BSEP-98-0017, Forwards Response to Telcon RAI Re 971106 Proposed License Amends Revising,For Limited Period of Time,Design Basis Qualification Requirements for CREVS & Crev Instrumentation. Calculations,Emergency Procedures & Plant Procedures Encl

Forwards Response to Telcon RAI Re 971106 Proposed License Amends Revising,For Limited Period of Time,Design Basis Qualification Requirements for CREVS & Crev Instrumentation. Calculations,Emergency Procedures & Plant Procedures Encl

ML20202D862
Person / Time
Site:	Brunswick
Issue date:	01/28/1998
From:	Hinnant C CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20202D867	List: BSEP-98-0017, Forwards Response to Telcon RAI Re 971106 Proposed License Amends Revising,For Limited Period of Time,Design Basis Qualification Requirements for CREVS & Crev Instrumentation. Calculations,Emergency Procedures & Plant Procedures Encl ML20202D894 ML20202D905 ML20202D915 ML20202D933 ML20202D937
References
BSEP-98-0017, BSEP-98-17, TAC-MA0112, TAC-MA0113, TAC-MA112, TAC-MA113, NUDOCS 9802180022
Download: ML20202D862 (6)

Text

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CP&L Carolina Power & Light Company C. S. Hinnant PO Box 10429 Vice President Southport, NC 28461.o429 Brunswick Steam Electric Plant JAN 2 81998 SERIAL: BSEP 95 0017 10 CFR 50.90 TSC 97TSB16 U. S. Nuclear Regulatcry Commission ATIN: Document Control Desk Wasnington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION h6 QUEST FOR LICENSE AMENDMENTS CONTROL BUILDING EMERGENCY VENTILATION SYSTEM (NRC TAC NOS. MA0ll2 AND MA0ll3)

Gentlemen:

By letter dated November 6,1997 (Serial: BSEP 97-0454), Carolina Power & Light (CP&L)

Company submitted a request to revise the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2. Specifically, the proposed license amendments revise, for a limited period of time, the design basis qualification requirements for the Control Room Emergency Ventilation System (CREVS) and CREVS instrumentation.

Through telephone discussions with the NRC Project Manager, CP&L was requested to provide additional information regarding Control Room heat up following a complete loss of the Control Room Air Conditioning system. CP&L was also requested to provide additional information regarding the availability and use of self-contained breathing apparatus for Control Room personnel. The information requested is provided in Enclosure 1.

L Please refer any questions regarding this submittal to Mr. Keith R. Jury, Manager - Regulatory l Affairs, at (910) 457-2783.

i Sincerely, C S lm W C. S. Hinnant h ,

9902180022 900128 PDR ADOCK 05000324 p PDR

i a

! ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKETNOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION  ;

REQUEST FOR LICENSE AMENDMENTS CONTROL BUILDING EMERGENCY VENTILATION SYSTEM - ,

(NRC TAC NOS. MA0112 AND MA0113)

. RESPONSE TO REQUEST FOR' ADDITIONAL INFORMATION

. B'y letter dated November 6,1997 (Serial: BSEP 97-0454), Carolina Power & Light (CP&L)

Company submitted a request to revise the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos l'and 2. Specifically, the proposed license amendments revise, fo" limited period of time, the design basis qualification requirements for the Control Room

- Emergency Ventilation System (CREVS) and CREVS instrumentation.

