ML20207B892

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Application for Amend to License DPR-71,incorporating Operating Limits for Cycle 7 Operation of Unit 1.Fee Paid
ML20207B892
Person / Time
Site: Brunswick Duke Energy icon.png
Issue date: 08/01/1988
From: Eury L
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML19292J182 List:
References
S-S-88-158, NUDOCS 8808040327
Download: ML20207B892 (33)
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Text

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coronne power a usht company P. O. Bos 1551

  • Ralegh. N. C. 27602 AUG 1 m LYNN W. EURY SERIAL: NLS-88-158 senior vwe er,skrent 10CFR50.90 OM'ations somrt 88TSB06 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PIANT, UNIT NO. 1 DOCKET NO. 50 325 / LICENSE NO DPR-71 REQUEST FOR LICENSE AMENDMENT FUEL CYCLE NO. 7--RELOAD LICENSING Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Technical Specifications (TS) for the Brunswick Steam Electric Plant, Unit 1 (BSEP-1). The purpose of this amendment is to incorporate operating limits for Cycle ~/ (Reload 6) operation of BSEP-1.

This submittal provides proposed cycle specific revisions to the TS to reflect the reload requirements for BSEP 1, Cycle 7 operation. By separate submittal, dated September 4, 1987, the Company proposed a request for license amendment which would remove cycle specific reload requirements from the TS. Issuance of one of these two requests is needed by December 16, 1988 to support start-up of BSEP-1 from the upcoming refueling outage. If the request for removing cycle specific reload requirements is issued prior to this date, the Company will submit a letter to withdraw the BSEP 1, Cycle 7 reload request.

Enclosure 1 provides a detailed description of the proposed changes, the basis for the changes, and the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 2 provides instructions for incorporation of the proposed changes into the Technical Specifications for BSEP-1.

Enclosure 3 provides a summary of the proposed Technical Specification changes for BSEP-1 on a page by page basis.

Enclosure 4 provides the proposed Technical Specification pages for BSEP-1.

Enclosure 5 provides a copy of the Supplemental Reload Licensing Report for BSEP-1, Cycle 7.

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Enclosure 6 provides a copy of NEDE 24165-P, "Loss Of-Coolant Accident T3 Analysis Report for BSEP-1." (Proprietary) ,l CH O CG IxR ENCL. (4 gtSO 8808040327 880801 5 4-#M J/V/ W#

DR ADOCK 0500 WSic.

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-Documsnt Control Dask NLS-88-158 /~Page 2 Enclosure 7 provides a copy of the General Electric (GE) affidavit for the NEDE-24165-P report.

The information contained in Enclosure 6 is considered to be proprietary.

An affidavit signed by GE, owner. of the information,' is provided as Enclosure 7 to this submittal. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission in accordance with 10CFR2.790(b)(1).

In accordance with the requirements of 10CFR170.12, a check for $150 is also enclosed.

Please refer any questions regarding this submittal to Mr. Stephen D. Floyd at (919) 836-6901.

Yours very truly,

-V j

& WW L. W. Eury AWS/aws

Enclosures:

1. Basis for Change Request
2. Instructions for Incorporation
3. Summary List of Revisions
4. Technical Specification Pages
5. Supplemental Reload Licensing Report .
6. Loss-Of-Coolant Accident Analysis Report
7. GE Affidavit ec: Mr. Dayne H. Brown Mr. B. C. Buckley Dr. J . Nelson Grace Mr. W. H. Ruland L. W. Eury, 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, contractors, and agents of Carolina Power & Light Company.

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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PIANT, UNIT 1 NRC DOCKET NO. 50-325 OPERATING LICENSE NO. DPR-71.

REQUEST FOR LICENSE AMENDMENT FUEL CYCLE NO. 7--RELDAD LICENSING BASIS FOR CHANGE REOUEST' The' current composition of the BSEP-1, Cycle 6 core consists of fuel types of the 8x8R, P8x8R, and BP8x8R fuel designs. Reload 6, Cycle 7 for BSEP-1 will introduce a new extended burnup barrier fuel design, GE8, manufactured by General Electric (GE). The remaining 8x8R fuel assemblies will be removed at the end of Cycle 6. The new GE8 fuel design was approved by the NRC in the Safety Evaluation Report for Amendment 10 to GESTAR II (NEDE-24011-P-A). To support the use of fuel types of the GE8 fuel design, Limiting Conditions for. Operation (LCO) within the BSEP-1 TS, which are derived from or reference an LHGR limit, are revised. .In addition, fuel type specific MAPLHGR limits, as a

- function of exposure, are included for the two new GE8 fuel types.

These new MAPLEGR limits for the GE8 fuel are for the most limiting lattice and are to be used in the event the more detailed core monitoring is unavailable. The MAPLHGR limits have been evaluated using NRC approved methodology described in GESTAR II.

