BSEP-95-0153, Application for Amends to Licenses DPR-71 & DPR-62,adding Exemption from Requirements of TS 3.0.4 to Spec 3/4.8.1.1

Application for Amends to Licenses DPR-71 & DPR-62,adding Exemption from Requirements of TS 3.0.4 to Spec 3/4.8.1.1

ML20082B893
Person / Time
Site:	Brunswick
Issue date:	03/31/1995
From:	Cowan J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082B895	List: BSEP-95-0153, Application for Amends to Licenses DPR-71 & DPR-62,adding Exemption from Requirements of TS 3.0.4 to Spec 3/4.8.1.1 ML20082B905
References
BSEP-95-0153, BSEP-95-153, TSC-95TSB07, TSC-95TSB7, NUDOCS 9504060088
Download: ML20082B893 (10)

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x CP&L Carouna Power & Light Company - John Paul Cowan PO Box 10429 Director - Site Operations

' Southport NC 28461 Brunswick Nuclear Plant 910 457 2496 MAR 311995 SERIAL: BSEP 95-0153 10 CFR 50.90 TSC 95TSB07

. U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washingtun, DC 20555 BRUNSWICK NUCLEAR PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENTS ADDITION OF 3.0.4 EXEMPTION TO ELECTRICAL DISTRIBUTION SYSTEM TECHNICAL SPECIFICATION 3/4.8.1.1 Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests amendments to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. The proposed amendments would add an exemption from the requirements of Technical Specification 3.0.4 to Specification 3/4.8.1.1.

Enclosure 1 provides a detailed description and the basis for the proposed amendments.

Enclosure 2 details the basis for the Company's determination that the proposed amendments do not involve a significant hazards consideration.

Enclosure 3 provides an environmental evaluation which demonstrates that the proposed amendments meet the eligibility for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment needs to be prepared in connection with the issuance of the amendment.

Enclosure 4 provides the marked-up Technical Specification pages for Unit 1.

Enclosure 5 provides the marked-up Technical Specification pages for Unit 2.

Enclosure 6 contains typed Technical Specification pages for Unit 1.

Enclosure 7 contains typed Technical Specification pages for Unit 2.

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9504060088 DR 950331 1 ADOCK 05000324 PDR I

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Document Control Desk l BSEP 95-0153 / Page 2 l

Carolina Power & Light Company is providing,in accordance with 10 CFR 50.91(b), l Mr. Dayne H. Brown of the State of North Carolina with a copy of the proposed license. ,

amendments.

In order to facilitate an orderly implementation of the proposed amendments, CP&L requests that the amendments be issued with an effective date of no later than 60 days from the date of issuance.

Please refer any questions regarding this submittal to Mr. R. P. Lopriore at (910)457-2212.

Very truly yours,  ;

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John Paul Cowan i KAH/ ,

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Enclosures John Paul Cowan, 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,

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Notary (Seal) ,

My commission expires: 8[2l 9 -l.

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-' Doc 0 ment Control Desk BSEP 95-0153 / Page 3

.-; . cc: Mr.~ D. H. Brown, State of North Carolina

- Mr. S. D. Ebneter, Regional Administrator, Region Il Mr. C. A. Patterson, Brunswick NRC Senior Resident inspector.-

Mr. D. C. Trimble, Jr., NRR Senior Project Manager - Brunswick Units 1 and 2 The Honorable H. Wells, Chairman - North Carolina Utilities Commission i

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ENCLOSURE-1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 ADDITION OF TS 3.0.4 EXEMPTION TO TS 3/4.8.1.1 BASIS FOR CHANGE REQUEST Pronosed Chance Brunswick Unit 1 and Unit 2 Technical Specification 3.0.4 state that entry into an OPERATIONAL CONDITION or other specified applicability state shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted.

Brunswick Unit 1 and Unit 2 Technical Specification 3/4.8.1 requires, for OPERATIONAL CONDITIONS 1,2, and 3, two physically independent circuits, per unit, between the offsite transmission network and the onsite Class 1E distribution system be OPERABLE.

A footnote in Unit 1 and Unit 2 Technical Specification 3.8.1.1, Action a, indicates that, with the opposite unit in Operational Condition 4 or 5 and one of the opposite unit's offsite sources not available, the operating unit may remain in service for 45 days. At the end of the 45 days, with the opposite, non-operating unit's offsite source not restored, the operating unit must be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No exemption to Specification 3.0.4 exists for this footnote. The proposed change would add an exemption only for the footnote to Action a. On Unit 2 only, an editorial revision is being made to the Action a. statement. The revision corrects a typographical error (changes "l" to "1") and does not affect any of the conclusions presented herein.

