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Category:CORRESPONDENCE-LETTERS
MONTHYEARBSEP-99-0170, Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6)1999-10-19019 October 1999 Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6) BSEP-99-0161, Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V3511999-10-13013 October 1999 Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V351 ML20217G1191999-10-0808 October 1999 Informs That on 990930,NRC Staff Completed mid-cycle PPR of Brunswick NPP & Did Not Identify Any Areas Where Performance Warranted More than Core Insp Program.Nrc Plan to Conduct Only Core Insps at Facility Over Next Five Months ML20217C6931999-10-0606 October 1999 Forwards Insp Repts 50-324/99-06 & 50-325/99-06 on 990801- 0911 at Brunswick Reactor Facility.No Violations Were Identified BSEP-99-0114, Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl1999-10-0404 October 1999 Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl BSEP-99-0157, Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii)1999-10-0404 October 1999 Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii) BSEP-99-0142, Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-23023 September 1999 Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0158, Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-21021 September 1999 Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0153, Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 19991999-09-14014 September 1999 Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 1999 BSEP-99-0147, Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval1999-09-14014 September 1999 Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval BSEP-99-0151, Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP1999-09-0808 September 1999 Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP BSEP-99-0149, Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld1999-09-0202 September 1999 Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld BSEP-99-0150, Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-0202 September 1999 Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0112, Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl1999-09-0101 September 1999 Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl ML20211K9001999-08-27027 August 1999 Forwards Insp Repts 50-324/99-05 & 50-325/99-05 on 990620-0731.Two Violations Occurred & Being Treated as NCVs BSEP-99-0146, Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl1999-08-26026 August 1999 Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl BSEP-99-0148, Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 21999-08-25025 August 1999 Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 2 BSEP-99-0141, Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-08-25025 August 1999 Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0130, Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl1999-08-25025 August 1999 Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl BSEP-99-0132, Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl1999-08-20020 August 1999 Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl BSEP-99-0134, Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl1999-08-13013 August 1999 Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl ML20210S9061999-08-11011 August 1999 Informs That GE Document Entitled, Addl Info Regarding 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12, Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act BSEP-99-0128, Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant1999-08-11011 August 1999 Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant ML20210S9121999-08-11011 August 1999 Informs That Document NEDC-31624P,Suppl 2,Rev 6,entitled, Loss-Of-Coolant Accident Analysis Rept for Brunswick Steam Electric Plant Unit 2,Reload 13,Cycle 14 Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) ML20210P8221999-08-11011 August 1999 Advises That Info Contained in Which Submitted Document,Prepared by Siemens Power Corp,EMF-2168(P) Rev 0, Marked Proprietary,Will Be Withheld from Public Disclosure, Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954 ML20210P9381999-08-10010 August 1999 Forwards SE Accepting Licensee & Suppls & 0517,which Submitted Assessment of Impact on Operation of Unit 1 with Crack Indications of 2.11, 6.36 & 1.74 Inches in Three Separate Jet Pump Risers ML20210P8911999-08-10010 August 1999 Forwards SE Authorizing Relief Requests CIP-01,02,06,07,08, 09,10,11 (with Certain Exceptions) & 12-18,for Second 10-year ISI Interval.Requests CIP-04 & 05 Would Result in Hardship,Relief CIP-03 Not Required & CIP-11 Denied in Part BSEP-99-0110, Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI1999-08-0505 August 1999 Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI BSEP-99-0123, Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 21999-08-0505 August 1999 Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 2 ML20210Q4581999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section to Written Operator Licensing Exam on 991006. Authorized Representative of Facility Must Submit List of Individuals to Take exam,30 Days Before Exam Date ML20210P2031999-08-0505 August 1999 