Cycle specific operating limit MCPR values have been evaluated as reported in the Supplemental Reload Licensing Report (SRLR). The evaluations summarized in the SRLR were performed using NRO approved methodologies. These methodologies include the advanced GEMINI /ODYN methods and the GEXL-PLUS CPR correlation in conjunction with the upgraded _ safety limit MCPR. The upgraded safety limit MCPR has been approved in the SER to Amendment 14 to GESTAR II. It has been determined that the upgraded safety limit MCPR is applicable to BSEP-1, Cycle 7. Several of the proposed changes reflect the use of the GEMINI /0DYN methods along with the GEXL PLUS CPR correlation and the application of the upgraded safety limit MCPR value.

The remaining proposed changes are editorial in nature. These proposed changes include revision of a reference to the Updated FSAR instead of the original FSAR, delineation of the control rod r.otch position taken to correspond to a scram insertion fraction, and establishing a common terminology between two sections of the TS which apply a similar technique to derive monitoring process setpoints.

El-1

Proposed Channe 1 Currently the-definition for Physics Tests in the BSEP-1 TS references a description in Section 13 of the FSAR. The proposed change revises this reference to read Section 14 of the Updated FSAR.

Signiffcant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The proposed change is an administrative change to the TS to revise the FSAR reference specified in the definition of Physics Tests. This type of change is necessary to maintain accurate reference within the TS and has no impact on the actual specification. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.
2. The proposed change is purely administrative and will not alter the technical content contained in the definition of Physics Tests. The change merely provides an updated reference. Based on this reasoning, CP&L has determined that the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The proposed change merely revises the FSAR reference in the definition of Physics Tests and will have no impact on the TS.

Revision of the FSAR reference is purely administrative and therefore, does not involve a significant reduction in the margin of safety.

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Proposed Change 2 The proposed change adds a reference to notch 36 position in TS Section 3.2.3.2.

Basis Currently TS Section 3.2.3.2 specifies that the cycle average 20% scram time shall be less than or equal to the Option B scram _ time limit.

Since the scram time limit is established using scram time statistical distributions based on the time from de-energization of the scram pilot valve solenoid to pickup of the control rod notch position 36 reed switch, a reference to the pickup of the notch 36 position ic being added for clarification.

Sienificant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The proposed change provides clarification to Specification 3.2.3.2. The specification references a cycle average 20% scram time. This scram time has been established as the time from de-energization of the scram pilot valve solenoid to pickup of the control rod notch position 36 reed switch. The proposed change provides a reference to notch 36 to clarify the basis for the scram time. Based on this reasoning, CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.
2. The 20% scram time limit is based on the time from de-energization of the scram pilot valve solenoid to pickup of the control rod notch position 36 reed switch. The proposed change provides clarification of the specification without changing the basis for or intent of the Technical Specification. Therefore,the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. Adding the reference to notch 36 clarifies the basis for the specification, thereby helping to prevent misinterpretation. The proposed revision does not change the method of determining the 20% control rod scram time limit. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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Proposed Chance 3 The proposed change deletes four Maximum Average Planar Linear Heat Generation Rate (MAPLHCR) curves for fuel types which will not be present in Cycle 7 (Fuel Types 8DRB265L, 8DRB283, P8DRB285, and P8DRB265H). The references to these curves in TS Section 3/4.2.1 are also being revised.

Basis The current BSEP-1 TS contain curves for Maximum Average Planar Linear Heat Generation Rate (MAPLHGR) limits versus exposure for fuel types present during Cycle 6. Four of these fuel types will no longer be used in the BSEP-1 core; therefore, data for these four fuel types need not be maintained in the Technical Specifications.

Significant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The 8DRB265L, 8DRB283, P8DRB285, and P8DRB265H fuel types will no longer be used in the BSEP-1 core. The deletion of the MAPLHGR curves for these fuel types will remove unnecessary and potentially confusing information from the TS. Therefore, this change cannot involve a significant increase in the probability or consequences of any accident previously evaluated.
2. The deletion of the MAPLHGR curves for those fuel types that will no longer be used in the BSEP core does not affect the function of any component or system. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The proposed amendment deletes from the TS data for fuel types that will no longer be used in the BSEP core. The removal of unnecessary information from the TS cannot change the margin of safety. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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Proposed Change 4 The proposed change adds two MAPLHCR curves for the GE8 fuel types (Fuel Types BD323B and BD339A) being added for Cycle 7 operation.

Basis For BSEP-1 Cycle 7 operation, two GE8 fuel types will be used.

Therefore, MAPLHGR curves appropriate for the new BD323B and BD339A fuel types are being added. The MAPLHGR fuel design limit is established and monitored during operation to assure that the peak cladding temperature (PCT) following the postulated design basis loss-of-coolant accident (LOCA) will not exceed the peak cladding temperature limit of 10CFR50, Appendix K (2200 degrees F) and that thermo-mechanical stresses do not cause excessive cladding strain, The GE8 MAPLHGR limits, as all other MAPLHGR limits, are derived to allow the fuel to be operated as close to the allowable fuel design limits as practical. MAPLHGR limits represent the combined limits imposed by PCT and thermo-mechanical fuel performance. The MAPLEGR limits have been evaluated using NRC approved methodology described in GESTAR II.

