ML19345E216

Forwards Commitments for Completion of Items in NUREG-0737, Clarification of TMI Action Plan Requirements, in Response to 801031 Request

ML19345E216
Person / Time
Site:	Brunswick
Issue date:	12/15/1980
From:	Utley E CAROLINA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.27 NO-80-1873, NUDOCS 8012230470
Download: ML19345E216 (22)

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December 15, 1980 File: NG-3514(B)

Serial No.:

N0-80-1873 Mr. Darrell G. Eisenhut, Director Division of Licensing 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. DPR-71 AND DFR-62 POST TMI REQUIREMENTS CONTAINED IN NUREC-0737

Dear Mr. Eisenhut:

As requested by your letter of October 31, 1980, Carolina Power & Light Company (CP&L) hereby forwards its commitments for comple-tion of the items contained in NUREG-0737, " Clarification of TMI Action Plan Requirements" which are applicable to the Brunswick Steam Electric Plant (BSEP). Enclosure 1 contains a listing of the items potentially applicable to Brunswick, the NRC requested schedule, and CP&L's commit-cent. Where CP&L's schedule is different from that requested, an attach-ment to Enclosure 1 has been provided. These attachments clarify CP&L's position on certain items or justify a schedule which differs from the one requested.

We believe that a number of the items required by your letter may require further definition of the requirements and acceptance criteria through discussions with NRC Staff.

If this should cause a change in scope of the items that could impact the Dnplementation schedule for Brunswick, we will inform you promptly so that any problems associated with implementation may be resolved to cur mutual agreement. As part of these discussions, and following a comprehensive review of the require-ments, CP&L may wish to propose alternatives to the strict interpretation of some requirements. Such alternatives may include: a) modifications other than those suggested by the requirement which are of equal or greater safety improvement; b) design and test of hardware modifications on a single typical plant followed by implementation on remaining plants; c) exception to some requirements whose implementation is believed unnecessary. Additionally, implementation of plant modifications may be dependent on availability of equipment and purchasing lead time.

It is our intent to work on the study, design, engineering, procurement, and construction of these items in a manner that will reduce or eliminate k

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these concerns; however, if equipment availability becomes a problem 1

that will unavoidably delay implementation of any requirement, we intend to petition for relief of the implementation schedule. Finally, you should realize that these requirements place a significant strain on CP&L's and the industry's resources. We hope that this is recognized by you and the remainder of the NRC Staff, and that you will work with us where necessary to ensure that correct implementation of the requirements are made only to increase the overall safety of the Brunswick Plant.

i We trust this letter is responsive to your requirements at this time, and stand prepared to provide additional information if you l

so desire.

Yours very truly,

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j Executive Vice President Power Supply and Engineering & Construction JJS/je (4173)

Attachments 8

cc:

Mr. J. N. Hannon (NRC)

Sworn to and subscribed before me this 15th day of December 1980 Notary Public I

My commission expires: October 4, 1981 s

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BRUNSW1CK POST Titi REQUIREt1ENTS PER NtJREG 0737 NRC iMPLE-LICENSE 11ENTAT10N SUBillTTAL ITEli TITLE DESCRIPTION SC11EDULE REQUESTED BY CP&L Cott?tIR1ENT REFERENCES 1.A.I.1 Shift Technical

3. Trained per LL Cat B 1/1/81 1/1/81 1/1/81 advisor

4. Describe long-term 1/1/81 1/1/81 1/1/81 program I.A.I.3 Shift manning

2. Min shift crew 7/1/82 11/1/80 Shift rianning -

CP& L l t r. 11/5/80 Complete See Attachment 11 I.A.2.1 Immediate upgrading

2. SR0s be R0s 1 yr 12/1/80 None Complete of RO and SRO training and qualifications I.A.3.1 Revise scope and

3. Simulator exar,a 10/1/81 None 10/1/81 criteria for licensing exams I.C.1 Short-term accident

2. Inadequate core and procedures cooling review

a. Reanalyze and 1/1/81 1/1/81 1/1/81 propose gui.lelines

b. Revise procedures First TBD First refueling refueling outage after outage after 1/1/82 1/1/82

