ML20066C931
| ML20066C931 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/07/1991 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20066C933 | List: |
| References | |
| GL-90-09, GL-90-9, NLS-90-251, NUDOCS 9101110321 | |
| Download: ML20066C931 (6) | |
Text
Carolina Power & Light Company P.O Box 1551 e Aaleegh, W C. 27602 SERIAL:
NLS-90 251 10CFR50.90 90TSB16 G E.VAUGHN UAN 071991 Vice President Nuclear Services Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSVICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50 325 & 50 324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT CENERIC LETTER 90 09 - SNUBBER VISUAL INSPECTION INTERVALS Centlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power 6 Light Company hereby requests a revision to the Technical Specifications for the Brunswick Sceam Electric Plant (BSEP),
Units 1 and 2.
The proposed amendment revises the visual inspection surveillance requirements and acceptance criteria associated with Technical Specification 3/4.7.5, Snubbers, in accordance with the guidance provided in Ceneric Letter 90-09, Alternative Requirements For Snubber Visual Inspection Intervals And Corrective Actions, cated December 11, 1990.
The current 18 month inspection interval requires visual inspections of inaccessible snubbers on Brunswick Unit 2 to be completed by July 29, 1991.
As such, these visual inspections are currently planned for completion during a three week outage scheduled to begin on April 13, 1991 for perfortance of certain periodic tests.
Issuance of the proposed amendment, which follows the guidance _of Cencric Letter 90 09, will allow inspection of the inaccessible snubbers to be perforted during the upcoming Unit 2 Relocd 9 outage, currently scheduled to begin on September 7, 1991.
Performing the inspections during the Reload 9 outage and after the planned chemical decontamination will result in a dose savings of approximately 6.6 manrem.
Based on this reasoning, Carolina Power & Light Company requests that the proposed amendment be issued by April 1, 1991 in order to realize these ALARA benefits. provides a detailed description of the proposed changes and the basis for the changes. details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides the proposed Technical Specification pages for Unit 1. provides the proposed Technical Specification pages for Unit 2.
9101110321 910107 04 PDR ADOCK 05000324 P
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NLS 90 251/ Page 2 l
l; In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued with an effective date.to be no later than 60 days from the issuance of the amendment.
Pier.se refer any questions regarding this' submittal te M:, M. R. Oates at (919) 546 6063.
Yours very truls, QY C. E. Vaughn CEV/ MAT
Enclosures:
1.-
Basis for Change Request 2.
10 CFR 50.92 Evaluation 3.
Technical Specification Pages.- Unit 1 4
Technical Specification Pages - Unit 2 cc:
Mr. Dayne 11. Brown Mr.-.S. D. Ebneter
~Mr. N. B. Le Mr. R. L. Prevatte G. E. Vaughn, having been first duly sworn, did depose and say that the infor-mation. contained heroin is true and correct to the best of his information, knowledge and belief; and the sourcee.* his information are officers,.
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i ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 6 50 324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT GENERIC LETTER 90 SNUBBER VISUAL INSPECTION INTERVALS BASIS FOR CHANGE REQUEST Pre'osed Chance The proposed amendment revises the visual inspection surveillance requirements 4
and acceptance criteria associated with Technical-Specification 3/4.7.5, i
Snubbers, in accordance with the guidance provided in Generic Letter 90-09, Alternative Requirements For Snubber Visual Inspection Intervals end Corrective Actions, dated December 11, 1990, r
Basis Performance of periodic _ visual inspections of snubbers complements the existing functional testing program and provides additional confidence in snubber operability. The existing Technical Specification surveillance schedule is based on the number of inoperable snubbers found during the previous inspection.
In addition, the existing surveillance' interval assumes an 18 month refueling interval which does not account for the trend to longer fuel cycles or the impact of extended outages such as the Brunswick Unit 2 Reload 8 outage during which portions of the recirculation piping were replaced.
The proposed amendment alleviates this situation by incorporating the alternative inspection schedule provided by the Staf f in Generic Letter 90-09, dated December 11, 1990. The alternative inspection schedule is based on the number of unacceptable snubbers found during the previous inspection in proportion to the sizes of the various snubber populations.and may be as long as 48 months with good overall visual inspection results.
As determined by the Staff, the alternate schedule for visual inspections maintains the same confidence level in snubber operability as the existing schedule while allowing the flexibility to perform visual inspections'and corrective actions during plant outages.
Because this line-item Technical Specification improvement will reduce future occupational radiation exposure and is highly cost effective, the alternative inspection schedule la consistent with the Commissions's policy statement on Technical Specification Improvements, I
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50 324 OPERATINC LICENSES DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT CENERIC LETTER 90 09 - SNUBBER VISUAL INSPECTION INTERVALS BASIS FOR CHANCE REQUEST 10 CPR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) fer 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 I
consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, l
or (3) involve a significant reduction in a margin of safety.
Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration.
The bases for this determination are as follows:
l Pr, nosed Change l
The proposed amendment revices the visual inspection surveillance requiremonts and acceptance criteria associated wit.i Technical Specification 3/4.7.5,
'.n accordance with the guidance provided in Ceneric Letter 90-09, Alternative Requirements For Snubber Visual Inspection Intervals And Corrective Actions, dated December 11, 1990.
l Ba ri t, The change does not involve a significant hazards-consideration for the following reasons:
1 1.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change does not result in any physical change to the facility which could cause an increase in the probability or consequences of any previously evaluated accident.
The requested change incorporates the alternative inspection schedule provided by the Staff in Generic Letter 90 09, dated December 11, 1990. As determined by the Staff, the alternate schedule for visual inspections maintains the same confidence level as the existing scheduln and, therefore, does not affect the j
probability or consequences of an accident previously evaluated.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment does not alter any plant operations, other than the E2-1
snubber visual inspection surveillance interval, maintenance requirements, or system design or' functions.
The Staff has previously reviewed these changes and determined that the alternative visual inspection interval maintains the same confidence level in snubber operability.
Therefore, no possibility of creating a new or different type of accident would result from the proposed amendment.
3.
The proposed amendment does not involve a significant reduction in the margin of safety. As stated above, the proposed amendment incerporates the alternative Technical Specification requirements for visual inspections of snubbers provided by the Staff in Generic Letter 90 09.
The Staff has previously reviewed these changes and determined thet the alternative visual inspection interval maintains the same confidence level in snubber operability.
Therefore, the proposed amendment does not involve a reduction in the margin of safety.
E2-2
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- ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & $0 324 OPERATING LICENSES DPR-71 & DPR 62
_ REQUEST FOR LICENSE AMENDMENT GENERIC LETTER 90 09 - SNUBBER VISUAL INSPECTION INTERVALS TECHNICAL SPECIFICATION PAGES - UNIT 1 p
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