Significant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The MAPLHGR fuel design limits do not act as initiators to any accident and thus have no affect on the probability of any accident. As a fuel design limit, the average planar exposure dependent MAPLHGR limits ensure that the peak cladding temperature does not exceed the PCT limit specified in 10CFR50, Appendix K for a design basis LOCA and the thermo-mechanical stress limits are met. This is exactly the same purpose as MAPLHGR limits for the previously approved fuel types. The purpose of these curves is and has been to allow the fuel to be operated as close to the acceptable limits as practical. The curves for the new fuel type continues to perform that function and as such will not significantly increase the consequeneses for any accident previously analyzed.
2. The proposed change adds MAPiRGR limits for the GE8 fuel types to be used in Cycle 7. This change does not affect the function of any component or system including those that mitigate che accident (LOCA) from which this limit is derived. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The MAPLEGR limits for the GE8 fuel design for use in Cycle 7, as well as those for other fuel types, have been developed to allow the fuel to be operated as close to the acceptable PCT and strain limits as is practical. The margin of safety is thus comparable El 5

to that of previraus MAPLHGR limits. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

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Proposed Change 5 The change deletes the LHGR limits for the 8x8R fuel design which will not be used during Cycle 7.

Basis Technical Specification Section 3.2.4 specifies the LHGR limits for fuel designs present in the BSEP-1 core. The LHGR limit ensures that excessive cladding strain does not occur during normal operation due to thermo-mechanical stresses. The 8x8R fuel design is currently in use for BSEP 1 Cycle 6; however, no 8x8R fuel will be used for BSEP-1 Cycle 7. Therefore, the LHGR limits for the 8x8R fuel need not be maintained in the TS.

Sicnificant Hazards Analysis The change does not involve si gaif : . ant hazards consideration for the following reasons:

1. The 8x8R feel design will no longer be used in the BSEP-1 core.

The deletion of the LHGR limits for this fuel design will remove unnecessary and potentially confusing information from the TS.

Therefore, this change cannot involve a significant increase in the probability or consequences of any accident previously evaluated.

2. The deletion of the LHGR limits for this fuel design, which will no longer be uced in the BSEP core, does not affect the function of any component or system. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The proposed amendment deletes data from the TS applicable to a fuel design that will no longer be used in the BSEP core. The removal of unnecessary information from the TS cannot change the margin of safety. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

Ei-7

Proposed Chance 6 The change adds the LHCR limit for the fuel types of the GE8 fuel design which are being added in Cycle 7.

Basis Technical Specification Section 3.2.4 specifies the LHGR limits for fuel designs used la the BSEP-1 core. The LHGR limit ensures that excessive cladding strain does not occur during normal operation due to thermo-mechanical stresses. In BSEP-1 Cycle 7, the GE8 fuel design will be used. Therefore, an LHCR limit appropriate for this fuel design is being added to the TS.

Significant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The LHCR limit ensures that excessive cladding strain does not occur during normal operation due to thermo-mechanical stresses.

Addition of the LH 9. limit for the GE8 fuel design cannot affect the probability of any accident. The consequences of anticipated operational occurrences are not affected directly by LHGR limits since the MCPR fuel design limits are derived such that the consequences of these events meet established criteria. The consequences of the postulated design basis LOCA are not directly affected by LHGR limits since the MAPLEGR fuel design limits are derived such that the consequences of this event meet established criteria. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. The proposed change adds the applicable LHGR limit for GE8 fuel which has been derived from the same methodology and acceptance criteria used for fuel designs present in Cycle 6. Therefore, the proposed amendment cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The LHGR limit for each fuel design is established using an NRC approved methodology to ensure that excessive cladding strain does not occur due to thermo-mechanical stresses. The same methodology and acceptance criteria used for fuel designs present in Cycle 6 have been applied to establishing the LHGR limit for the GE8 fuel design. This has resulted in a margin of safety for the GE8 fuel design that is comparable to the margin established for existing fuel designs. Based on this reasoning CP&L has determined that the proposed amendment does not involve a significant reduction in the margin of safety.

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Proposed Chance 7 Currently TS Section 3.2.2 specifies design Total Peaking Factors (TPF) for the 8x8R, P8x8R, and BP8x8R fuel designs. The proposed change deletes reference to the 8x8R fuel design since none of this fuel design will be present during Cycle 7.

Basis The design TPF values for the various fuel designs are used to determine appropriate flow biased setpoints. The 8x8R fuel design is currently in use for BSEP-1 Cycle 6; however, no 8x8R fuel will be used for BSEP-1 Cycle 7. Therefore, the TPF values for the 8x8R fuel need not be maintained in the TS.

Sienificant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The 8x8R fuel design will no longer be used in the BSEP-1 core.

