ML20046A306

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Provides Addl Info Re 921231 Application for Amends to Licenses DPR-62 & DPR-71,revising TS 3.7.1.2,in Response to Issues Raised by NRC During 930617,30 & 0707 Telcons
ML20046A306
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/20/1993
From: Richard Anderson
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046A307 List:
References
BSEP-93-0112, BSEP-93-112, NUDOCS 9307270219
Download: ML20046A306 (9)
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Text

{{#Wiki_filter:w  :- e q L CP&L Carolina Power & Light Company P o. Box 10429 southport, NC 28461 

                                                'JUL 2 01993 SERIAL: BSEP 93-0112 RoY A ANDERSON                                                            10 CFR 50.90 TSC 91TSB07 BrunUxNcfe Yetant I    United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCNET NCE 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62                                                _

t RESONSE iG REQUEST FOR ADDITIONAL INFORMATION SEFtICE WATER SYSTEM LICENSE AMENDMENT REQUEST Gentlemen: The purpose of this letter is to provide the NRC staff additional information regarding the Service Water System Technical Specification Amendment request for Carolina Power & Light Company's (CP&L) Brunswick Steam Electric Plant (BSEP), Units 1 and 2. On December 31,1992, CP&L submitted a request for a license amendment to Technical Specification 3.7.1.2, Service Water System, for the BSEP. On June 17,1993, June 30,1993, and July 7,1993, conference calls were held betwe3n CP&L and the NRC staff to discuss NRC staff issues raised concerning the December 31,1992 submittal. Enclosure 1 provides the CP&L response to the issues raised by the NRC staff during those conference calls. Three additional revisions are being made with respect to the December 31,1992 submittal. Administrative changes are being made to the Technical Specification pages previously submitted in order to reflect recent amendments to the Technical Specifications which involved the same pages. The second change involves adding a quarterly surveillance of the pressure switch logic and valve actuation capabil ty associated with the service water supply to the diesel generators (4.7.1.2.c). In addition, an administrative change is being made to provide the operators direction to the specific requirements of inocerable equipment in lieu of directing the operator to declare the systems inoperable. Enclosure 1 contains a discussion of the basis for these changes. Enclosure 2 provides revised page change instructions for incorporating the proposed amendment. j These instructions supersede those instructions provided in the December 31,1992 submittal. 4 Enclosure 3 provides mark-ups of the December 31,1992 submittal Technical Specification pages for Unit 1, reflecting the changes being made in this submittal. Enclosure 4 provides mark-ups of the December 31,1992 submitto Technical Specification pages for Unit 2, reflecting the changes being made in this submittal. Enclosure 5 provides typed Technical Specification pages for Unit 1. T Enclosure 6 provides typed Technical Specification pages for Unit 2. Carolina Power & Light Company is providing, in accordance with 10 CFR 50.91(b), Mr. Dayne H.

  • Brown of the State of North Carolina with a copy of this submittal.
                               ~

9307270219 930720 [ PDR ADDCK 05000324 P PDR U@

7 f Document Control Desk BSEP 93-0112 / Page 2 Please refer any questions regarding this submittal to Mr. W. Levis at (919) 457-2404. Yours very truly, 6(_. Ro A. Anderson v 

    ' KAH/kah (bsep930112.wpf)

Enclosures:

1. Disposition of NRC Staff issues
2. Page Change instructions
3. Marked-up Technical Specification Pages - Unit 1
4. Marked-up Technical Specification Pages - Unit 2
5. Technical Specification Pages Unit 1
6. Technical Specification Pages - Unit 2 H Attachments:
1. Hydraulic Analysis Report (contains G0050A-16, Rev.1, and G0050A-18, Rev. 0)
2. - Analysis for Tech Spec 3.7.1.2 Proposed Change (0SW-0048, Rev. 0)
3. Unit 2 Hydraulic Analysis (G0050A-12, Rev. 5)
4. Unit 1 Hydraulic Analysis (G0050A-10, Rev. 5)

