Process (TSTF-447, Revision 1)

Request for License Amendments Deletion of Hydrogen and Oxygen Analyzer Requirements Consolidated Line Item Improvement Process (TSTF-447, Revision 1)

ML042180205
Person / Time
Site:	Brunswick
Issue date:	07/26/2004
From:	Gannon C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 04-0098, TSC-2004-01
Download: ML042180205 (33)

Text

Progess uII~!JyCornelius J. Cannon a Progress Energy Vc~e Preside0ntann Brunswick Nuclear Plant JUL 2 6 2004 Progress Energy Carolinas, Inc.

SERIAL: BSEP 04-0098 10 CFR 50.90 TSC-2004-01 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Request for License Amendments Deletion of Hydrogen and Oxygen Analyzer Requirements Consolidated Line Item Improvement Process (TSTF-447, Revision 1)

Reference:

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (i.e., 68 FR 55416)

Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC),

requests a revision to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The proposed license amendments will delete the TS requirements for hydrogen and oxygen analyzers contained in TS Section 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation." The proposed license amendments support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP).

PEC has evaluated the proposed change in accordance with 10 CFR 50.91(a)(1), using the criteria in 10 CFR 50.92(c), and determined that this change involves no significant hazards considerations.

P.O.

Box 10429 Southport, NC 28451 T> 910.457.3698 F> 910.457.2803

Document Control Desk BSEP 04-0098 / Page 2 PEC requests approval of the proposed amendments by October 29, 2004, with the amendments being implemented within 90 days from the date of approval.

In accordance with 10 CFR 50.91(b), PEC is providing the State of North Carolina a copy of the proposed license amendments.

Please refer any questions regarding this submittal to Mr. Edward T. O'Neil, Manager - Support Services, at (910) 457-3512.

Sincerely, J. Gannon MAT/mat

Enclosures:

1. Evaluation of Proposed Amendment Requests

2. Marked-up Technical Specification Pages - Unit 1

3. Typed Technical Specification Pages - Unit 1

4. Typed Technical Specification Pages - Unit 2

5. Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

6. Marked-up Technical Requirements Manual Pages - Unit 1 (For Information Only)

7. List of Regulatory Commitments Cornelius J. Gannon, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power &

Light Company.

Notary(Seal)

My commission expires: 6) =

Document Control Desk BSEP 04-0098 / Page 3 cc:

U. S. Nuclear Regulatory Corniniig§iofi, Region II ATITN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 04-0098 Page 1 of 5 Evaluation of Proposed Amendment Requests

Subject:

Request For License Amendments Deletion of Hydrogen And Oxygen Analyzer Requirements Consolidated Line Item Improvement Process (TSTF-447, Revision 1) 1.0 Introduction This letter is a request to amend Operating Licenses DPR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2.

The proposed license amendments will delete the Technical Specification (TS) requirements for hydrogen and oxygen analyzers contained in TS Section 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation." The proposed license amendments support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision I of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP).

2.0 Description of Proposed Amendment Consistent with TSTF447, Revision 1, the following TS changes are proposed.

Proposed Technical Specification Changes - 112 and 02 Analyzer Deletion Specification Existing Requirement Proposed Requirement TS 3.3.3.1, " PostAccident Monitoring (PANI)

Instrumentation" SR 3.3.3.1.2 Perform CHANNEL (Not Used.)

CALIBRATION of the Drywell and Suppression Chamber H2 and 02 Analyzers TS 3.3.3.1, " Post Accident Monitoring (PAM)

Instrumentation" SR 3.3.3.1.3 Perform CHANNEL Perform CHANNEL CALIBRATION for each required CALIBRATION for each required PAM Instrumentation channel except PAM Instrumentation channel.

for Drywell and Suppression Chamber H2 and 02 Analyzers

BSEP 04-0098 Page 2 of 5 Proposed Technical Specification Changes - 112 and 02 AnalyzerDeietion Specification Existing Requirement Proposed Requirement TS 3.3.3.1, " PostAccident Monitoring (PAM)

Instrumentation" Table 3.3.3.1-1, 'Post Accident

9. Drywell and Suppression

9. (Not Used.)