The deletion of the design TPF for this fuel design will remove unnecessary and potentially confusing information from the TS.

Therefore, this change cannot involve a significant increase in the probability or consequences of any accident previously evaluated.

2. The deletion of the design TPF for this fuel type, which will no longer be used in the BSEP core, does not affect the function of any component or system. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The proposed amendment deletes data from the TS for a fuel design that will no longer be used in the BSEP core. The removal of unnecessary information from the TS cannot change the margin of safety. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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Proposed Chance Q The proposed change adds the value of the design TPF for the GE8 fuel design in TS Section 3.2.2.

Basis The design TPF values for the various fuel designs are used to determine appropriate flow biased setpoints. For BSEP 1 Cycle 7 operation, the GE8 fuel design will be used. Therefore, a design TPF value appropriate for the new BD323B and BD339A fuel types are being added.

Sienificant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The design TPF values for the various fuel designs are used to determine appropriate flow biased setpoints which prevent LHGR limits from being exceeded. In addition, it provides comparable probability that the assumptions used in the plant transient analyses are not violated at any operating power level when operating with large peaking factors. The design TPF is calculated directly from the LHGR limit for each fuel design using the same method that is used to calculate the maximum TPF.

Addition of the design TPF for the GE8 fuel design cannot affect the probability of any accident. Use of a design TPF appropriate to the GE8 fuel design ensures the applicability of the assumptions used to evaluate transient conditions. This results in consequences comparable to the use of other design TPF values in tandem with the applicable fuel design. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. Specification of the design TPF for the new GE8 fuel design present in Cycle 7 ensures that adjustment of monitoring setpoints is consistent for all fuel designs. The proposed change does not affect the function of any system or component. Based on this reasoning, CP&L has determined that the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The design TPF for the GE8 fuel design is calculated in the same manner as the values for the fuel designs present in Cycle 6 and is based on the LHGR limit applicable to the GE8 fuel design. The GE8 LHGR limit was evaluated using an NRC approved methodology with comparable cladding strcin acceptance criteria. This methodology assures that comparable cladding protection exists.

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

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Pronosed Change 9 The proposed amendment changes the MCPR safety limit, specified in the BSEP-1 TS, from 1.07 to 1.04.

Basis Currently, BSEP-1 TS reference the use of a safety limit Minimum Critical Power Ratio (MCPR) value of 1.07. The proposed amendment changes the MCPR safety limit specified in the BSEP-1 TS from 1.07 to 1.04.

The MCPR safety limit is established as the specific fuel design limit that will not be exceeded during any condition of normal operation, including the effects of anticipated operational occurrences to meet criterion 10 of 10CFR50, Appendix A. As such, the MCPR cafety limit bounds the acceptabic consequences of anticipated operational occurrences. The NRC approved methodology, used to derive the upgraded MCPR safety limit value of 1.04, applied the same criteria as that used to derive the original safety limit MCPR value of 1.07 The MCPR safety limit currently used for BSEP-1 reload cores was established in 1978. This safety limit was designed to provide a level of conservatism in establishing operating limit MCPR values, based on fuel design characteristics typical of those utilized at the time. The level of conservatism ouilt into the safety limit provides adequate margin to assure that more than 99.9% of the fuel rods in the core are expected to avoid boiling transition. An updated safety limit of 1.04, specified in Amendment 14 to NEDE-240ll-P A, "General Electric Standard Application for Reactor Fuel" (CESTAR II), has been reviewed and approved by the NRC for D lattice plants when applied to second successive reload cores of P8x8R, BP8x8R, GE8x8E or CE8X8EB fuel type with a high bundle R-factor. 3SEP-1 is such a D-lattice plant, with Cycle 7 being the third successive reload core with high bundle R-factor fuel. The Staff found a similar change for BSEP-2 acceptable via Amendment 151 dated April 12. 1988.

Significant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The NRC accepted methodology used to derive the upgraded safety limit MCPR of 1.04 applies the same criteria as that used to derive the current safety limit MCPR of 1.07. The upgraded safety limit MCPR value of 1.04 assures that fuel cladding protection equivalent to that provided with the 1.07 safety limit is maintained. Thus, the consequences of accidents previously evaluated are not significantly increased. The safety limit MCPR does not affect any physical system or equipment which could change che probability of an accident. Therefore, the proposed El-ll

change does not involve a significant increase in the probability of any accident previously evaluated.

2. Adoption of proposed MCPR safety limit value does not affect the function of any component or system _Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

- 3. The accidents analyzed in Chapter 15 of the Updated FSAR are not affected by the change in the safety limit MCPR. The 1.04 safety limit MCPR is applicable to GE8 fuel designs and assures that fuel cladding protection equivalent to that provided with the 1.07 safety limit is maintained. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

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I Proposed Chance 10 The proposed amendment deletes the operating limit MCPR values for the 8xCR fuel design which will not be used during Cycle 7.

