ML20094E949
| ML20094E949 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/30/1992 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-048, REF-GTECI-049, REF-GTECI-NI, TASK-A-48, TASK-A-49, TASK-OR GL-91-11, NLS-92-020, NLS-92-20, NUDOCS 9202110349 | |
| Download: ML20094E949 (7) | |
Text
Carolina Power & LI ht Company D
P o Box 1651
- Rategh. N C 27tKV SERIAL: NLS 92-020 (JAN 301992 uv-vr. er. o.m Node.ar Servres Depadmem United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STE.AM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR 71 & DPR 02 RESPONSE TO NRC GENERIC LETTER 91 11 RESOLUTION OF CENERIC ISSilES 48 AND 49 Gentlemsn:
The purpose of this letter is to provide, in accordance with 10 CFR 50.54(f), Carolina Power &
Light Company's response for the Brunswick Steam Electric Plant, Un:ts 1 and 2 to NRC Generic Letter 91 11, " Resolution of Generic issue 48, 'LCOs for Class IE Vital instrument Buses,' and 49,
' interlocks and LCOs for Class 1E Tie Breakers' Pursuant to 10 CFR 50.54(f)" dated July 18,1991, The generic letter requested that licensees provide certification, within 180 days of receipt of the generic letter, that they have implemented the appropriate procedures conforming to the guidarace provided in the generic letter enclosure or have prepared justification that such procedures are not needed. Carolina Power & Light Company does have Technical Specification requirements and procedures in place that conform to the guidance of the generic letter. Each of the NRC recommended actions, and CP&L's response thereto, are provided in Enclosure 1.
Please refer any questions regarding this submittal to Mr. W. R. Murray at (919) 546-4661, Yours very truly,
-fb r-r?. Fi. Vaughn WRM/wrm (g!9111 wpf)
Enclosure cc:
Mr. S. D. Ebneter Mr. N. B. Le Mr. R. L. Prevatte
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Document Control Desk NLS 92 020 / Page 2 G. E. Vaughn, 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.
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324-OPERATING LICENSE NOS. DPR 71 & DPR-62 RESPONSE TO NRC GENERIC LETTER 91 11-RESOLUTION OF GENERIC ISSUES 48 AND 49 RECOMMENDED ACTION 1:
I Ensure that your plant has procedures that include time limitations and surveillance requirements for vital instrument buses (typically 120V ac buses),
r;ESPoi4GCs 120V ac Emeroency Busts:
At the Brunswick Plant, there are four 120V ac emergency buses in service, two buses for each unit. These buses are designated as 1E5, IE6,2E7, and 2E8 No tie breakers exist between the
> 120V ac emergency buses.
The Brunswick Plant Technical Specifications currently include limitations for tie breakers between the four 120V ac buses (even though no tie breakers exist between the 120V ac buses).
Specifically Technical Specification 3.8.2.1 lists the 120V ac buses that are required to be
" OPERABLE with the tie breakers open between redundant buses" during OPERATIONAL CONDITIONS 1, 2, or 3. With less than all four of the 120V ac emergency buses OPERABLE, the inoperable bus must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the unit must be placed in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
L The Brunswick Plant Technical Specifications currently include surveillance requirements for these L
tie breakers enforcing this restriction (even though no tie breakers exist between the 120V ac -
buses). Specifically, Technical Specification 4.8.2.1 states the following:
l The specified A.C. buses shall be determinod OPERABLE at least once per 7 days by varifying co.voci b:eshot tjicr.r.unt c.M MCcated cvd'2"!t*,*.*
Plant procedure Periodic Test (PT) 12.6, paragraphs 7.9.3, 7.9.4, 7.14.3, and 7.14.4 require the four 120V ac emergency buses to be verified as energized at least once every 7 days.
480V ac Emeroency Buses:
At the Brunswick Plant, there are four 480V ac emergency buses in service, two buses for each unit. These buses are designated as ES, E6, E7, and E8. Tie breakers are installed to connect I
bus E5 to bus E6 and to connect bus E7 and bus E8, LThe Brunswick Plant Technical Specifications currently include limitations for tie breakers between the four 480V ac buses. Specifically, Technical Specification 3.8.2.1 lists the 480V ac buses that are required to be " OPERABLE with the tie breakers open between redundant buses" during l.
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OPERATIONAL CONDITIONS 1. 2, or 3. With less than all four of the 480V ac emergency buses OPERABLE, the inoperable bus must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the unit must be placed in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The Brunswick Plant Technical Specifications currently include surveillance requirements for these tie breakers enforcing this restriction. Specifically, Technical Specification 4.8.2.1 states the following:
The specified A.C. buses shall be determined OPERABLE at least once per 7 days by verifying correct breaker alignment and indicated availability."
The following plant procedures provide surveillance requirements covering these buses:
Periodic Test (PT) 12.6, pa;agraphs 7.6.1.5, 7.6.1.6, 7.6.1.7, and 7.6.1.8 require the four 480V ac emergency buses to be verified as energized at least once every 7 days.
PT 12.6, Breaker Alignment Surveillance, paragraph 7.23.2 requires the tie breaker to compartment AT4 be verified as racked out once every 7 days. This is the E5 tie breaker between emergency buses E5 and E6.