Monitoring Instntmentation,"

Chamber H2 & 02 Analyzer Function 9 For convenience, Enclosure 2 contains a marked-up version of the Unit 1 TSs showing the proposed changes. Since the TS Section 3.3.3.1 for Unit I and Unit 2 are identical, only the mark-ups of the Unit 1 TSs are provided. Enclosures 3 and 4 provide typed versions of the Unit 1 and Unit 2 TSs, respectively. These TS pages are to be used for issuance of the proposed amendments.

Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc.

(PEC), will make supporting changes to the TS Bases in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program." Enclosure 5 provides marked-up TS Bases pages for Unit 1. These pages are being submitted for information only and do not require issuance by the NRC.

3.0

Background

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (i.e., 68 FR 55416), TSTF447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 Regulatory Requirements and Guidance The applicable regulatory requirements and guidance associated with this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (i.e.,

68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 Technical Analysis PEC has reviewed the safety evaluation (SE) published on September 25, 2003 (i.e., 68 FR 55416), as part of the CLIIP Notice of Availability, as well as the information provided to support TSTF447, Revision 1. Based on this review, PEC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC are applicable to BSEP Units 1 and 2 and justify the incorporation of the changes to the TSs for BSEP Units 1 and 2.

BSEP 04-0098 Enclosure I Page 3 of 5 6.0 Regulatory Analysis A description of this proposed change and its relationship to applicable regulatory requirements and guidance associated with this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (i.e., 68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (i.e., 68 FR 55416), for this TS improvement, PEC is making the following verifications and regulatory commitments.

1.

PEC has verified that a hydrogen monitoring system (i.e., the H2 and 02 Analyzers) capable of diagnosing beyond design-basis accidents is installed at BSEP Units I and 2 and is making a regulatory commitment to maintain that capability. The H2 and 02 Analyzers will be included in the Technical Requirements Manual (TRM) for each unit.

This regulatory commitment will be implemented within 90 days from the date of approval of this amendment.

2.

BSEP Units 1 and 2 have inerted containments. PEC has verified that an oxygen monitoring system (i.e., the H2 and 02 Analyzers) capable of diagnosing beyond design-basis accidents is installed at BSEP Units I and 2 and is making a regulatory commitment to maintain that capability. The H2 and 02 Analyzers will be included in the TRM for each unit. This regulatory commitment will be implemented within 90 days from the date of approval of this amendment. provides marked-up TRM pages for Unit 1, which reflect the changes to be made to implement the above commitments. These pages are being submitted for information only and do not require issuance by the NRC.

7.0 No Significant Hazards Consideration PEC has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (i.e., 68 FR 55416), as part of the CLIIP. PEC has concluded that the proposed determination presented in the notice is applicable to BSEP Units 1 and 2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 Environmental Evaluation PEC has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (i.e., 68 FR 55416), as part of the CLIIP. PEC has concluded that the NRC's findings presented in that evaluation are applicable to BSEP Units 1 and 2 and the evaluation is hereby incorporated by reference for this application.

BSEP 04-0098

• Page 4 of 5 9.0 Precedent This application is being made in accordance with the CLIIP. PEC is not proposing variations or deviations from the TS changes described in TSTF-447, Revision I or the NRC's model SE published on September 25, 2003 (i.e., 68 FR 55416), as part of the CLIIP. However, due to minor differences between the BSEP TSs and the model TSs in NUREG-1433, "Standard Technical Specifications, General Electric Plants BWR/4," Revision 2, certain small variances from the TSTF mark-up changes are necessary. These variances are discussed below and do not affect the no significant hazards consideration determination and environmental evaluation included in the model SE or the adoption and application of TSTF447, Revision 1.

1.