Basis TS Section 3.2.3.1 specifies operating limit MCPR values for the fuel designs present in Cycle 6 based on the core conditions of Cycle 6.

Operating limit MCPR values are the fuel design limits during operation at nominal rated conditions which assure that the MCPR does not fall below the safety limit MCPR during any anticipated operational occurrence. The proposed change deletes the operating limit MCPR values for the 8?8R fuel design which will not be present in Cycle 7.

Significant Hazards Analysts The change does not involve a significant hazards consideration for the following reasons:

1. The 8x8R fuel design will no longer be used in the BSEP-1 core.

The deletion of the operating limit MCPR for this fuel design will remove unnecessary and potentially confusing information from the TS. Therefore, this change cannot involve a significant increase in the probability or consequences of any accident previously avaluated.

2. The deletion of the operating limit MCPR for this fu 1 design, which will no longer be used in the BSEP core, does not affect the function of any component or system. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The proposed amendment deletes data from the TS for a fuel design that will no longer be used in the BSEP ccre. The removal of unnecessary information from the TS cannot change the margin of safety. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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j Prooosed Channe 11 The proposed amendment adds to TS 3/4.2.3, the operating limit MCPR values applicable to the GE8 fuel types.

Basis Currently TS Section 3.2.3.1 specifies operating limit MCPR for the fuel types present in Cycle 6 based on the core conditions of Cycle 6.

Operating limit MCPR values are the fuel design limits during operation at nominal rated conditions which assure that the MCPR does not fall below the safety limit MCPR during any anticipated operational occurrence. The proposed change adds operating limit MCPR values for the new GE8 fuel design based on the core conditions of Cycle 7 consistent with the upgraded safety limit MCPR.

Significant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

l. The consequences of the accidents analyzed in Chapter 15 of the Updated FSAR have been evaluated for Cycle 7 core conditions and are summarized in the SRLR. These consequences have been used to derive the operating limit MCPR values. The operating limits for previous cycles were similarly derived to assure that the MCPR did not fall below the MCPR safety limit for any anticipated operational occurence. This ensures that the consequences of an accident are comparable. Therefore, the proposed change does not involve a significant increase in the probability or consequences of any accident previously evaluated.
2. The proposed revision of operating limit MCPR values does not affect the function of any component or system. Therefore, CP&L has determined that the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. An NRC approved methodology is utilized to determine the applicable operating limit MCPR values based on cycle specific core conditions, fuel designs and the applicable safety limit MCPR value. The application of this NRC approved methodology to determine the operating limit MCPR values does not change the criteria used to establish the fuel design safety limit MCPR.

This ensures a margin of safety comparable to previous cycles.

Based on this reasoning, CP&L has determined that the proposed change does not involve a significant reduction in the margin of safety.

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I Proposed Chanze 12 The proposed change revises the values for mu (p) and sigma (a) contained in TS Section 3.2.3.2 to reflect the use of the advanced GEMINI /0DYN analysis methods used for Cycle 7 evaluations.

Basis Section 3.2.3.2 of the current BSEP-1 TS specifies values for mu (p) and sigma (a) which are based on GENESIS /0DYN analysis methods. The proposed change revises these values to be consistent with the advanced GEMINI /0DYN analysis methods used for Cycle 7 evaluation.

The change incorporates values used in the statistical weighting of scram time testing results applicable to the NRC approved GEMINI /0DYN methods for establishing the operating limit MCPR values. These new values are based upon the expanded BWR industry scram speed data base and as such, are more appropriate for current fuel designs than those currently in use.

Sienificant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The proposed change revises the numerical values of the formula for determining the ODYN Option B scram time limit which is used to select the applicable operating limit MCPR value. These operating limit MCPR values are the fuel design limits during operation at nominal rated conditions which provide assurance that the MCPR does not fall below the safety limit MCPR for any anticipated operational occurrence. The operating limits for previous cycles were similarly derived to assure that the MCPR does not fall below the MCPR safety limit for any anticipated operational occurence. This ensures that the consequences of an accident are comparable. Based on this reasoning, CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.
2. The proposed change reflects the use of General Electric derived values of mu (p) and sigma (a). The use of these new values will not affect the function of any component or system. The use of values for statistical weighting in the determination of the ODYN Option B scram time limit cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The proposed change revises values required for the proper determination of the operating limit MCPR values used to meet Criterion 10 of 10CFR50, Appendix A. These revised values are El-15

applicable to the NRC approved GEMINI /0DYN methods ur.ed to evaluate the fuel performance during anticipated operational occurrences in Cycle 7. These evaluations establish operating limit MCPR values that ensure the MCPR does not fall below the safety limit MCPR values during any anticipated operational

- occurence such that the margin of safety is comparable to previous cycles. Based on this reasoning CP&L has determined that the proposed amendment does not involve a significant reduction in the margin of safety.

P El-16

Pronosed Change 13 The change deletes the limiting transient operating limit MCPR values in TS Table 3.2.3.2-1 for the 8x8R fuel type. This fuel design vill not be used during Cycle 7.