NRC REOUEST:-

On January 16,1998, a telephone conference call was conducted with the NRC to discuss --

' CP&L's license amendment requests.-- The NRC requested that CP&L provide additional

- information regarding: (1) Contro1 Room heat-up following a complete loss of the Control Room Air Conditioning system, and (2) the availability and use of self-contained breathing apparatus (SCBA) for Control Room personnel, including information on the number of SCBAs available, refill capabilities, procedures,' training, and demonstration of the capability of coperators to perform required plant operations. ,

' RESPONSE TO NRC REOUEST:

I+ Control Room Heat-Un Aiialysis mas described in CP&L's request of November 6,1997, temporary condensing units will be 1 erected outside of the Control Building. Since the temperatures are generally cool dming the

' time period for which the NRC approval is requested, the cooling load will not be extensive and E f will not be difficult to maintain. The temporary cooling units will not be seismically mounted or

• qualified nor protected from high winds and tornado missiles. Therefore, in the unlikely event of

.a design basis earthquake (DBE) or tornado during the nine weeks that the temporary o .s will Lbe used, that resulted in loss of the temporary cooling units, the temperature of the Control Room will be maintained by opening doors and increasing the ventilation rate. The temporary cooling a meaures for the Control Room would violate the Control Room pressure boundary. This would require both units to shut down under the Limiting Condition for Operation Action statement.

h El-1

The analysis for the complete rupture of the chlorine car shows that the cloud, including the liquid spill, dissipates to below levels of concern in less than three hou;s. The temporary cooling measures can be delayed by at least this amount of time without affecting the operability of Control Room equipment. For other chlorine releases, the specific conditions of atmospheric chlorine concentration, wmd direction, c.ispersion, and duration of event must be considered if a chlorine system break occurs in conjunction with a seismic event and required use of the temporary measures for Control Room cooling, the Control Room operators could don SCBAs.

Calculation Number OVA-0104 contains a transier mperature analysis for selected areas of the Control Building, during a specified time period folio sing a postulated loss-of-coolant accident (LOCA) without a concurrent loss of offsite power event. A copy of Calculation Number OVA-0104 is provided in Enclosure 2.

CP&L has prepared another Control Building transient temperature analysis for typical seasonal temperatures rpplicable to the period covered by the license amendment requests. This analysis is documented in Calculation No. OVA-0114, " Control Building Transient Temperature Analysis During Spring Conditions," a copy of which is provided in Enclosure 3. The analysis confirms that, for a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> period following a postulated loss of temporary Control Room air conditioning equipment during the months of February through May, Control Room habitability for personnel and equipment can be maintained (i.e., the central Control Room remains below 100* F). The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> period provides adequate time for the units to achieve safe shutdown (i.e.,

liot Shutdown) and the alternative Control Room cooling measures.

Self-Contained Breathine Apparatus

~

As described in CP&L's request of November 6,1997, during the time period when the ductwork -

is breached such that the Con'rol Room pressure boundary is no longer OPERABLE (i.e.,

16 days total), a temporary barrier will be erected in the duct to preserve the leakage characteristics of the duct. During this time period, the chlorine tank car will be removed from the exclusion area; therefore, a toxic gas release event is not a consideration. Radiation events or o!Tsite fires resulting from a seismic event can be postulated as a hazard to Control Room personnel. If hazardous conditians exist, Control Room personnel would don SCB As. The Abnormal Operating Procedure for an Earthquake is being revised to direct SCBA use in the event of an earthquake in conjunction with a radiation or smoke hazard to the Control Room.

During the nine week period while temporary condensing units are used for Control Room cooling, the temporary cooling units will not be seismically mounted or qualified nor will the units be protected from high winds and tornado missiles. Therefore, a tomado or other severe wind could damage one or more of the temporary condensing units. In addition, a tornado or scismic event could result in a chlorine system leak or rupture of the chlorine tank car. As noted in the November 6,1997 submittal, a complete rupture of the chlorine tank car shows that the cloud, including the liquid spill, dissipates to below levels of concern in less than three hours.

As demonstrated by the transient temperature analysis provided in Enclosure 3, temporary cooling measures can be delayed for this amount of time. If a chlorine system break were to occur, the transient temperature analysis demonstrates that sufficient time is available to achieve El-2

safe shutdown befcre temporary Control Room cooling measures would be necessary. Should chorine conditions persist after this time, Control Room personnel could don SCBAs.