TSTF-447, Revision 1, modifies Standard Technical Specification (STS) 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," by deleting a Note to Condition C, eliminating Condition D, and re-lettering the subsequent Conditions. The BSEP Unit 1 and 2 TSs do not have the Note in Condition C nor is there a need to delete the existing Condition D. Therefore, these changes are not needed to adopt the TSTF.

2.

The BSEP Unit 1 and 2 TSs have a specific surveillance requirement (i.e., SR 3.3.3.1.2) which requires channel calibration of the Drywell and Suppression Chamber H2 and 02 Analyzers on a 92 day frequency. A similar SR, specific to the Drywell and Containment H2 and 02 Analyzers does not exist in NUREG-1433, Revision 1 and, as such, is not reflected in the TSTF-447, Revision 1, markups. Consistent with the intent of removing the H2 and 02 Analyzers from the TSs, the requirements of BSEP SR 3.3.3.1.2 are deleted and replaced with the designation "Not Used."

Associated with the change to BSEP SR 3.3.1.2, BSEP SR 3.3.1.3 currently requires channel calibration of the PAM instrumentation, except for the Drywell and Suppression Chamber H2 and 02 Analyzers, on a 24 month frequency. Reference to the Drywell and Suppression Chamber H2 and 02 Analyzers is deleted from BSEP SR 3.3.1.3.

3.

TSTF447, Revision 1, modifies STS Table 3.3.3.1-1, "Post Accident Monitoring Instrumentation," by deleting Functions 10 and 11, for the Drywell and Containment H2 and 02 Analyzers, respectively. In the BSEP Unit 1 and 2 TSs, these Functions are combined in a single entry (i.e., Function 9, Drywvell and Suppression Chamber H2 and 02 Analyzer). Accordingly, this single function is deleted and replaced with the designation "Not Used."

4.

TSTF-447, Revision 1, modifies STS 5.6.7, "Post Accident Monitoring Report," to reflect the changes discussed in Item 1, above. Since the BSEP Unit 1 and 2 TSs did not require the changes discussed in Item 1, changes to the equivalent BSEP TS 5.6.6 are not required.

10.0 References

1.

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement,

BSEP 04-0098 Page 5 of 5 and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (i.e., 68 FR 55416).

2.

Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," Revision 1.

BSEP 04-0098 Marked-up Technical Specification Pages - Unit 1

PAM Instrumentation 3.3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.A Enter the Condition Immediately associated Completion Time referenced in of Condition C not met.

Table 3.3.3.1-1 for the channel.

E. As required by Required E.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by Required F.1 Initiate action in accordance Immediately Action DA and referenced in with Specification 5.6.6.

Table 3.3.3.1-1.

SURVEILLANCE REQUIREMENTS NOTE These SRs apply to each Function in Table 3.3.3.1-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK.

31 days S R 3.3.3.1.2 C:1 !A? PHE11E)P CALIDtATIeN ft c Dr 1 a &rd 9-~

V P(JI C-VIVID Ghambff aK d Q, Ad B

zerV-,

(continued)

Brunswick Unit 1 3.3-27 Amendment No. 20-3

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.3.1.3 Perform CHANNEL CALIBRATION for each required 24 months PAM Instrumentation channe xeept for &rvw.-IIand I Gupprc3s3in Chamber HZ and

_ Analyzorc.

Brunswick Unit 1 3.3-28 Amendment No. 2

PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REQUIRED FROM REOUIRED FUNCTION CHANNELS ACTION D.1

1.

Reactor Vessel Pressure 2

E

2.

Reactor Vessel Water Level

a.

-t 50 Inches to *IS0 Idces 2

E

b.

Dinchesto*210inches 2

E

c.

150 lnches to *550 nches 2

E

3.

Suppression Chamber Water Level 2

E

4.

Suppression Chamber Water Temperature 2

E

5.

Suppression Chamber Pressure 2

E

6.

DryweIl Pressure 2

E

7.