Discusses Staff Response to GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity for Plant,Units 1 & 2 ML20210N2041999-08-0505 August 1999 Forwards SE Accepting Response to GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Unresolved Safety Issues (USI) A-46, & Suppl 1 BSEP-99-0127, Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl1999-08-0505 August 1999 Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl BSEP-99-0124, Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld1999-07-30030 July 1999 Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld ML20210G2941999-07-28028 July 1999 Discusses Public Meeting Conducted on 990720 to Present Results of Periodic Plant Performance Review for Brunswick Facility for Period of May 1997 to January 1999.List of Attendees Encl BSEP-99-0122, Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld1999-07-20020 July 1999 Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld BSEP-99-0121, Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant1999-07-19019 July 1999 Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant BSEP-99-0111, Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR1999-07-19019 July 1999 Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR ML20210E1181999-07-19019 July 1999 Forwards Insp Repts 50-324/99-04 & 50-325/99-04 on 990509- 0619.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20209G1081999-07-13013 July 1999 Forwards Radiological Emergency Response Plan & Revised Epips,Including Rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26 BSEP-99-0106, Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl1999-06-28028 June 1999 Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl BSEP-99-0103, Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 11999-06-24024 June 1999 Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 1 BSEP-99-0100, Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results1999-06-23023 June 1999 Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results BSEP-99-0105, Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl1999-06-23023 June 1999 Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl ML20196H8191999-06-21021 June 1999 Informs That on 980915,Commission Suspended SALP Program for an Interim Period Until NRC Completes Review of Process for Assessing Performance at NPPs ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First BSEP-99-0091, Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-06-14014 June 1999 Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20196A8111999-06-14014 June 1999 Ack Receipt of 990401 Response to NRC Ltr Issued on 990302 Re OI Investigation to Determine Whether Former BSEP Manager Threatened to Fire Employees Who Brought Safety Concerns to Nrc.Concluded That No Violation Occurred ML20195J1971999-06-14014 June 1999 Advises That GE-NE-523-B13-01920-56,Rev 1,submitted with 990202 Affidavit,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended BSEP-99-0090, Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 9905141999-06-0909 June 1999 Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 990514 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARBSEP-99-0170, Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6)1999-10-19019 October 1999 Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6) BSEP-99-0161, Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V3511999-10-13013 October 1999 Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V351 BSEP-99-0114, Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl1999-10-0404 October 1999 Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl BSEP-99-0157, Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii)1999-10-0404 October 1999 Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii) BSEP-99-0142, Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-23023 September 1999 Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0158, Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-21021 September 1999 Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0153, Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 19991999-09-14014 September 1999 Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 1999 BSEP-99-0147, Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval1999-09-14014 September 1999 Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval BSEP-99-0151, Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP1999-09-0808 September 1999 Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP BSEP-99-0150, Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-0202 September 1999 Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0149, Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld1999-09-0202 September 1999 Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld BSEP-99-0112, Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl1999-09-0101 September 1999 Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl BSEP-99-0146, Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl1999-08-26026 August 1999 Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl BSEP-99-0141, Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-08-25025 August 1999 Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0148, Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 