PT 12.6, Breaker Alignment Surveillance, paragraph 7.25.2 requires the tie breaker to compartment AX1 be verified as racked out once every 7 days. This is the E6 tio breaker between emergency buses E5 and E6.
PT 12.6, Breaker Alignment Surveillance, paragraph 7.35.2 requires the tie breaker to compartment AIO be verified as racked out once every 7 days. This is the E8 tio breaker between emergency buses E7 and E8.
PT 12.6, Breaker Alignment Surveiitance, paragraph 7.37.2 requires the tie breaker to compartment AX5 be verified as racked out once every 7 days. This is the E7 tie breaker between emergency buses E7 and E8.
RECOMMENDFD ACTION 2:
Ensure that your plant has procedures that include time limitations and surveillance requirements i ::!
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RESPONSE
250/125V de Systems:
At the Brunswick Plant, there are four 250/125V de battery systems, two for each unit. Each battery system consists of two 125V de battery banks, two full capacity battery chargers, and a 250/125V de switchboard. 250/125V de switchboards 1 A and 18 are associated with Unit 1; switchboards 2A and 2B are associated with Unit 2. No tie breakers exist between the 250/125V de switchboards.
The Brunswick Technical Specifications currently include limitations for the 250/125V de battery systems (even though no tie breakers exist between the 250/125V de switchboards). Technical El-2
Specification 3.8.2.3 requires the following divisions in each unit to be OPERADLE with the tie breakers between the divisions open:
Division 1 consisting of:
- 1. A 250/125 volt bus
'2. Two 125 volt de batteries, each with a full capacity charger Division 2 consisting of:
- 1. A 250/125 volt bus
- 2. Two 125 volt de batteries, each with a full capacity charger
- Technical Specification 3.8.2.3 also specifies that with one or more batteries and/or its associated battery charger inoperabh in one division, the division must be restored to OPERABLE < tatus within 7 days or the unit be placed in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cot.0 SHU1DOW14 w:.:.'n the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With one or saore baitories and/or its as:ociated battery charger inoperable in both divisions, the unit must be placed in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The Brunswick Plant Technical Specifications currently include surveillance requirements for these tie breakers enforcing this restriction (even though no tie breakers exist between the 250/125V de switchboards). Specifically, Technical Specification 4,8.2.3.1 requires that each of the required DC -
divisions be determinod OPERABLE with the tie breakers open at least once overy 7 days by verifying the correct breaker alignment, indicated power availability, and that no combination of more than two power conversion modules (consisting of either two lighting inverters or one lighting
. inverter and one plant UPS unit) are aligned to division 2, bus B.
The following plant prncedures provide surveillance requirements covering these buses:
Periodic Test (PT) 12.6, paragraphs 7.11.2, 7.11.3, 7.16.2, and 7.16.3 regelte the Division 1 and 2 for both Unit I and Unit 2 be verified at least once every 7 days as having two 125V de batteries with two full capacity battery chargers supplying each 250/125V de L
bus.
PT 12.6, Breaker Alignment Surveillance, paragraphs 7.9.2 and 7.14.2 requires the power I
conversion module alignment to the battery system be verified once every 7 days.
P~ '. ". % .w.h. /.!:r..% * ".'~ -8" trap /-CJ.1 monims thr: verific1 tion once every 7 days of DC power availability for each battery.
RECOMMENDED ACTION 3:
Ensure that your plant has procedures that include time limitations and surveillance requirements for tie breakers that can connect redundant Class 1E buses (ac or de) at one unit or that can connect Class 1E buses between units at the same site.
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4 BESPONSE:-
The Brunswick Plant Technical Specifications currently include limitations for tie breakers between redundant Class 1E buses between the two Brunswick units. SpecificallyiTechnical Specification 3.8.2.1 lists the Class 1E buses that are required to be " OPERABLE with the tie
' breakers open beeran redundant buses' during OPERATIONAL CONDITIONS 1,2, or 3. This requirement ak, s#.o the fc!!owing buses:
4160 voit Emergency Bus El and E3 4160 voit Emergency Bus E2 and E4 -
480. volt Emergency Bus E5 and E6-480 volt Emergency Bus E7 and E8 -
i The Brunswick Plant Technical Specifications currently include surveillance requirements for these.
= tie breakers enforcing this restriction. Specifically, Technical Specification 4.8.2.1 states tha followin0:
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The specified A.C. buses shall be determined OPERABLE at least once per 7 days by-j.
. verifying correct breaker alignment and indicated availability."
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~ Plant procedure Periodic Test (PT) 12.6 enforces this surveillance requirement by verifying the
' breakers lit,ted below are ' racked out":
Normal Bus Breaker Position El AGO (E3)
Racked Out E1 AG1 (E2)
Racked Out E2 AH8 (E1)
Racked Out E2-AH9 (E4)
Racked Out E3 AJS (E1)
Racked Out E3 AJ6 (64)-
Rccked Ot.t E4 AL4 (E3)
Racked Out E4-ALS (E2)
Racked Out E5
- AT4 (EG)
Racked Out E6 AX1 (ES)
Racked Out '
E7 AX5 (E8)
Racked Out
~E8 AIO (E7)
Racked Out.
These breakers are placed under clearance with the control fuses removed for increased ass,.:rance that an inadvertent operation does not occur.
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