Drywell Temperature

((AJ tlJ)C 2

E B.

PCIV Position 2 per penetration E

flow path'Xt'

9.

Ii JC Z

tdi n

2."

cgs

10.

Drywett Area Radiation 2

F (a)

Not required for Isolation valves whose associated penetration flow path Is Isodated by at least one dosed and deactivated automatic valve, dosed manual valve, blind flange, or check valve with Ilow through the valve secured.

(b)

Only one position hdication channel Is required for penetration flow paths with only one installed conbrol room indication channel.

Brunswick Unit 1 3.3-29 Amendment No. 2a

BSEP 04-0098 Typed Technical Specification Pages - Unit 1

PAM Instrumentation 3.3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and D.1 Enter the Condition Immediately associated Completion Time referenced in of Condition C not met.

Table 3.3.3.1-1 for the channel.

E. As required by Required E.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action D.1 and referenced in Table 3.3.3.1-1.

F.

As required by Required F.1 Initiate action in accordance Immediately Action D.1 and referenced in with Specification 5.6.6.

Table 3.3.3.1-1.

SURVEILLANCE REQUIREMENTS NOTE --------------------------------------------------------

These SRs apply to each Function in Table 3.3.3.1-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK.

31 days SR 3.3.3.1.2 (Not Used.)

(continued) I Brunswick Unit 1 3.3-27 Amendment No.

I

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.3.1.3 Perform CHANNEL CALIBRATION for each required 24 months PAM Instrumentation channel.

I Brunswick Unit 1 3.3-28 Amendment No.

I

PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page l of t)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REOUIRED FROM REOUIRED FUNCTION CHANNELS ACTION D.1

1.

Reactor Vessel Pressure 2

E

2.

Reactor Vessel Water Level a

-*50inchesto + 50inches 2

E

b.

0 Inches to +21 0 inches 2

E

c.

+t10 inches to +550 Inches 2

E

3.

Suppression Chanber Water Level 2

E

4.

Suppression Chanber Water Terperature 2

E

5.

Suppression Charber Pressure 2

E

6.

Drywall Pressure 2

E

7.

Drywall Tem'perature 2

E

8.

PCIV Position 2 per penetration E

flow path'm

9.

(Not Used.)

10.

Drywall Area Radation 2

F I

(a) Not required for isolation valves whose associated penetration flow path Is Isolated by at least one closed and deactivated autornaic vaive, dosed rmanual valve, blind flange. or check valve with flow through the valve secured.

(b) Only one poSitio indicaon channel I required for penetration flow paths with only one Installed control wornindication channel.

Brunswick Unit 1 3.3-29 Amendment No.

I

BSEP 04-0098 Typed Technical Specification Pages - Unit 2

PAM Instrumentation 3.3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Enter the Condition Immediately associated Completion Time referenced in of Condition C not met.

Table 3.3.3.1-1 for the channel.

E. As required by Required E.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by Required F.1 Initiate action in accordance Immediately Action D.1 and referenced in with Specification 5.6.6.

Table 3.3.3.1 -1.

SURVEILLANCE REQUIREMENTS

---

NOTE ----------------------------------------------------

These SRs apply to each Function in Table 3.3.3.1-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK.

31 days SR 3.3.3.1.2 (Not Used.)

(continued)

I Brunswick Unit 2 3.3-27 Amendment No.

I

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.3.1.3 Perform CHANNEL CALIBRATION for each required 24 months PAM Instrumentation channel.

I Brunswick Unit 2 3.3-28 Amendment No.

I

PAM Instrumentation 3.3.3.1 Table 3.33.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REOUIRED FROM REOUIRED FUNCTION CHANNELS ACTION DA1

1.

Reactor Vessel Pressure 2

E

2.

Reactor Vessel Water Level

a.

• 150Incheslot+150Inches 2

E

b.

0 Inches to +210 Inches 2

E c

+150 Inches to +550 Inches 2

E

3.

Suppression Chanber Water Level 2

E

4.