Basis The limiting transient operating limit MCPR values may be used to establish the operating limit MCPR values in the event that measured control rod scram insertion times exceed the value specified in TS 3.2.3.2. TS Table 3.2.3.2 1 presently contains limiting transient operating limit MCPR values applicable to the present Cycle 6 core conditions. The 8x8R fuel design is currently in use for BSEP-1 Cycle 6; however, r.o 8x8R fuel will be used for BSEP-1 Cycle 7.

Therefore, the MCPR values for the 8x8R fuel need not be maintained in the TS.

Significant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The 8x8R fuel design will no longer be used in the BSEP-1 core.

The deletion of the limiting transient operating limit MCPR values for this fuel design will remove unnecessary and potentially confusing information from the TS. Therefore, this change cannot involve a significant increase in the probability or consequences of any accident previously evaluated.

2. The deletion of the limiting transient operating limit MCPR values for this fuel design, which will no longer be used in the BSEP core, does not affect the function of any component or system.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment deletes data from the TS for a fuel design that will no longer be used in the BSEP core. The removal of unnecessary information from the TS cannct change the margin of safety. Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

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Pronosed Chance 14 The proposed change revises the BP8x8R and P8x8R fuel design limiting transient operating limit MCPR values in TS Table 3.2.3.2-1 and adds the value for the GE8 fuel design to be added in the Cycle 7 core.

Basis The limiting transient operating limit MCPR values may be used to establish the operating limit MCPR values in the event that measured control rod scram insertion times exceed the value specified in TS 3.2.3.2.- This is provided for in the NRC approved GEMINI /0DYN methods. TS Table 3.2.3.2-1 presently contains limiting transient operating limit MCPR values applicable to the present Cycle 6 core conditions. The proposed change revises these MCPR values to reflect Cycle 7 core conditions for fuel designs present in both Cycle 6 and Cycle 7, and the addition of values for the GE8 fuel design added for Cycle 7.

Sienificant Hazards Analysis

. The change does not involve a significant hazards consideration for the following reasons:

1. The proposed change specifies limiting transient operating limit MCPR values which are not accident initiators and, therefore, cannot affect the probability of any accident. The proposed values are appropriate for Cycle 7 core conditions and are used as necessary to determine the applicable operating limit MCPR values as described in the NRC approved GEMINI /0DYN methods. These operating limit MCPR values are the fuel design limits during operation at nominal rated conditions which provide assurance that the MCPR does not fall below the safety limit MCPR for any anticipated operational occurrence. The operating limits for previous cycles were similarly derived to assure that the MCPR does not fall below the MCPR safety limit for any anticipated operational occurence. This ensures that the consequences of an accident are comparable. Based on thic reasoning CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.
2. The revised limiting transient operating limit MCPR values do not affect the function of any component or system. Therefore, this proposed change cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

j 3. The proposed change specifies values that may be required for the proper determination of the operating limit MCPR values used to El-18

meet criterion 10 of 10CFR50, Appendix A. These revised values are applicable to Cycle 7 core conditions based on evaluations performed to evaluate the fuel performance during anticipated operational occurrences in Cycle 7. The evaluations establish the operating limit MCPR which ensures the MCPR does not fall below the safety limit MCPR values during any anticipated operational occurence such that the margin of safety is comparable to previous cycles. Based on this reasoning CP&L has determined that the proposed amendment does not involve a significant reduction in the margin of safety.

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Proposed Chance 15 This change deletes the GEXL reference and specifies that an NRC approved correlation be used.

Basis Currently, the definition for Critical Power Ratio (CPR) in the BSEP-1 Technical Specificattions specifies that the CPR is calculated by application of the CEXL correlation. The GEXL correlation is one of several NRC approved CPR correlations which could be used for this purpose. The GEXL-PLUS CPR correlation has been used in developing the operating limit MCPR values for Cycle 7. This change would allow for the use of any of the NRC approved CPR correlations, as appropriate, for future fuel cycles. Future fuel cycles could require the application of one or more CPR correlations during a particular fuel cycle.

Sirnificant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The proposed change replaces the reference to a specific CPR correlation with a general reference and further specifies that the correlation must be approved by the NRC. The requirement that the CPR correlation be approved by the NRC assures that the performance of the correlation has been compared against applicable test data and found to provide acceptable results. The CPR correlation is used in both monitoring and establishing a fuel design limit for the core conditions. The CPR correlatic is not an accident initiator and cannot affect the probability of an accident. The operating limit MCPR values are the fuel design limits during operation at nominal rated conditions which provide assurance that the MCPR does not fall below the safety limit MCPR for any anticipated operational occurrence. The operating limit MCPPs for previous cycles were similarly derived to assure that the MCPR does not fall below the MCPR safety limit for any anticipated operational occurence. This ensures that the consequences of any accident are comparable. Based on this reasoning, CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of any accident previoucly evaluated.
2. The proposed change does not alter the requirement that a CPR fuel design limit be monitored and, therefore, this change does not affect the function of any component or system. Use of an hRC approved CPR correlation therefore cannot create the possibility of a new or different kind of accident from any accident i previously identified.