Roy A. Anderson, 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. k skA 1, TKv0dh My commission expires: Oup /J, nf & cc: Ms. P. D. Anderson Mr. Dayne H. Brown Mr. S. D. Ebneter Mr. P. D. Milano Mr. S. R. Jones Mr. R. L. Prevatte - b C'-- -

pa c ENCLOSURE 1 BSEP 93-0112 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 1 NRC DOCKET NOS. 50-325 & 50 324  ; OPERATING LICENSE NOS. DPH-71 & DPR-62 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SERVICE WATER SYSTEM LICENSE AMENDMENT REQUEST  ; DISPOSITION OF NRC STAFF ISSUES  ! NRC STAFF ITEM 1:

\

Provide justification for the relaxation from the current licensing basis (which requires two (2) nuclear service water pumps be OPERABLE for an cperating unit) without implementing a sixty-day Limiting Condition for Operation (LCO) during the condition where three (3) site nuclear service water pumps are OPERABLE. i CP&L RESPONSE: l During the June 17,1993, June 30,1993, and July 7,1993, conference calls held between CP&'. and the NRC staff, the NRC staff raised a concern that operation of the Brunswick facility with three site nuclear service water (NSW) pumps OPERABLE was less reliable than operation with two (2) NSW pumps OPERABLE on an operating unit. Although the risk associated with this operation was not considered to be significant, the NRC staff contends that the risk associated with the three OPERABLE site NSW pump configuration for an extended period of time is not negligible; therefore, the NRC staff believes that a sixty-day LCO for operation of a Brunswick unit ' with one NSW pump out-of-service is necessary. The basis for the NRC staff considering that a reduction in reliability exists with the three site NSW pump configuration is that this configuration relies on automatic actions (pressure switch operation and valve operation) to maintain functional capability following a single failure (i.e., loss of the remaining NSW pump on the unit with one - NSW pump out of service). On October 11,1990, Amendments 146 and 177 were issued for Brunswick Units l'and 2-respectively. These amendments expanded the service water pump operability requirements to ensure that the system would be capable of performing its required functions under postulated accident / transient conditions. The amendments captured additional system requirements that had been implemented at Brunswick due to design deficiencies identified during a 1989 Diagnostic Evaluation Team inspection at the Brunswick Plant. Prior to these amendments, Technical Specification 3.7.1.2 required that the service water system nuclear header be OPERA 9LE with at , least three OPERABLE service water pumps. Amendments 146 and 177 were implemented as an , interim measure until the recognized design deficiencies were corrected, allowing the system to be operated in a manner consistent with the specifications in place prior to 1990. CP&L does not consider the current Technical Specifications to be reflective of the intended licensing basis of the l Brunswick Plant with respect to the Service Water System; therefore, CP&L does not believe that  ; operation of the Brunswick Plant with three OPERABLE nuclear service water pumps is a relaxation I of the licensing basis of the Brunswick Plant. l 1 CP&L further believes that there is negligible difference in the risk of loss of service water to the 

                                                                                 .                           )

diesel generators between either the three per site or 2 pumps per unit NSW pump operation J configurations. The " risk" in the three NSW pump configuration is the inability to supply service  ! water to the diesel generator jacket water coolers. More specifically, the risk is confined to the l El-1 t