21999-08-25025 August 1999 Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 2 BSEP-99-0130, Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl1999-08-25025 August 1999 Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl BSEP-99-0132, Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl1999-08-20020 August 1999 Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl BSEP-99-0134, Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl1999-08-13013 August 1999 Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl BSEP-99-0128, Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant1999-08-11011 August 1999 Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant BSEP-99-0127, Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl1999-08-0505 August 1999 Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl BSEP-99-0123, Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 21999-08-0505 August 1999 Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 2 BSEP-99-0110, Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI1999-08-0505 August 1999 Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI BSEP-99-0124, Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld1999-07-30030 July 1999 Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld BSEP-99-0122, Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld1999-07-20020 July 1999 Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld BSEP-99-0111, Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR1999-07-19019 July 1999 Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR BSEP-99-0121, Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant1999-07-19019 July 1999 Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant ML20209G1081999-07-13013 July 1999 Forwards Radiological Emergency Response Plan & Revised Epips,Including Rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26 BSEP-99-0106, Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl1999-06-28028 June 1999 Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl BSEP-99-0103, Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 11999-06-24024 June 1999 Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 1 BSEP-99-0100, Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results1999-06-23023 June 1999 Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results BSEP-99-0105, Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl1999-06-23023 June 1999 Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl BSEP-99-0091, Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-06-14014 June 1999 Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0090, Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 9905141999-06-0909 June 1999 Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 990514 BSEP-99-0092, Informs That,Effective 990513,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired.Proprietary Encl Containing Name of Individual,Docket Number,License Mumber & Date of Expiration Encl.Proprietary Encl Withheld1999-06-0808 June 1999 Informs That,Effective 990513,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired.Proprietary Encl Containing Name of Individual,Docket Number,License Mumber & Date of Expiration Encl.Proprietary Encl Withheld BSEP-99-0085, Forwards Proprietary Rev 67 to EPIP OPEP-App a, Emergency Response Resources & non-proprietary Rev 53 to Radiological Emergency Response Plan, Rev 15 to EPIP OPEP- 03.8.2 & Rev 17 to EPIP OPEP-04.2.Proprietary Info Withheld1999-05-27027 May 1999 Forwards Proprietary Rev 67 to EPIP OPEP-App a, Emergency Response Resources & non-proprietary Rev 53 to Radiological Emergency Response Plan, Rev 15 to EPIP OPEP- 03.8.2 & Rev 17 to EPIP OPEP-04.2.Proprietary Info Withheld BSEP-99-0078, Provides Addl Info Re Jet Pump Riser Weld Insp Results,Per 990406 Telcon with NRC Re Effect of worst-case Crack on LPCI Sys Flow & PCT1999-05-17017 May 1999 Provides Addl Info Re Jet Pump Riser Weld Insp Results,Per 990406 Telcon with NRC Re Effect of worst-case Crack on LPCI Sys Flow & PCT BSEP-99-0080, Forwards Revs Made to TS Bases Between 980605 & 990507 Without Prior NRC Approval1999-05-17017 May 1999 Forwards Revs Made to TS Bases Between 980605 & 990507 Without Prior NRC Approval BSEP-99-0083, Forwards Two Proprietary License Renewal Applications Consisting of NRC Forms 398 & 396,for Operators Licensed on CP&L Bsep,Units 1 & 2,IAW 10CFR55.57.Proprietary Info Withheld from Public Disclosure IAW 10CFR2.790(a)(6)1999-05-14014 May 1999 Forwards Two Proprietary License Renewal Applications Consisting of NRC Forms 398 & 396,for Operators Licensed on CP&L Bsep,Units 1 & 2,IAW 10CFR55.57.Proprietary Info Withheld from Public Disclosure IAW 10CFR2.790(a)(6) BSEP-99-0056, Forwards 1998 Radiological Environ Operating Rept for BSEP, Units 1 & 2. Encl 1 Provides List of Regulatory Commitments.Vols II & Iii,Sample Analysis Data for Jan-June 1998 & Jul-Dec 1998,respectively1999-05-13013 May 1999 Forwards 1998 Radiological Environ Operating Rept for BSEP, Units 1 & 2. Encl 1 Provides List of Regulatory Commitments.Vols II & Iii,Sample Analysis Data for Jan-June 1998 & Jul-Dec 1998,respectively BSEP-99-0073, Withdraws Request for Approval of Proposed QAP Change Which Was Submitted by1999-05-12012 May 1999 Withdraws Request for Approval of Proposed QAP Change Which Was Submitted by BSEP-99-0062, Forwards Latest Revs of COLR & Suppl Reload Licensing Rept, for Bsep,Unit 2.Proprietary Rev 6,Suppl 2 to NEDC- 31624P & EMF-2168P,included.Proprietary Encls Withheld, Per 10CFR2.790 & 10CFR9.171999-05-11011 May 1999 Forwards Latest Revs of COLR & Suppl Reload Licensing Rept, for Bsep,Unit 2.Proprietary Rev 6,Suppl 2 to NEDC- 31624P & EMF-2168P,included.Proprietary Encls Withheld, Per 10CFR2.790 & 10CFR9.17 BSEP-99-0079, Forwards Proprietary One License Renewal Application Consisting of NRC Form 398, Personal Qualification Statement - Licensee & NRC Form 396, Certification Of... Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-05-0707 May 1999 Forwards Proprietary One License Renewal Application Consisting of NRC Form 398, Personal Qualification Statement - Licensee & NRC Form 396, Certification Of... Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0066, Submits Revised Relief Requests Which Provides Alternative to ASME B&PV Code Requirements for Insp of Containments. Revised Copies of Relief Requests CIP-03,CIP-04,CIP-05, CIP-10,CIP-16 & CIP-17 Provided1999-05-0404 May 1999 Submits Revised Relief Requests Which Provides Alternative to ASME B&PV Code Requirements for Insp of Containments. Revised Copies of Relief Requests CIP-03,CIP-04,CIP-05, CIP-10,CIP-16 & CIP-17 Provided ML20195D6301999-04-30030 April 1999 Forwards Natl Marine Fisheries Svc Biological Opinion Based on Review of Continued Use of Cooling Water Intake Sys at Bsep.Rept Reviews Effects of Activity on Loggerhead,Kemps Ridley,Green,Hawksbill & Leatherback Sea Turtles BSEP-99-0071, Forwards Notice of Expiration of Operator License,Per 10CFR50.75(b).Details Withheld Per 10CFR2.790(a)(6)1999-04-27027 April 1999 Forwards Notice of Expiration of Operator License,Per 10CFR50.75(b).Details Withheld Per 10CFR2.790(a)(6) BSEP-99-0069, Discusses Rev of Relief Request RR-17, Leakage at Bolted Connections, for ISI Program for Third ten-yr Interval.Util & NRC Were Unable to Reach Agreement Re Use of ASME Code Case N-566-1 as Permanent Basis for Relief Request RR-171999-04-26026 April 1999 Discusses Rev of Relief Request RR-17, Leakage at Bolted Connections, for ISI Program for Third ten-yr Interval.Util & NRC Were Unable to Reach Agreement Re Use of ASME Code Case N-566-1 as Permanent Basis for Relief Request RR-17 BSEP-99-0063, Notifies NRC of Plans to Install Mod for Bsep,Units 1 & 2 Erds.Physical Computer Sys Changeout Activities Will Temporarily Affect Availability of ERDS Computer Points Via NRC Data Link1999-04-21021 April 1999 Notifies NRC of Plans to Install Mod for Bsep,Units 1 & 2 Erds.Physical Computer Sys Changeout Activities Will Temporarily Affect Availability of ERDS Computer Points Via NRC Data Link BSEP-99-0050, Informs NRC That Certain Category C,D & E Piping Welds in Units 1 & 2 Have Not Been Inspected in Accordance with Frequencies Provided by NRC GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping,1999-04-0606 April 1999 Informs NRC That Certain Category C,D & E Piping Welds in Units 1 & 2 Have Not Been Inspected in Accordance with Frequencies Provided by NRC GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, BSEP-99-0051, Forwards Response to Ofc of Investigations Rept 2-1998-014 to Support Final Resolution of Allegations.Response in Encl 1 Withheld.Public Version of Response in Encl 21999-04-0101 April 1999 Forwards Response to Ofc of Investigations Rept 2-1998-014 to Support Final Resolution of Allegations.Response in Encl 1 Withheld.Public Version of Response in Encl 2 BSEP-99-0015, Forwards Response to NRC 981221 RAI Re Cp&Ls Response to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves1999-03-31031 March 1999 Forwards Response to NRC 981221 RAI Re Cp&Ls Response to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves 1999-09-08
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.. CP&L Corolina Power & Light Company William R. Campbell PO Box 10429 Vice Presicient Southport NC 28461 Brunswick Nuclear Plant March 22,1997 SERIAL BSEP 97-0119 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR ENFORCEMENT DISCRETION INSTRUMENTATION RESPONSE TIME TESTING Gentlemen:
In accordance with the NRC's Enforcement Policy as published in NUREG-1600, " General l Statement of Policy and Procedures for NRC Enforcement Actions," Carolina Power & j Ught (CP&L) Company requests that the NRC exercise enforcement discretion regarding i compliance with the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. This request is made to permit continued operation without completion of instrumentation response time testing, as currently defined in the Technical Specifications, for the Reactor Protection System (RPS), Emergency Core Cooling System (ECCS), and Isolation Actuation instrumentation. It was determined that these instruments are inoperable because instrument response time surveillance testing required by Technical Specifications 4.3.1.3, 4.3.2.3, and 4.3.3.3 has not been performed in accordance with the instrumentation response time testing definitions contained in Section 1.0 of the BSEP Technical Specifications.