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3. As stated previously, CPR correlations approved by the NRC are compared against applicable test data and must provide acceptable results. Applicable operating limit MCPR and safety limit MCPR values are established in a manner consistent with the CPR correlation. This ensures that the MCPR does not fall below the safety limit MCPR values during any anticipated operational occurence such that the margin of safety is comparable to previous cycles. Based on this reasoning CP&L has determined that the proposed amendment does not involve a significant reduction in the margin of safety.

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Proposed Chance 16 The proposed change revises TS Figure 3.2.3-1 to reflect the GEXL-PLUS correlation recently approved by the NRC which will be used during Cycle 7 to monitor MCPR.

Basis TS Figure 3.2.3-1 contains a set of curves to determine the applicable Kg MCPR multiplier based on percent core flow and scoop tube calibration setpoint. The proposed change incorporates the Kg factor curve required for the use of the GEXL-PLUS CPR correlation which has been approved by the NRC in the SER to Amendment 14 to GESTAR II. The Kg factor is used to adjust the operating limit MCPR values for off nominal flow conditions.

Sinnificant Hazards Analysis The change does not involve a significant hazards consideration for the following reasons:

1. The Kg curves are used to establish applicable operating limit MCPR values for off nominal flow conditions in the process of monitoring fuel performance. The CPR correlation is used in both monitoring and establishing an operating limit MCPR for the core conditions and is not an accident initiator. The CPR correlation therefore, cannot affect the probability of an accident. The operating limit MCPR values are the fuel design limits during operation which provide assurance that the MCPR does not fall below the safety limit MCPR for any anticipated operational occurrence. The operating limit MCPRs for previous cycles were similarly derived to assure that the MCPR does not fall below the MCPR safety limit for any anticipated operational occurence. This ensures that the consequences of an accident are comparable.

Based on this reasoning, CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated.

2. The Kg curves do not affect the function of any component or system. Therefore, the use of Kg curves consistent with the applicable CPR correlation cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
3. The NRC approved GEXL PLUS CPR correlation has been compared I against applicable test data and has been demonstrated to provide acceptable results. These comparisons and results include the application of Kg curves for off-nominal flow conditions.

l Applicable operating limit MCPR values are established, consistent with the CPR correlation and the appropriate Kg curve , to ensure the MCPR does not fall below the safety limit MCPR values during I

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eny anticipated operational occurence, thereby maintaining a margin of safety comparble to previous cycles. Based on this reasoning, CP6L has determined that the proposed amendment does not involve a significant reduction in the margin of safety, i

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Proposed Chance 17 The proposed change revises formulas in TS Table 3.3.4-2 which are used to determine flow biased setpoints, to be consistent with TS r Section 3.3.2 and removes specific values contained in the footnote to TS Table 3.3.4 2 and replaces them with a reference to TS Section 3.2.2.

Basis The proposed change provides consistency in formulas specified in TS Section 3.2.2 and TS T?le 3.3.4-2. These formulas use the ratio of design TPF divided by t..e MTPF but identify the components differently.

The formulas are used to calculate flow biased setpoints and contain a similar_ stated variable. The formulas in TS Section 3.2.2 utilize the variable "T" which is defined as the ratio of the design TPF divided by the MTPF. Values for the design TPF for the various fuel designs are c also given within the specification. The formulas in TS Table 3.3.4-2 utilize the same ratio, although it is stated differently. In this formula the variable is stated as the ratio of "T" divided by the MTPF where "T" corresponds to the design TPF. The footnote to this table gives the design TPF (stated as values for "T") for the various fuel designs.

Significant Hazards Consideration The change does not involve a significant hazards consideration for the following reasons:

1. Consistency between the formulas in TS Section 3.2.2 and TS <

Table 3.3.4-2 will aid in eliminating potential confusion without altering the calculation of these setpoints. This change would result in the use of a numerically equivalent formula which cannot affect either the probability or consequences of an accident.

Based on this reasoning, CP&L has determined that the proposed

amendment does not involve a significant increase in the p.obability or consequences of any accident previously evaluated.
2. The proposed change provides consistency between TS Table 3.3.4-2 and TS Section 3.3.2 without altering the numerical method of determining the flow biased setpoints. Therefore, the proposed amendment does not create the possibility of a new or different j kind of accident from any accident previously evaluated, i
3. Revision of the formulas and footnote contained in TS Table 3.3.4 2 provides consistency with TS Section 3.2.2 without
altering the technical content or numerical result of the calculations contained in the specification. The margin of safety  ;

is therefore identical. Based on this reasoning, CP&L has  !

i determined that the proposed change does not involve a significant

! reduction in the margin of safety.