3. Transients & accidents

a. Reanalyze and 1/1/81 1/1/81 1/1/81 propose guidelines

b. Revise procedures First TBD First refueling refueling outage after outage after 1/1/22 1/1/82

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I NRC IMPLE-LICENSE MDITATION SilBMITTAL I

ITDI TI1LE DESCRIPTION SCIID)ULE RB)U ESTU) BY CP&L COMMI1NENT REFERDJCES I

-I.C.5 Feedback of operat-Licensee to implement 1/1/81 None 1/1/81 l

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ing experience procedures t

l I.C.6 Verify correct per-Revise performance 1/1/81 None CP&L Position by At tachment 12 i

formance of operat-procedures 1/1/81 f

ing' activities i

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I.D.1 Control-room design Preliminary assessment TM) 4/82 See At tachment I

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reviews and schedule for cor-t I

recting deficiencies I

i I.D.2 Plant-safety-

1. Description ThD Later

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parameter display

2. Installed TBD console

3. Fully implemented TBD 2

i I1.B.1 Reac to r-coolant-

1. Design vents 7/1/81 1/1/81 7/1/81 At tachment 2 r

l system vents

2. Install vents 7/1/82 7/1/81 NA CP&L ltr. 12/31/79 (LL Cat B)

3. Procedures 1/1/82 1/1/81 1/1/82 i

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I I. B.2 Plant shielding

2. Plant modifications 1/1/82 1/1/81 Documentation 1/1/81 t

(LI. Cat B)

(Deviation only) Modifications 1/1/82

3. Ecluipment qualif t-6/30/82 1/1/82 Consistent with IE

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catton Bulletin 79-01B I1.B.3 Postaccident

2. Plant modificattons I/1/82 1/1/81 Documentatton I/1/81 I

sampling (LI. Cat B)

(Deviation only) Modifications 1/1/82 i

I I. B.4 Training for

1. Develop training 1/1/81 1/1/81 1/1/81

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f mitigating core program j

damage

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f l NRC IMPLE-LICENSE MENTAT10N SUBttlTTAL ITEM TITLE DESCRIPTION SCHEDULE REQUESTED BY CP&L COttMIDtENT REFERENCES II.B.4

2. Implement program (Cont'd) a.

Initial 4/1/81 4/1/81

b. Complete 10/1/81 10/1/81 II.D.1 Relief & safety-

2. RV & SV testing i

valve test require-(LL Cat B) ments

a. Complete testing 7/1/81 7/1/81 See Attachment 3

b. Plant-specific 10/1/81 1/1/82 report II.E.4.1 Dedicated hydrogen

2. Install 7/1/81 7/1/81 Unit 1 - Early 1982 penetrations Refueling Outage 1

Unit 2 - Late 1981 Refueling Outage I

II.E.4.2 containment

5. Cntmt pressure isolation setpoint dependability

a. Specify 1/1/81 1/1/81 1/1/81 pressure

b. Modifications 7/1/81 1/1/81 None Planned

6. Cntmt purge valves 1/1/81 1/1/81 1/1/81

7. Radiation signal on 7/1/81 7/1/81 7/1/81 purge valves

8. Tech. Specs.

12/15/80 9/1/80 4/1/81 CP&L ltr. 9/16/80 II.F.1 Accident-monitoring

1. Noble gas 1/1/82 1/1/81 Documentation 3/l/81 Submittal Implementation 1/1/82 if deviation from position

2. Iodine / particulate 1/1/82 1/1/81 Documentation 3/1/81 sampling Submittal Implementation 1/1/82 if deviation from position

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i NRC IMPLE-LICENSE HENEATION Stint 1ITTAL l

ITEM TITLE DESCRIPTION SCllEDULE REQUESTED BY CP&L CottHITMENT REFERENCES i

II.F.1 Accident-monitoring

3. Containment high-1/1/82 7/1/81 Documentation 7/1/81 (continued) range monitor Submittal Implementation 1/1/82 if deviation I-from position