Suppression Charnber Water Tenperature 2

E

5.

Suppression Chanber Pressure 2

E

6.

Drywall Pressure 2

E

7.

Drywell Terrperature 2

E

8.

PCIV Position 2 per penetration E

llow pahto"bD

9.

(Not Used.)

10. Drywell Area Radiation 2

F I

(a) Not req~ired br solafon vatves whose associated penetration low path I solated by a least one closed and deactvated autornatk valve, closed manual vave blind ltange. or check valve with low through the valve secured.

(b) Only one position indication channel I required for penetration llov paths With onty one Instatted controld omn Indication channel.

Brunswick Unit 2 3.3-29 Amendment No.

I

BSEP 04-0098 Marked-up Technical Specification Bases Pages - Unit 1 (For Information Only)

PAM Instrumentation B 3.3.3.1 BASES LCO

7. Drywell Temperature (continued) by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

8. Primary Containment Isolation Valve (PCIV) Position PCIV position, a Category I variable, is provided for verification of containment integrity. In the case of PCIV position, the important information is the isolation status of the containment penetration. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one active PCIV having control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE.

The PCIV position PAM instrumentation consists of position switches, associated wiring and control room indication for active PCIVs (check valves and manual valves are not required to have position indication).

Therefore, the PAM Specification deals specifically with these instrument channels.

+

Dayv-ll on Gharnber I I3lyuen and 8xvhnam Arairyog)

K Dryvvell atnd skup1p;0ires heambef h

ydeedaE xygeR analyzers i}1 (continued)

Brunswick Unit 1 B 3.3.3.1-6 Revision No.< lI

PAM Instrumentation B 3.3.3.1 f.

BASES LCO 7kDLilvwWUAI al id StivpessiO n CHinsbei I i'verociem andl Hxveiem JAalyfer3S con d) ontainment ch. This variable is also important in ve the dequacy of mitiga ctions. The drywell and sup son chamber ydrogen and oxygen ana rs PAM instwme on consists of two ndependent gas analyzer syste Eac s analyzer system consists of hydrogen analyzer and an oxyge er. The analyzers are capable f determining hydrogen co ration in the ge of 0% to 30% and xygen concentration e range of 0% to 25%.

gas analyzer ystem must be able of sampling the drywell and the ssion hamber.

e are two independent recorders in the contro to is e results. Therefore, the PAM Specification deals specifica w~e

!h ait y

F noaR M rE v

10. Drvwell Area Radiation Drywell area radiation is a Category I variable provided to monitor the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. Post accident drywell area radiation levels are monitored by four instruments, each with a range of 1 R/hr to 1 0 R/hr.

The outputs of these channels are indicated and recorded in the control room. Therefore, the PAM Specification deals specifically with this portion of the instrument channel.

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS Note 1 has been added to the ACTIONS to exclude the MODE change restriction of LCO 3.0.4. This exception allows entry into the applicable MODE while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to (continued)

Brunswick Unit 1 B 3.3.3.1-7 Revision No.

X31

PAM Instrumentation B 3.3.3.1 BASES e-SURVEILLANCE REQUIREMENTS SR 3.3.3.1.1 (continued)

The Frequency of 31 days is based upon plant operating experience, with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31 day interval is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the channels required by the LCO.

I\\j-~ vsect.

S PI.9 -3 S. I. -_111 CHANNEL CALIBRATION to be performed.

/ CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured arameter with the necessary range and accurac, I l

irzn samplor, Gontaining a nominal:\\

a.

Zcro volume perzcnt hydrgen, balance nitrogen;

c.

Twenty We to thirty volume pereeet hydrogen, balance nitrogen; d.~ ~~~J Zef VeVm peAeJ exy

, balane FVV

• 9e n.Swvon to ton volumno percent oxygen, balance Ritrogen; and if Tw~ntt totw We Ycvlaume pereen! exygen, balanieent~e For Function 10, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above.10 Rlhr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.