Plant procedure OAOP-34.0, " Chlorine Emergqncies ' provides instructions on the actions necessary due to the occurrence of a chlorine emergency. A copy of procedure OAOP-34.0 is provided in Enclosure 4. If SCBAs are required to be worn, the procedure directs the Shift Superintendent to coordinate with Fire Brigade personnel to have additional SCBAs brought to the Control Room. As noted in procedure OAOP-34.0, the emergency kit inventory for the Control Room includes a total of 15 SCBAs (i.e., nine SCBAs for Control Room personnel, one SCBA for the Security Central Alarm Station, and five spares). In addition to the Control Room SCBA inventory,24 SCBAs are stored in the Operational Support Center,10 SCBAs are stored in the Technical Support Center, and eight SCBAs are stored for post-accident sampling, as part of the emergency kits for these facilities. Approximately 60 additional SCBA bottles are stored and available in the site fire house.

Plant procedure OPEP-04.6, " Radiological Emergency Kit Inventories," provides a method for validating, on a monthly frequency, the inventories of emergency supplies and equipment in the Control Room, Operational Support Center, Technical Support Center, and post-accident sampling erc.ergency kit. A copy of procedure OPEP-04.6 is provided in Enclosure 5.

Plant procedures exist for operation of the SCBA refill system (i.e., procedure 0FPP-038,

" Operation of the SCBA Refill System") and the selection, issuance, use, maintenance, and inspection of SCB As (i.e., procedure 0FPP-039, "SCB A Use and Maintenance"). In addition, section 3.2 of procedure 0FPP-038 reflects a mutual aid agreement with the Long Beach Fire Department whereby that fire department's compressor and portable cascade system can be used as an alternate SCBA air compressor. Copies of the plant procedures 0FPP-038 and 0FPP-039 are provided in Enclosures 6 and 7, respectively.

On-shift licensed operators are qualified and trained regarding the use of the SCBAs. Annual training requirements for licensed operators include the donning and wearing of an SCBA to demonstrate proper usage. To provide insights regarding the donning and use of SCBAs by licensed operators while serving on shifl, a crew of BSEP operatore will be observed in a simulator scenario. The results of the observed scenario, along with any insights related to SCBA donning and performance, will be communicated to the on-shift licensed operators prior to standing watch while the Control Room ventilation system upgrade modifications are being installed.

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Document Control Desk -

- BSEP 98-0017 / Page 3 cc (with Enclosures 1 and 3 only):

U. S. Nuclear Regulatory Commission, Region 11 ATTN: Mr. Luis A. Reyes, Regional Adminirirator Atlanta Federal Center

- 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303 -

U. S. Nuclear Regulatory Commission ATEN: Mr. Charles A. Patterson, NRC Senior Resid:nt inspector  ;

8470 River Road Southport, NC 28461-8869 The Honorable Jo A. Sanford Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

- Mr. Mel Fry Director - Division of Radiation Protection -

North Carolina Department of Environment, Health, and Natural Resources

-~ 3825 Darrett Drive I Raleigh,NC 27609-7221 cc (with all enclosures):

U. S. Nuclear Regulatory Commission

- ATfN: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738-

Document Control Desk I BSEP 98-0017 i Page 2 WRM/wrm

Enclosures:

1. Response to Request For AdditionalInformation

2. Calculation Number OVA-0104, " Control Building Transient Temperature Analysis"

3. Calculation Number OVA-0114 " Control Building Transient Temperature Analysis Curing Spring Conditions"

4. Pla nt Procedure OAOP-34.0, " Chlorine Emergencies"

5. Plant Procedure OPEP-04.6," Radiological Emergency Kit Inventories" 6 Plant Procedure 0FPP-038, " Operation of the SCBA Refill System"

7. Plant Procedure 0FPP-039, "SCBA Use and Maintenance" C. S. Ilinnant, having been first duly sworn, did depose and say that the infonnation 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.

Ouuv cs5. n1a A \

Notary (Seal) I My commission expires: boh ? l; OD l

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