4. Containment pressure 1/1/82 1/1/82 1/1/82 L

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5. Containment water 1/1/82 1/1/82 Unit 1 - Early 1982 CP&L ltr. of i

level Refueling Outage 12/12/80 i

linit 2 - Late 1981 Refueling Outage t

6. Containment hydrogen 1/1/82 1/1/82 Unit 1 - Early 1982 3 Refueling Outage 4

Unit 2 - Late 1981

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Refueling Outage i

II.F.2 Instrumentation for

3. Install level 1/1/82 1/1/82 Complete CP&L ltr.of l

detection of in-instruments 12/31/79 adequate core (LL Cat B) cooling j

II.K.3 Final recommen-

3. Reporting SV & RV 1/1/81 1/1/81 1/1/81 j.

dations, B&O task failures & challenges force

13. IIPCI & RCIC init I

levels

a. Analysis 1/1/81 1/1/81 1/1/81

b. Modify 7/1/81 1/1/81 Documentation 1/1/81 Attachment 6 1

15. Isolation of IIPCI &

7/1/81 1/1/81 Documentation 1/1/81 Attachment 6 1

1 RCIC modification

16. Challenges & failures i

to relief valves

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a. Study 4/1/81 4/1/81 4/1/81 4

b. Modify 1st refuel 4/1/81 Documentation 4/1/81 Attachment 6 l

or 1 yr af ter

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17. ECC system outages 1/1/81 1/1/81 1/1/81 l

18. ADS actuation j

a. Study 4/1/81 4/1/81 4/1/81 j

b. Propose 4/1/82 4/1/82 4/1/82

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c. Modification 1st refuel See Attachment 6 6 mo after staff approval I

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. NRC IMPLE-LICENSE 1

MENTATION SUBMITTAL f

ITEM TITLE DESCRIPTION SCHEDULE REQUESTED bY CP&L COMMI1HENT REFERENCES II.K.3 Final reconunen,

21. Restart of CSS &

dations, B&O task LPCI force (continued)

a. Design 1/1/81 1/1/81 1/1/81

b. Modification 1st refuel 1/1/81 Documentation 1/1/81 A::tachment 6 6 mo after staff approval

22. RCIC suction

a. Verify procedures 1/1/81 1/1/81 1/1/81 i,

b. Modification 1/1/82 1/1/82 Unit 1 - Early 1982 4 Refueling Outage Unit 2 - Late 1981 Refueling Outage

24. Space cooling for 1/1/82 1/1/82 1/1/82 HPCI/RCIC modification

25. Power on pump seals

a. Propose mods 7/1/81 7/1/81 7/1/81

b. Modifications 1/1/82 1/1/82 See Attachment 6

27. Common ref. level 7/1/81 1/1/81 7/1/81

28. Qual of ADS 1/1/82 1/1/82 1/1/82 accumulators

30. SB LOCA methods

a. Schedule outline 11/15/80 11/15/80 Not Applicable CP&L Ltr. 12/4/80

b. Model 1/1/82 1/1/82

c. New analyses 1/1/83 or 1/1/83 or 1 yr after 1 yr af ter staff staff approval approval

31. Compliance with CFR 1/1/83 or 1/1/83 See Attachment 9 50.46 1 yr after staff approval

44. Eval transient with 1/1/81 1/1/81 1/1/81 single failure t

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NRC IMPLE-LICENSE i

MENTATION SU BMITTAL I

' ITEM TITLE DESCRIPTION SCHEDULE RIT}UESTED BY CP&L COMMI'INENT REFERENCES II.K.3 Final recommen-

,.s. Manual depres-1/1/81 1/1/81 I/1/81 l

dations, B&O task surization 3

force (continued)

57. Manual act of ADS TIM)

TBD III.A.I.2 Upgrade emergency

2. Design Tiu)

TBD support facilities

3. Modifications TBD TBD III.A.2 Hnergency

1. Upgrade emergency 4/1/81 1/2/81 1/2/81 3

l preparedness plans to App. E.

10 CFR 50

2. Meteorological data 6/1/83 1/2/81 See Attachment 10 I

III.D.3.3 Inplant radiation

2. Modifications to 1/1/81 1/1/81 1/1/81 monitoring accurately measure 12 i

III.D.3.4 Control-room

1. Review 1/1/81 1/1/81 1/1/81 j

habitability

2. Modificatton I/1/83 1/1/81 Documentatton 1/1/81 Implementatica 1/1/83 I

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ATTACHMENT 1 Item I.D.1 - Control Room Design Review Carolina Power & Light Company (CP&L) will commit to a schedule to perform this review upon receiving finalized criteria and requirements from the NRC.

