ML19338D552

Forwards Proposed Revisions to Tech Specs,Implementing Changes Requested by NRC Re TMI Lessons Learned Requirements.Proposed License Conditions Encl

ML19338D552
Person / Time
Site:	Brunswick
Issue date:	09/16/1980
From:	Utley E CAROLINA POWER & LIGHT CO.
To:	Ippolito T Office of Nuclear Reactor Regulation
Shared Package
ML19338D553	List: ML19338D552 ML19338D554
References
NO-80-1355, NUDOCS 8009230438
Download: ML19338D552 (4)

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Cp&L Carouna Power & Light Company September 16, 1980 FILE: NG-3514(B)

SERIAL NO.:

NO-80-1355 i

Office of Nuclear Reactor Regulation ATTENTION:

Mr. T. A. Ippolito, Chief Operating Reactors Branch No. 2 United States Nuclear Regulatory Commission Washington, D. C.

20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPit-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENT - CATEGORY "A" LESSONS LEARNED ITEMS

Dear Mr. Ippolito:

In accordance with the Code of Federal Regulotions, Title 10, Part 50.90 and Part 2.101, Carolina Power & Light Company (CP&L) hereby requests revisions to the Technical Specifications and the Operating Licenses for its Brunswick Steam Electric Plant (BSEP) Unit Nos. 1 and 2.

The attached revisions to the Operating Licenses and Technical Specifi-cations for the Brunswick units implement the changes requested by D. G. Eisenhut's letter of July 2, 1980, concerning Category "A" Lessons Learned items. Although CP&L does not agree with the finding of the Staff concerning the applicability of license fees for these revisions (

Reference:

D. G. Eisenhut's letter of August 7, 1980), our check for $4,400 is attached for one Class III and one Class I amendment.

The enclosed revisions provide Technical Specifications, as requested, for Safety-Relief Valve Position Indications and in the area of shift manning to reflect the augmentation of the Shift Technical Advisor. As agreed to in a telephone conversation with your staff on September 2,1980, CP&L will submit revised Technical Specifications in the area of Containment Isolation by December 31, 1980. Mr. Eisenhut's letter of July 2, 1980 requested Technical Sepcifications in the area of Emergency Power Supply / Inadequate Core Cooling. CP&L has determined that the existing Technical Specifications for the Brunswick Units adequately address this subject and therefore, no revisions are proposed for that area.

Requested changes to the Technical Specifications are indicated by a vertical bar in the right-hand margin on the attached replacement pages.

Mr. Eisenhut's letter of July 2, 1980 also requested that the Operating Licenses for the~ Brunswick Units be amended to include license conditions related to a System Integrity Measurements Program and Improved Iodine Measurements capability. The requested proposed license conditions are attached. As before, changes are indicated by vercical bars in the right-hand margin.

Altbough CP&L has provided'the requested revisions to the Brunswick Operating Licenses and Technical Specifications, we believe that the NRC needs to recognize the prototypical state of some of the' Lessons Learned items.- In Mda 5 4, o,.,,... e,.... m m,. ~.- c. mm B)09230 N.

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Mr. Ippolito many cases, sufficient operating experience has not been accrued or time elapsed to develop adequate spare part supply chains or maintenance procedures to maintain the equipment at the required reliability. This is especially true at Brunswick in the area of Safety-Relief Valve position indications but will also apply to several Categcry "B" items. We feel that in the cases of prototypical equipment a minimum of one year's operating experience should '>e allowed prior to the formal imposition of Technical Specifications, and that the Technical Specifications should only be imposed after consulting with the' licensee as to the status of operating experience, spare parts, and technical information on the equipment.

In return the licensee should be pledged to a best effort approach from the time of installation of the equipment to obtain the required spare parts and technical information. We would welcome further discussion with you on this subject.

If you have any questions regarding this request, please contact my staff.

Yours very truly, 4]

E. E. Utley Executive Vice President Power Supply and Engineering & Construction JJS/dk Attachments cc:

J. P. O'Reilly (NRC-RII)

Sworn to and subscribed before me this 16th day of September, 1980 Notary Public 9"

4 My Commission expires:

October 4, 1981

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I aJPOSED. LICENSE CONDITIONS FOR OPEknTING LICENSE NO. DPR-71 2.I.

Systems Integrity The licensee shall impicment a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transicut or accident to as low as practical levels. This program shall include the following:

1.

Provisions establishing preventive unintenance and periodic visual inspection requirements, and 2.

Integrated leak test requirements for each system at a frequency not to exceed refueling cycle intervals.

2. J.

Iodine Monito g The licensee shall implement a program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

1.

Training of personnel, 2.

Procedure..or monitoring, and 3.

Provisions for maintenance of sampling and analysis equipment.

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' PROPOSED LICENSELCONDITIONS FOR OPERATING LICENSE NO. DPR-622 t

I, P-3 2. F. ' iSystems Integrity 1Thelicensce[siiall?impleme..'a-vogramtorsduce'leakagefromsystems.outside '

c9ntainment that would orTcould_contain highly-radioactive fluids..during a.,

. serious; transient or. accident.tolas-low as practical levels.: This program shalliinclude.~the-following:

~

li Provisions establishing preventive maintenance and periodic visual'

' inspection requirements, and

Integratied lehk~. test. requirements for each system at-a frequency 2.

' not to exceed refueling cycle intervals.

2. C.,

'Io' dine Nonitoring

-The licensee'shall-implement a program which'will ensure the capability to

' l a'ccurately determine the airborne'iod.ine concentration in vital areas under accident conditions. 1This program shall include the following:

i ~ Training of personnel,

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Procedures for monitoring, and 3.-

. Provisions for maintenance of sampling and analysis equipment'.-

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