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-Proposed Chance 18 The proposed change revises the BSEP-1 TS Bases, consistent with the upgraded safety limit MCPR, and eliminates out of date-input data which

  • had been used in the discussion of previous MCPR safety limit determinations based on previous fuel designs.

Basis A 10CFR50.92 significant hazards evaluation is not provided for this change since the Bases are only summary statements in support of the Technical Specifications and are not considered part of the actual Technical Specifications consistent with the provisions of 10CFR50.36.

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Proposed Chance 19 Currently the TS Bases provides descriptive information relative to the present Cycle 6 core load. The proposed change revises Bases Sections 3/4.2.1, 3/4.2.2 and Table B2.2.1-1 to reflect the new Cycle 7 core design.

Basis A 10CFR50.92 significant hazards evaluation is not provided for this change since the Bases are only summary statements in support of the Technical Specifications and are not considered part of the actual Technical Specifications consistent with the provisions of 10CFR50.36.

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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 NRC DOCKET No. 50 325 OPERATING LICENSE NO. DPR 71 REQUEST FOR LICENSE AMENDMENT FUEL CYCLE NO. 7- RELOAD LICENSING INSTRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to Operating License DPR-71) would be incorporated as follows:

UNIT 1 Remove Page Insert Pane III III IV IV 1-2 12 1-5 1-5 21 21 B2-1 B2 1 B2-2 B2 2 B2-3 B2 3 B2-4 B2-4 B2 5 B2-5 B2 6 B2 6 B2 7 B2-7 B2 8 B2-9 B2-10 B2 11 B2 12 3/4 1-17 3/4 1-17 3/4 2-1 3/4 2-1 3/4 2-2 3/4 2-2 3/4 2 3 3/4 2-3 3/4 2-4 3/4 P 4 3/4 2 5 3/4 2-5 3/4 2-6 3/4 2-6 3/4 2 7 3/4 2-7 3/4 2-8 3/4 2 8 3/4 2 9 3/4 2-9 3/4 2 10 3/4 2 10 3/4 2 11 3/4 2 11 3/4 2 12 3/4 2 12 3/4 2-13 3/4 2 13 3/4 2 14 3/4 2 14 E2 1

Pemove Page Insert Page 3/4 2 15 3/4 2-16 3/4 3-39 3/4 3 39 3/4 3 42 3/4 3 42 B3/4 1 2 B3/4 1-2 B3/4 1 3 B3/4 1 3 B3/4 2 1 B3/4 2-1 B3/4 2-2 B3/4 2-2 B3/4 2-3 B3/4 2-3 E2 2

ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PIANT, UNIT 1 NRC DOCKET No. 50 325 OPERATING LICENSE NO DPR-71 REQUEST FOR LICENSE AMENDMENT FUEL CYCLE NO. 7 RELOAD LICENSING

SUMMARY

LIST OF REVISIONS UNIT 1 Par.es Description of Changes III Revises page reference IV Revises page reference 1-2 Revises the definition of Critical Power ratio 15 Revises the definition of Physics Tests 2-1 Revises the value of the MCPR safety limit B2-1 Revises the value of the MCPR safety limit and the reference to the CPR correlation B2-2 Revises the Thermal Fove' bases B2 3 Repagination only B2-4 Revises the value of the MCPR safety limit and repaginates the page B2 5 through B2-7 Repagination only 3/4 1-17 Revises the value of the MCPR safety limit 3/4 2-1 Revises the reference to the figures containing the MAPillGR curves 3/4 2 2 through Repagination only 3/4 2-4 E3-1

UNIT 1 Panes Description of Changes 3/4 2 5 and 3/4 2-6 Incorporate MAPLHGR curves for the new CE8 fuel types 3/4 2-7 Deletes the design TPF for the 8x8R fuel and adds a design TPF for the new GE8 fuel 3/4 2 8 Deletes the MCPR values for the 8x8R fuel, adds the MCPR values for the new GE8 fuel, and revises the P8x8R and BP8x8R MCPR values 3/4 2-9 Repagination only 3/4 2-10 Adds a reference to notch 36 and revises the values for mu (p) and sigma (a) 3/4 2-11 Repagination only 3/4 2-12 Deletes the most limiting transient MCPR values for the 8x8R fuels, adds the values for the GE8 fuel, and revises the values for the P8x8R and BP8x8R fuels 3/4 2-13 Revises the Kg curves 3/4 2-14 Adds a LHCR limit for the new GE8 fuel and deletes the LHCR limit for the 8x8R fuel 3/4 3 39 Revises the value of the MCPR safety limit 3/4 3-42 Revises the APRM and rod block monitor setpoint formulas and the table footnote B3/4 1-2 Revises the value of the MCPR safety limit B3/4 2-1 Revises the reference to the figures containing the MAPLHGR curves B3/4 2 2 Adds the fuel parameters for the GE8 fuel E3-2

B3/4 2-3 Revises the TPFs and values for the MCPR safety limit I

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