TL._92....

F~~e~y.f-C 1ANNEL C Al:lnATi of ta f the drywval an cupproccion chambor hydrogon and oxygen analyzer is ba o

operating oxporionco./he 24 month Frequency forCHANNEL (continued)

Brunswick Unit I B 3.3.3.1 -1 I Revision No. a4j

PAM Instrumentation B 3.3.3.1 BASES

./

SURVEILLANCE REQUIREMENTS 2..~

R 3.3.3.1.3 (continued)

CALIBRATION of all other PAM Instrumentation of Table 3.3.3.1-1 is based on operating experience and consistency with the BNP refueling cycles.

REFERENCES

1.

Regulatory Guide 1.97, Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, December 1980.

2.

NRC Safety Evaluation Report, Conformance to Regulatory Guide 1.97, Rev. 2, Brunswick Steam Electric Plant, Units 1 and 2, May 14, 1985.

3.

10 CFR 50.36(c)(2)(ii).

Brunswick Unit 1 B 3.3.3.1-12 Revision No.:av

BSEP 04-0098 Marked-up Technical Requirements Manual Pages - Unit 1 (For Information Only)

Accident Monitoring Instrumentation 3.4 3.4 ACCIDENT MONITORING INSTRUMENTATION TRMS 3.4 The accident monitoring instrumentation for each Function in Table 3.4-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.4-1.

COMPENSATORY MEASURES kI, I Trr-U IM I

r- 's

1.

TRMS 3.0.4 is not applicable.

2.

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED COMPENSATORY COMPLETION TIME MEASURE A.

N NOTE-A.1 Restore required channel to 31 days Only applicable to a;

OPERABLE status.

Functions 1, 2, eldJ One or more Functions with one required channel inoperable.

B.

One or more Functions with B.1 Restore one required 7 days two required channels channel to OPERABLE inoperable.

status.

OR NOTE Only applicable to Functions 4 and 5.

One or more Functions with one required channel inoperable.

(continued)

Brunswick Unit 1 3.4-1 Revision No.@l

Accident Monitoring Instrumentation 3.4 COMPENSATORY MEASURES (continued)

CONDITION REQUIRED COMPENSATORY COMPLETION TIME MEASURE C.

Required Compensatory Measure and associated Completion Time not met.

C.1 Submit a Special Report to the NRC outlining the preplanned alternate monitoring method, the cause of the inoperability, and plans for restoring the instrumentation to OPERABLE status.

14 days 5Lp1 tr US 'ou C& _>

1k; c-'tL °2 wgg~gzes.If_

TEST REQUIREMENTS TEST FREQUENCY TR 3.4.1 Perform CHANNEL CHECK.

A 31 days TR 3.4.2 Perform CHANNEL CALIBRATIO4 l24 months

-7

-rk ? 133

(%,-(ovt" CRIIMA-CSRATIOM r

me 1{

Kd-S&3 t3S qz"-'V%0t2,c 0z f~er

-a _

Brunswick Unit 1 3.4-2 Revision No./l

Accident Monitoring Instrumentation 3.4 FUNCTION Table 3.4-1 (page 1 of 1)

Accident Monitoring Instrumentation APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS

1. Suppression Chamber

1.

Suppression Chamber Atmosphere Temperature

2.

Drywell Radiation

3.

Safety/Relief Valve Position Indication

a.

Primary-Sonic

b.

Secondary-Temperature

4.

Turbine Building Ventilation Monitor(a)

5.

Offgas Stack Ventilation Monitor(a) 1,2 1,2,3 1,2 2

2 2 per valve 1,2,3 1

1,2,3 1

(a) High range noble gas monitors.

bowQ WC d a,.d gff i 'A Caugh I "ea @

AY4zrdv l, _

Brunswick Unit 1 3.4-3 Revision No.2I

Accident Monitoring Instrumentation B 3.4 B 3.4 ACCIDENT MONITORING INSTRUMENTATION BASES The OPERABILITY of the post-accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess important variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident,". December 1975, and NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations."