Until then, no schedular commitments can be made.

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ATTACRMENT 2 Item II.B.1 - Reactor Coolant System Vents In accordance with the discussion on reactor coolant system vents contained in our submittal of December 31, 1979, no additional venting capability is required due to the inherent capability already contained in the Brunswick plant. However, additional information was requested of the GE BWR Owners' Group on this subject in a letter from Mr. T. M. Novak dated September 10, 1980. CP&L will work with the Owners' Group on this item and will submit the requested information on hydrogen concentrations inside containment prior to July 1, 1981. With regard to procedures for venting, emergency procedure guidelines, containing the necessary guidelines for venting, have been developed and submitted for review and approval. We propose that implementation of any venting procedures be integrated with the general emergency procedures implementation requirement of Item I.C.I.

Until that time current procedures governing the operation of high pressure ECCS systems assure that adequate venting of noncondensibles will occur.

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j ATTACmiENT 3 i

Item II.D.1 - Relief & Safety Valve Test Requirements With regard to this item, Carolina Power & Light Company is a member of i

the BWR Owners' Group committee which is developing and performing the test program for the valves. The test program was described in a submittal dated i

September 17, 1980, from D. B. Waters, Chairman of the Owners' Group, to D. G.

j Eisenhut. We program is a low-pressure test program, and the actions of Item II.D.1 will be completed for this program in accordance with the NRC's j

implementation schedule. He need for high pressure liquid and two-phase testing of the valves is under review by NRC, and it is our understanding, i

based on an executive meeting between the Owners' Group and NRC on October 22, 1980, that the schedule for any additional testing that may be required as a I

result of that review will be established at a later date. Based on this understanding, Carolina Power & Light Company commits to the implementation and submittal dates contained in item II.D.1 for the low-pressure test program

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ATTACHMENT 4 Item II.E.4.1 - Dedicated Hydrogen Penetrations The modifications required to meet this item require several weeks of outage time.

Current delivery for required neu valves are projected for the fall of 1981 and are being hampered by the equipment qualification requirement to meet IEEE-323-1974 Current outage forecasts call for outages at Brunswick as follows:

Unit 2 - Late 1981 Unit 1 - Early 1982 Because of the outage time required to make these modifications, CP&L has chosen to install these changes during scheduled maintenance or refueling outages consistent with the present equipment delivery projections.

CP&L believes that this deferral is justified due to Brunswick having presently installed an operable hydrogen control system (CAD System) that has previously been reviewed and approved by the NRC as part of the licensing base for the plant. The proposed modifications are merely providing an upgrade to the present approved system.

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ATTACIC!ENT 5 Item II.E.4.2 - Containment Isolation Dependability In its January 1,1981 submittal, CP&L intands to justify appropriateness of the present containment pressure setpoint.

With regard to Technical Specifications, phone conversations between CP&L and the l'RC on September 2,1980 and CP&L's letter of September 16, 1980 committed to provide Technical Specification changes consistent with the reevaluation of the Containment Isolation Valve ISI Program, then expected to be completed in December 1980. The completion date of that reevaluation has now been extended to March 1981 and has been approved by the Region II office of Inspection & Enforcement. Therefore, CP&L will provide Technical Specification changes by April 1,1981, consistent with completion of the above evaluatien.

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I ATTACINENT 6 J

i Item II.K.3 - Final Recommendations of the B&O Task Force A number of items under II.K.3 require an analysis or study to be 4

j performed, the proposal of modifications, if required, and then implementation i

of the changes.

For these items, CP&L will commit to perform the required studies / analyses and make the required modification proposals in accordance 1

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with the NRC schedule. CP&L, however, cannot commit to performing modifications whose scope has not been determined or which may require j

scheduling consistent with planned maintenance or refueling outages. Upon completion of the required studies / analyses, CP&L will work with the NRC to schedule in a timely manner any required modifications.