i first ten (10) minutes of the postulated event, during which time no credit is taken for operator action (e.g., manual valve manipulation). During this time period, one NSW pump is required for adequate service water supply and, in all cases, the jacket water inlet valve must open from its ' normally closed position. Actuation logic associated with the jacket water inlet valve must also be successful in all cases to affect delivery of service water to the jacket water coolers. From a risk perspective, the dominant contributor is the failure of the primary and backup inlet valves to open  ; on demand. Detection and actuation logic failures (e.g., pressure switches) are lower contributors to overall risk, and the failure of three NSW pumps during this time period is negligible. Using failure rate estimates based on generic and plant failure data, the failure of a motor-operated valve to open is 3E-3 per demand. The failure of actuation logic is approximately 2E-6 per demand, and the failure of a NSW pump while running is approximately 4E-6 per hour (this equates to a probability of approximately 8E-7 over a ten-minute interval). Therefore, the risk of losing service water supply to the diesel generators due to losing three NSW pumps (with the fourth out of service) is negligible, even over an extended period. In order to further enhance the reliability of the diesel generator service water supply switchover logic and valves, a quarterly functional test is t. sing added to the surveillance requirements in the service water Technical Specification (4.7.1.2.c). Given that there is a negligible increase in risk associated with the three site NSW pump operational I configuration, and the fact that the intent of the current Servica Water System Technical Specification was to provide interim measures that were necessary to cope with system design deficiencies that have now been corrected, CP&L does not believe that a sixty-day LCO for three site NSW pumps being OPERABLE is necessary. CP&L will continue to retura NSW pumps to service in an expeditious manner and does not intend to unnecessarily allow the NSW pumps to remain out of service with or without a LCO. CP&L does believe that implementation of planned maintenance / modifications that willimprove the long-term reliability of the service water system is - enhanced by not having a sixty-day time restriction. NRC STAFF ITEM 2: Modify the LCO statement for OPERATIONAL CONDITIONS 1,2, and 3 to denote a requirement for  ; ensuring that, for the unit with only one (1) OPERABLE nuclear service water pump, at least one  ; conventional service water pump on that unit must be powered from a separate emergency bus than the OPERABLE nuclear service water pump. This requirement ensures that a failure of the emergency bus supplying the OPERABLE nuclear service water pump would not render the ' remaining conventional pump on that unit inoperable. CP&L RESPONSE: ACTION statements 3.7.1.2.a.1 and 3.7.1.2.a.4 are the only instances which would allow operation with a single nuclear service water pump and a single conventional service water pump. These statements have been revised to denote the requirement to have the conventional pump powered from a separate emergency bus. Statement 3.7.1.2.a.4 has been revised as noted in the response to item 4. ACTION statement 3.7.1.2.a.1 has been revised as follows (example represents the proposed Unit 2 specification):

1. With one OPERABLE conventional service water pump:
a. Ensure that, it only one Unit 2 nuclear service water pump is OPERABLE, the OPERABLE conventional service water pump is powered from a separate El-2

k i emergency bus than the OPERABLE Unit 2 nuclear service water pump, and' 4 1

b. Restore at least one additional conventional service water pump to OPERABLE status within 7 days.  !

Otherwise, be in at least HOT SHUTDOWN within 12 hours and in COLD SHUTDOWN within the following 24 hours, 4 NRC STAFF ITEM 3: Confirm that the motor-operated valves in the service water system will operate under the , conditions expected. ' 1 CP&L RESPONSE: CP&L has confirmed that the motor-operated valves required to operata in response to the l postulated accidents are a part of the Generic Letter 89-10 MOV Program and will operate as ' required. NRC STAFF iTEk _4:  ; Eliminate the 12 hour allowance under the proposed specification ACTION statement 3.7.1.2.a.4. This allowance is not justifiable since, under postulated circumstances the service water system j would not be capable of fulfilling its design functions. CP&L RESPONSE: , The NRC staff concern with the proposed specification ACTION statement 3.7.1.2.a.4 is that j' certain service water configurations would be allowed under which a single service water pump would be all that is available to supply a unit's needs. A resultant single failure to that unit's service water pump would result in no service water to supply the unit's unshared equipment. To alleviate this concern, the 12 hour allowance under the proposed specification ACTION .  ! statement 3.'7.1.2.a.4 prior to initiating plant shutdown has been eliminated. The ACTION statement has been revised as follows 4:,mple is representative of the proposed Unit 2 i specification):  ;

4. With two OPERABLE site nuclear service water pumps and one OPERABLE conventional service water pump:
a. Ensure that at least one Unit 2 nuclear service water pump is OPERABLE, and
b. Ensure that, if only one Unit 2 nuclear service water pump is OPERABLE, the OPERABLE conventional service water pump is powered from a separate 'i emergency bus than the OPERABLE Unit 2 nuclear service water pump, and
c. Restore two conventional service water pumps or three site nuclear service 'l water pumps to OPERABLE status within 72 hours.

Otherwise, be in HOT SHUTDOWN within 12 hours and COLD SHUTDOWN within ci-3 l 

         -.                 .~           . . .                     . . - . - .     . .        .-- - .

the following 24 hours. . Upon further review of the December 31,1993 submittal, a similar concern to the concern with - statement 3.7.1.2.a.4 was identified with statement 3.7.1.2.a.2. This statement would allow a configuration of only one NSW pump supplying all of a unit's needs. A failure of the remaining service water pump would result in a loss of all service water supply for that unit's unshared equipment. To avoid this configuration, the statement is being revised as follows (example is representative of the proposed Unit 2 specificationk

2. With no conventional service water pumps OPERABLE:
a. Ensure both Unit 2 nuclear service water pumps are OPERABLE, and
b. Restore at least one conventional service water pump to OPERABLE status within 72 hours.