Brunswick Unit 1 Revision No.,'I B 3.4-1

TRM Appendix B TS Instrument List TRM Table 3 3.3 t-l (page l ot 1)

Post Accident Monitoring Instrurnentation TECHNICAL SPECIFICATION FUNCTION APPLICABLE INSTRUMENT NUMBER(S)

1.

Reactor Vessel Pressure 2-Reactor Vessel Water Level

a.

• 50 Inches to +150 inches

b.

0 inches to +210 inches C.

+150 Inches to.550 inches

3.

Suppression Chanmber Water Level A

Suppression Chanter Water Trnperature

5.

Suppression Chanber Pressure

6.

Drywell Pressure

7.

Drywell Tenperature 8

PCtV Position

(

A _.e(

821-Pt-R605A, B B21-LI-R610. B21-LR-R615 B21-L-RUM4A. 8 821-L-R605A, B CAC-U-2601-1. CAC-LR-2602 CAC-TR-4426-1A CAC-TR-4426-2A CAC-TY4426-1. 2 CAC-PI-1257-2A, B CAC-Pt-4176, CAC-PR-1257-1 CAC-TR-4426-1A, B CAC-TRP4426-2A, B CAC-TY4426-1. 2 See TRM Table 3.3.3.1-2, Pdn ary Containmnent Isolafion Valve Position Inrdicalion.

.^~~~~

o o^. -s iWPo......

-J 10 Drywelt Area Rariation D22-RI-4 195, D22-RI-4 196, D22-Ri-197. D22-RI-4 198.

D22-RR-4195, 022-RR-4197 Brunswick Unit 1 B-7 Revision No.4,j

TRM Appendix C TRM Instrument List TRM Table 3 4-2 (page t o 1)

Accident Monitoring Instrunenlatior APPtlCABLE INSTRUMENT NUMBER(S)

TRM FUNCTION

1.

Suppression Chamber Atmosphere Temperature

2.

Dfywen Radiation 3

Salety/Reliet Valve Position Indcation a

Prinary-SoniC

b.

Secondary-Ternperature

4.

Turbine Building Ventilation Monitorm

5.

Oltgas Stack Ventilation MonitorW CAC-TE-1258-17 or 18 CAC-TY-4426-1 CAC-TR-4426-1A-5 or IA-4 CAC-TE-1258-19 or 20 CAC-TY*4426-2 CAC-TR-4426-2A-5 or 2A-6 CAC-AR-1260 CAC-AOH-126MI. 2,3 CAC-AM-1262 CAC-AOH-1262-1, 2.3 821-FY-4157 Thru 4167 B21-TR-R614 Points I Thtu 1t D12-RE-4561. D12-RE-4562 D12-RR-4548-2. D12-RR.A548-1 D12-RE-4573. D12-RE-4574 D12-RR-4599-2. D12-RR-4599-1 Revision No.l'I Brunswick Unit 1 C-3

BSEP 04-0098 Page 1 of 1 List Of Regulatory Commitments The following table identifies those actions committed to by Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to the Manager - Support Services at the Brunswick Steam Electric Plant (BSEP).

Commitment

--, Schedule:

1. PEC has verified that a hydrogen monitoring system (i.e., the H2 90 days from the and 02 Analyzers) capable of diagnosing beyond design-basis date of approval of accidents is installed at BSEP Units 1 and 2 and is making a this amendment.

regulatory commitment to maintain that capability. The H2 and 02 Analyzers will be included in the Technical Requirements Manual (TRM) for each unit.

2.

PEC has verified that an oxygen monitoring system (i.e., the H2 90 days from the and 02 Analyzers) capable of diagnosing beyond design-basis date of approval of accidents is installed at BSEP Units 1 and 2 and is making a this amendment.

regulatory commitment to maintain that capability. The H2 and 02 Analyzers will be included in the TRM for each unit.