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ATTACIDiENT 7

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Item II.F.1 - Additional Accident-Monitoring Instrumentation 1.

Noble _Ms Effluent Monitor -Due to changes imposed by NUREG 0737, the.equired documentation of the final design details will not be atailable until March 1, 1981. Any deviations from the NRC

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requirements will be documented at that time. Tha system will be i

installed by January 1, 1982. Since this is a post-implementation review iten, as indicated in Enclosure 1 of NUREG 0737, the delay in 4

submittal of information is not deemed significant.

2.

Iodine / Particulate Sampling - Due to changes imposed by NUREG 0737, the required documentation of the final design details will not be available until March 1, 1981. Any deviations from the NRC requirements will be documented at that time. The system will be installed by January 1, 1982.

Since this is a post-implementation review item, as indicated in Enclosure 1 of NUREG 0737, the delay in i

submittal of information is not deemed significant.

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ATTACle!ENT 8 Item II.K.3.27 - Common Reference Level for Vessel Level Instrumentation This item requires a post-implementation review.

Therefore, providing documentation on the item six months prine to accomplishing it is inconsistent. CP&L will provide the required documentation upon completion of the modification.

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ATTACRMENT 9 Item II.K.3.31 - Compliance with 10CFR 50.46 CP&L cannot commit to the schedule for this item untti the results of Item II.K.3.30 are known. As stated in our letter of December 4, 1980, Item II.K.3.30 is strictly the purview of the NS3S vendor and therefore we have no control over it or its schedule. Upon completion of Item II.K.3.30 by the NSSS vendor, CP&L will work with the NSSS vendor and NRC to provide any required analysis in a timely manner.

ATTACEFiENT 10 Item III. A.2.2 - Meteorological Data To date, CP&L has not received the finalized versions of NUREG 0654,

" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" or NUREG 0696,

" Functional Criteria for Emergency Response Facilities."

There fore, CP&L cannot commit to the schedule provided. Upon receipt of the above documents and after appropriate time to analyze them, CP&L will work with the NRC to provide the required capabilities in a timely manner.

ATTACHMENT 11 Item I.A.1.3 - Shift Manning As stated in Carolina Power & Light Company's letter of November 5, 1980, Brunswick meets the shif t manning requirements outlined in D. G. Eisenhut's letter of July 31, 1980 by July 1, 1982. Additionally, CP&L has adopted an overtime policy generally consistent with the concerns expressed in the July 31, 1980 letter. CP&L, however, believes that some details of the overtime restrictions as stated in NUREG 0737 are overly prescriptive, detrimental to an orderly life for our personnel and potentially harmful to safety. Therefore, CP&L will address these items in detail in a submittal to the NRC by January 15, 1981 and propose specific alternatives to those requirements expressed in NUREG 0737.

P ATTACRMENT 12 Item I.C.6 - Verify Correct Performance of Operating Activities This item is a new item not previously required of operating plants, and requires detailed study to assess the impact of requirements on plant operating practices. Therefore, CPSL cannot commit to full implementation by January 1, 1981.

CP&L, however, will provide by January 1,1981 a description of measures being performed at Brunswick in this area and CP&L's position on the remaining portions of the item.

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ATTACHMENT 13 Item II.F.1.6 - Containment Hydrogen Brunswick currently has eso post accident hydrogen / oxygen analyzers installed on each unit as part of the containment atmosphere monitoring subsystem.

Replacement of these monitors is being pursued as a reliability improvement.

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Installation of the new monitors will require an outage. Since delivery is not scheduled until the summer of 1981, CP&L has elected to install the new monitors during the first scheduled outage of sufficient duration. As currently scheduled these outages are:

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ATTACIUiENT 14 Item II.K.3.22 - Automatic Switchover of RCIC Suction 1

!!odifying RCIC to provide for auto-switchover of pump suction from the condensate tank to the suppression pool will require RCIC to be removed from service. CP&L has elected to perform this work during the following outages:

Unit 2 - Late 1981 Unit 1 - Early 1982 Since the switchover is c arrently addressed in plant emergency procedures and can be performed from the Control Room, CP&L does not feel that the modification warrants the reduction in safety margiu associated with doing the modification while operating with RCIC out of service (LCO).

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