Otherwise, be in at least HOT SHUTDOWN within 12 hours and COLD SHUTDOWN within the following 24 hours. , The allowance of a 72 hour out of service time for each of these situations is considered acceptable considering that the system could still withstand a single failure and have service water available to the unshared equipment, provided operator action is taken after the 10 minute ' period. One additional administrative change to the Technical Specification ACTION statements associated ' with OPERATIONAL CONDITIONS 4 and 5, Specification 3.7.1.2.b has been made. The individual ACTION statements (1 through 5) were madified to either state the specific ACTION to be taken for the inoperable equipment or direct the operator to the specific ACTION statement in lieu of simply directing the operator to declare the systems inoperable. For statements 1 and 2, the required action would be to suspend all operations that have a potential for draining the reactor vessel instead of declaring the core spray and low pressure coolant injection system inoperable. Suspension of operations that have a potential for draining the reactor vessel is the ACTION required for inoperable Core Spray and low pressure coolant injection with the unit in OPERATIONAL CONDITIONS 4 and 5 (Specification 3.5.3.1.b). For statements 3,4, and 5, a - reference to the diesel generator ACTION for inoperable diesel generators in OPERATIONAL' CONDITIONS 4 and 5 is made (Specification 3.8.1). This ACTION requires the operator to suspend handling of irradiated fuel, CORE ALTERATIONS, positive reactivity changes, and operations with a potential for draining the reactor vessel. This change eases the operator burden in handliag the requirements associated with the inoperable support equipment. + a El-4

NRC STAFF ITEM 5: Provide a copy of the service water system calculations supporting the proposed amendment j request. CP&L RESPONSE: t The following calculations are being provided:

  • Hydraulic Analysis Report (contains G0050A-16, Rev.1, and G0050A-18, Rev. 0)' :
  • Analysis for Tech Spec 3.7.1.2 Proposed Change (OSW-0048, Rev 0) ,

i

  • Unit 2 Hydraulic Analysis (G0050A-12, Rev. 5)
  • Unit 1 Hydraulic Analysis (G0050A-10, Rev. 5) r 6

I I l I El-5 i

1 ENCLOSURE 2 BSEP 93-0112 - BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 i NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62. RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION , SERVICE WATER SYSTEM LICENSE AMENDMENT REQUEST PAGE CHANGE INSTRUCTIONS t UNIT 1  ; Removed Pace inserted Pace XI XI i Xil Xil , 3/4 7-2 3/<4 7-2 , 3/4 7-2a 3/4 7 2a - 3/4 7-2b 3/4 7-2b 3/4 10-5 3/4 10-5 B3/4 7-1 B3/4 7-1 , B3/4 7-la B3/4' 7-1 a 

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B3/4 7-1b B3/4 7-1b B3/4 7-1c B3/4 7-1c B3/4 7-1d B3/4 7-1d B3/4 7-le B3/4 7-le 

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B3/4 7-1f B3/4 7-1f. B3/4 7-1g B3/4 7-1g B3/4 7-lh B3/4 7-lh  ; B3/4 7-li B3/4 7-1] , 

                                                               'I l

E2-1

4 UNIT 2 Removed Pace Inserted Pace XI XI r Xil Xil 3/4 7-2 3/4 7-2 3/4 7-2a 3/4 7-2a 3/4 7-2b 3/4 7-2b - 3/4 10-5 3/4 10-5 f B3/4 7-1 B3/4 7-1 J B3/4 7-la B3/4 7-1a 

                                                                    -l B3/4 7-1b                  B3/4 7-1b                         ,

i B3/4 7-1c B3/4 7-1c , B3/4 7-1d B3/4 7-1d B3/4 7-le B3/4 7-le < B3/4 7-1f B3/4 7-1f  ; B3/4 7-1g B3/4 7-1g B3/4 7-lh B3/4 7-lh . B3/4 7-li-B3/4 7-1j l , I r l E2-2 l l . - . _ -. , - . ., - . . - -}}

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