Basis For Pronosed Chance Th? safety objective of the auxiliary power system (which includes the offsite power sources and the emergency diesel generators)is to furnish adequate power to the plant auxiliaries during all modes of operation, enabling the plant to be maintained in a safe

. condition (Reference UFSAR Section 8.3.1.1.1).

The Brunswick Plant Electrical Distribution System provides a high degree of flexibility in serving emergency power system load requirements. The Brunswick Plant is a two-unit site with four 4KV emergency buses (E1, E2, E3, and E4). Each unit's safety-related loads are distributed across these four emergency buses, with each bus having its own dedicated emergency diesel generator. Any three of the four diesel generators can supply the required loads for the safe shutdown of one unit and a design basis accident on the i other unit without offsite power or the need for parallelling the emergency diesel .d. ,

generators. For a station blackout event, any one of the four diesel generators can proyIde the necessary power for both units for the required coping duration. Redundancy is E1-1 3

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provided by the offsite power sources. Emergency buses El and E2 are supplied from the Unit 1 switchyard (via the Unit 1 Unit Auxiliary Transformer (UAT) and Startup Auxiliary Transformer (SAT)) while E3 and E4 are supplied from the Unit 2 switchyard (via the Unit 2 UAT and SAT). The two switchyards are not connected at the site.

Tables 1 and 2 i!!ustrate the high level of AC source redundancy provided by the Brunswick Electrical Distribution System. The tables identify the offsite power sources available for the operating unit (for the example case, Unit 2) with one of the shutdown unit's (for the example case Unit 1) offsite circuits (UAT or S AT) out of service.

Table 1 Emergency Bus Available Power Sources: Unit 1 SAT Out-of-Service Being Other Emergency Station Blackout Source Emergency Powered By Available Standby (From Other Unit)

Bus Offsite source Offsite Source Source E1 Unit 1 UAT None EDG #1 E1-E3 Crosstie Circuit E2 Unit 1 UAT None EDG #2 E2-E4 Crosstie Circuit E3 Unit 2 UAT Unit 2 SAT EDG #3 E1-E3 Crosstle Circuit Circuit E4 Unit 2 UAT Unit 2 SAT EDG #4 E2-E4 Crosstle Circuit Circuit Table 2 Emergency Bus Available Power Sources: Unit 1 UAT Out-of-Service Being Other Emergency Station Blackout Source

' Powered By Available Emergency Standby (From Other Unit)

Bus Offsite Source Offsite Source Source E1 Unit 1 SAT None EDG #1 E1-E3 Crosstie Circuit E2 Unit 1 SAT None EDG #2 E2-E4 Crosstle Circuit E3 Unit 2 UAT Unit 2 SAT EDG #3 E1-E3 Crosstle Circuit Circuit E4 Unit 2 UAT Unit 2 SAT EDG #4 E2-E4 Crosstie Circuit Circuit ,

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c Amendments 145 and 176 to the Brunswick' Unit 1 and Unit 2 Technical Specifications,'

respectively, were issued on October 5,1990. These amendments added the footnote to Specification 3.8.1.1.a of the operating unit which permits an offsite circuit of the shutdown unit to be inoperable for up to 45 days; however, no exemption to the requirements of TS 3.0.4 was proviceo witi th!:: change.

. The basis of the change in Amendments 145 and 176 was to increase the flexibility in the-electrical distribution system specifications to allow transformer maintenance, inspections, and bus duct inspections to be performed in future outages. The October 5,1990 NRC staff Safety Evaluation for the proposed change indicated that the change was acceptable on the following basis:

i For operation to continue on the operating unit while one of the shutdown unit's offsite sources is out of service, the existing TS require all four diesel generators and the remaining offsite power sources of both units to be operable. Action Requirement 3.8.1.1.c or 3.8.1.1.d will be applicable to the operating unit upon loss of a diesel generator or loss of an additional offsite circuit. Thus, the operability of the two offsite circuits on the operating unit is not affected during this maintenance work. Based on the above, we find the proposed changes to the Brunswick unit 1 and 2 TS to be acceptable.

