ML20127E317
| ML20127E317 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/18/1985 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127E321 | List: |
| References | |
| NLS-85-067, NLS-85-67, NUDOCS 8506240521 | |
| Download: ML20127E317 (5) | |
Text
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i CD&L CaroHna Power & Light Company SERIAL: NLS-85-067 Director of Nuclear Reactor Regulation Attention:
Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission Washington, DC 20535 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT REACTOR BUILDING SERVICE WATER RADIOACTIVE EFFLUENT MONITORING
Dear Mr. Vassallo:
SUMMARY
Carolina Power & Light Company (CP&L), in accordance with the Code of Federal Regulations, Titic 10, Parts 50.90 and 2.101, hereby requests a revision to the Technical Specification (TS) for the Brunswick Steam Electric Plant, Unit Nos. I and 2.
The proposed TS change deletes the requirements for radioactivity monitors on individual branches of the Reactor Building Component Cooling Water (Service Water) System.
E.SCUSSION The Service Water System provides cooling for Residual Heat Removal (RFIR) Flest Exchangers A and B, Reactor Building Component Cooling Water Heat Exchangers, and RHR Division I and Il Pump Seal Coolers.
Tabic 3.3.5.8-1 of the TS Indicates that effluent radiation monitors are located on each of the components identified above. The purpose of this license amendment is to dt.lete the reference to these five monitors. In addition, applicability condition note *
- has been revised to reflect current plant configuration.
l Carolina Power & Light Company believes that these monitors are not necessary for the following reasons:
1)
Potential radioactivity level in the service water effluent is detected by the main service water ef fluent monitors.
These instruments are equipped with alarm setpoints, which are calculated in accordance with the Offsite Dose Calculation Manual (ODCM), to ensure the alarm will occur prior to exceeding limits set forth in 10CFR20. The operability and use of this instrumentation is consistent with General Design Criteria 60,63, and 64 of Appendix A to 10CFR50.
l 2)
Procedures have been developed such that, if the main service water effluent monitor alarms, the source of contamination can be located by, grab sampling at f
each component.
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Mr. D. B. Vcssallo P:g2 2 3)
As required by T/S 3.3.5.8, during periods that the service water effluent radioactivity monitor is inoperable, service water samples are taken once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzed using gamma spectroscopy.
At the request of the NRR reviewers, these service water radiation monitors were included in the Brunswick Technical Specifications as part of the Radiological Effluent Technical Specifications contained in NUREG-0473. In a presentation at the Atomic Industrial Forum Conference held in Washington, DC, October 4-7, 1951, Charles A.
Willis and Frank 3. Congel (USNRC) stated, " Operating reactors are bein6 asked to meet the intent, not the letter, of the model of RETS requirements."
The intent of NUREG-0473 specification 3.3.7 !! is to ensure compliance to 10CFR20 liquid effluent radioactivity limits.
CP&L believes that the existing main service water effluent radioactivity monitors meets this intent.
Subsequent to issuance of the RETS, the Company determined that the cost of backfitting the plant with the service water monitors, currently shown in Table 3.3.5.8-1, is prohibitively costly. The Company has spent approximately $250,000 evaluating this system. Installation of the system is expected to cost in excess of $6,000,000. In light of the fact that neither a significant benefit to the radioactive liquid effluent monitoring system nor a reduction of risk to the public is achieved by this backfit, this cost is not justifiable.
SIGNIFICANT HAZARDS ANALYSIS The Company has reviewed this request and determined that the proposed amendment does not increase the probability or consequences of an accident previously evaluated, or create the possibility of a new accident as no physical alteration of plant configuration or changes to setpoints or operating parameters is involved. This change deletes the reference to radiation monitors that were to be added to the radioactive liquid effluent monitoring system. Because the RBCCW service water ef fluent is adequately monitored with the existing main service water effluent monitor, no reduction in a margin of safety is insolsed. Based on the above reasoning, CP&L has determined that operation of the facility in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or consequence of an accident previously evaluated: 2) create a new or dif ferent kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety. As such, this amendment involves no significant hazards consideration.
l l
ADMINISTR ATIVE INFORMATION The proposed Brunswick-1 and Brunswick-2 TS pages are included in Attachment I and. A complete summary of the changes made to each TS page is included to assist in reviewing this amendment.
Carolina Power & Light Company has evaluated this request in accordance with the provisions of 10 CFR 170.12 and has determined that a license amendment application fee is required. A check for $150.00 is enclosed in payment of this fee.
n Mr. D, B, Vassalla Pcg2 3 Should you have any questions concerning this submittal, please contact Mr. Sherwood R.
Zimmerman at (919) 836-6242.
Your Sery tr 19,
[(
,B. Cutter - Vice[
hent uclear Engineering & Licensing RW /pgp (1202RWS)
Attachments cci Dr. J. Nelson Grace (NRC-Ril)
Mr. W. H. Rutand (NRC-BNP)
Mr. M. Grotenhuis (NRC)
A. B. Cutter, 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 beliefs and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.
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ATTACHMENT 1 SERIAL: NLS-85-067 BRUNSWICK STEAM ELECTRIC PLANT PROPOSED TECHNICAL SPECIFICATION PAGES - UNIT 1 (CP&L SERIAL NO. 84TSB45)
SUMMARY
LIST OF REVISIONS BRUNSWICK-1 Page Comments t
3/4 3-63 Deleted Item 8 3/4 3-65 Deleted note **** referring to applicability of monitors in Item 8 deleted above Revised Note ** - Equipment is now installed 3/4 3-66 Deleted Item 8
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