4 The addition of a TS 3.0.4 exemption to the footnote does not affect the basis of NRC staff acceptance of the changes made in Amendments 145 and 176. The Action Requirements of Specifications 3.8.1.1.c and 3.8.1.1.d remain applicable to the operating 1

unit's specification, and the operability of the two offsite circuits on the operating unit is not affected by the change. Therefore, CP&L believes that the proposed change of providing an exemption to the requirements of 3.0.4 to the footnote in TS 3.8.1.1.a is consistent with intent of Amendments 145 and 176 in providing additional flexibility for the electrical distribution system. Furthermore, CP&L has completed a safety assessment of the proposed change and has concluded that no impact to safety would result from the change. The conclusions of the safety assessment are presented below.

With respect to this request, the relative risk and impact on ccre damage frequency (COF) to the unit in the Limited Condition for Operation (LCO) would be based on the likelihood of having an initiating event that would cause a reactor trip leading to core damage during the period of restart. The example described in the following paragraphs demonstrates i that the relative risk to the unit proceeding through startup is negligible with respect to the opposite unit not having one of the off site power feeds available, in this example, Unit 1 is considered to be shutdown, with one of the two off-site circuits which power Emergency Buses E1 and E2 not available (either the UAT or the SAT). Unit 2 would be

, proceeding through Operational Conditions 3,2, and 1 to full power.

The overallimpact on Unit 2 core damage frequency as a result of having one of the Unit 1

. offsite power circuits unavailable is minimal due to the limited duration of a plant startup i

and the low probability of an initiating event occurring on Unit 2 during the startup period.

The probability of having a loss of offsite power (LOOP) event on Unit 2 during the startup period would not be affected by this request, since the primary contributors to a LOOP (i.e., severe weather and transmission network maintenance) are unaffected. In addit $n~;,

a loss of off site power event that affects both units, such as a foss of the grid, would ,

pose no additional core damage risk when one Unit 1 offsite power source is initially

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una'vailable. A LOOP would cause all offsite sources to be unavailable, regardless of their initial operability status. A LOOP event is evaluated in the base case core damage frequency for each unit.

If the remaining Unit 1 offsite circuit were to fait during the restart of Unit 2, some Unit 2 components that receive AC power from Emergency Buses El and E2 and their functions would be unavailable until power is restored to the emergency buses by the emergency diesel generators. The Unit 2 components that would be temporarily unavailable include 2 of the 4 drywell coolers (4 of 8 drywell cooling f ans), one conventional service water pump, RHR and RHR service water pumps 2C and 2D, LPCIinjection valves, torus spray valves, and two diesel building exhaust fans. Were Unit 2 shutdown and Unit 1 transitioning through startup to full power operation, a Group 6 valve isolation and reactor building / secondary containment isolations also occurs on the operating unit (Unit 1), as well as a Standby Gas Treatment System automatic start. Temptsrary loss of these functions and the associated isolations and actuations would not cause an automatic unit reactor trip; therefore, a loss of offsite power to emergency buses on the shutdown unit would not cause a transient initiating event on the operating unit.

In summary, with one shutdown unit offsite power source initially unavailable, a dual unit LOOP will pose no additional risk to the plant. A LOOP occurring only on the shutdown unit will not cause the operating unit to trip. The probability of a LOOP occurring only on the operating unit is not affected by this change. The overall safety impact of adding a TS 3.0.4 exemption statement to the footnote of TS 3.8.1.1.a, therefore, is not considered to be significant.

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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1' AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR 71 & DPR-62 REQUEST FOR LICENSE AMENDMENTS ADDITION OF TS 3.0.4 EXEMPTION TO TS 3/4.8.1.1 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power & Light Company has reviewed this proposed licmse amendment request and believes that its adoption would not involve a significant hazards consideration. The basis for this determination follows.

1. The proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change would allow one unit to transition through Operational Conditions 3,2, and 1'to full power with the opposite unit in Operation Condition 4 or 5 and one off site power circuit out of service. The current specification allows one unit to operate for up to 45 days with the other unit shutdown and one of the shutdown unit's off-site power circuits unavailable.

A significant level of redundancy of AC sources remains, even with one of the shutdown unit's off-site circuits unavailable, if the shutdown unit's remaining offsite circuit were to fail during the restart of the other unit, some of the operating unit's components that receive AC power from the shutdown unit's emergency buses and

< their functions would be unavailable until power is restored to the emergency buses by the emergency diesel generators. For example, with Unit 1 shutdown and Unit 2 transitioning through startup to full power operation, the Unit 2 components fed by Emergency Buses E1 and E2 that would be temporarily unavailable on a loss of both Unit 1 off-site circuits include 2 of the 4 drywell coolers (4 of 8 drycell cooling

. fans), one conventional service water pump, Residual Heat Removal System (RHR) and RHR service water pumps 2C and 2D, Low Pressure Coolant injection (LPCI) system injection valves, torus spray valves, and two diesel building exhaust fans.

Were Unit 2 shutdown and Unit 1 transitioning through startup to full power operation, a Group 6 valve isolation and reactor building / secondary containment

! isolations also occurs on the operating unit (Unit 1), as well as a Standby Gas Treatment System automatic start. Temporary loss of these functions and the associated isolations and actuations would not cause an automatic unit reactor trip; therefore, a loss of offsite power to emergency buses on the shutdown unit would not cause a transient initiating event on the operating unit. Therefore, the 6( * ,

probability of an accident previously evaluated is not significantly increased by the .

proposed change.

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. A loss of auxiliary (off-site) power (LOOP) event is an analyzed transient for the Brunswick Plant. A loss of offsite power is assumed to occur following a loss of all j external grid connections or faults in the offsite power system itself. The Brunswick '

Probabilistic Safety Assessment has modeled the loss of offsite power event. The most probable causes of a loss of offsite power event involve natural events or transmission network maintenance. Neither of these is affected by the proposed change. Therefore, the probability of a previously evaluated transient is not significantly increased.

' This change does not affect the remaining off-site Technical Specification requirements nor does it affect the on-site electrical distribution Technical i

Specification requirements. The existing Technical Specifications require all four diesel generators and the remaining offsite power sources of both unite be operable.

Technical Specifications 3.8.1.1.c and 3.8.1.1.d will still be applicable to the unit transitioning through the startup evolution. These specifications dictate requirements for the operating unit upon loss of a diesel generator or an additional offsite power circuit. Thus, operability of the emergency diesel generators and the remaining offsite power sources is unaffected by this change. Since the emergency diesel generator capability is unaffected by this change, the proposed change would not affect the capability of accident mitigating equipment; therefore, the consequences of previously evaluated accidents is not affected by the proposed change.

2. The proposed amendments would not create the possibility of a new or differem kind of accident from any accident previously evaluated. A LOOP is one of the transients analyzed in the Brunswick Update Final Safety Analysis Report.. The proposed action would not affect the conclusions of that analysis. In addition, the Brunswick design basis accident analyses accommodate a loss of off-site power coincident with the design basis accident and a single failure of one emergency diesel generator. The proposed change does not affect operability requirements of the emergency diesel generators. Therefore, no new malfunction or accident is introduced by the i proposed action.

3. The proposed amendments do not involve a significant reduction in a margin of safety. The basis of Technical Specification 3.0.4 is to ensure that facility operation is not initiated with either required equipment or systems inoperable or other limits being exceeded. Exceptions to this provision are provided for specifications when startup with inoperable equipment would not affect plant safety. Sufficient' redundancy of AC power will continue to exist and no fewer sources of AC power will be available than would be allowed for power operation for up to 45 days under Specification 3.8.1.1.a. Therefore, the proposed change would not impact safety '

and the margin of safety imposed by either Technical Specification 3.0.4 or Specification 3/4.8.1 would not be significantly reduced. j d.',

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. . l ENCLOSURE 3

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BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AND 2 NRC DOCKETS 50-325 & 50-324 iOPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENTS ADDITION OF TS 3.0.4 EXEMPTION TO TS 3/4.8.

1.1 ENVIRONMENTAL CONSIDERATION

S 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A=

proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in an increase in individual or cumulative occupational radiation exposure.

Carolina Power &' Light Company has reviewed this request and believes that the proposed amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).' Pursuant to 10 CFR 51.22(c), no environmentalimpact statement of environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows.

1. The amendments do not involve a significant hazards consideration, as shown in Enclosure 2.

2. The amendments do not result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The physical characteristics and function of plant systems, structures and components which serve to control the release of radionuclides are not being altered. Sufficient redundancy of the AC sources which power these plant systems will continue to exist. Therefore, no increase in the type or quantity of radionuclides released offsite at the Brunswick Plant will be introduced _by the proposed amendments.

3. The amendments do not result in any physical changes to plant systems or method of operation. The amendments will not result in the increase of any radiological products contained in plant systems. Therefore, the amendments will not result in an increase in individual or cumulative occupational radiation exposure.

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