A discussion of the circumstance surrounding this request, including technical justification, compensatory measures, safety evaluation, and evaluation of the potential impact on the public health and safety and the environment is enclosed. CP&L has determined that there is no safety significance associated with this issue and that there are no potential adverse consequences associated with the proposed enforcement discretion.
A letter notifying the NRC of the potential need for enforcement discretion was previously submitted on March 21,1997 (Serial: BSEP 97-0117). Subsequently, a telephone conference was held with the NRC staff on the evening of March 21,1997. The NRC staff verbally granted this request for enforcement discretion at 9:36 p.m. on March 21,1997. The NRC Inspection Manual, Part 9900: Technical Guidance stipulates that a licensee's written request for enforcement discretion should be submitted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following verbal approval of the enforcement discretion. This letter supersedes the March 21,1997, letter and provides the necessary written request for enforcement discretion.
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l Please refer any questions regarding this submittal to Mr. Keith Jury, Manager - Regulatory l Affairs, at (910) 457-2783.
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Sincerely, h) 17" William R. Campbell
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Enclosures:
- 1. Basis for Enforcement Discretion Request
- 2. Marked Up Technical Specification Pages pc (with enclosures):
U. S. Nuclear Regulatory Commission AT b .: Mr. Luis A. Reyes, Regional Administrator 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323-0199 U. S. Nuclear Regulatory Commission ATTN: Mr. C. A. Patterson, NRC Senior Resident inspector 8470 River Road .
Southport, NC 28461 U. S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738
, The Honorable J. A. Sanford Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 i
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! ENCLOSURE 1 1
! I BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 I NRC DOCKET NOS. 50-325 AND 50-324
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- OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR ENFORCEMENT DISCRETION INSTRUMENTATION RESPONSE TIME TESTING Summary- )
In accordance with the NRC's Inspection Manual, Part 9900: Technical Guidance, Carolina Power & Light (CP&L) Company requests that the NRC exercise enforcement discretion ,
regarding compliance with the Technical Specifications for the Brunswick Steam Electric l Plant (BSEP), Unit Nos.1 and 2. This request would permit continued operation without completion of instrumentation response time testing of the Reactor Protection System (RPS),
Emergency Core Cooling System (ECCS), and Isolation Actuation Instrumentation. These instruments are considered inoperable because instrument response time surveillance testing required by Technical Specifications 4.3.1.3,4.3.2.3, and 4.3.3.3 has not been performed in accordance with the instrumentation response time testing definitions contained in section 1.0 of the BSEP Technical Specifications. As a result of these circumstances, shutdown of both BSEP Unit No.1 and BSEP Unit No. 2 in accordance with Technical Specifications is required.
_l A letter notifying the NRC of the potential need for enforcement discretion was previously submitted on March 21,1997 (Serial: BSEP 97-0117). Subsequently, a telephone conference was held with the NRC staff on the evening of March 21,1997. The NRC staff verbally granted this request for enforcement discretion at 9:36 p.m. on March 21,1997. The NRC Inspection
, Manual, Part 9900: Technical Guidance stipulates that a licensee's written request for enforcement discretion should be submitted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following verbal approval of the enforcement discretion. This letter supersedes the March 21,1997, letter and provides the necessary written request for enforcement discretion.
- 1. Reauirements For Which Discretion is Reauested:
Technical Specification Section 1.0 includes the following defined terms:
EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME l The EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME shall be that l time interval from when the monitored parameter exceeds its ECCS actuation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable.
ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation actuation setpoint at the channel sensor until t
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L the isolation valves travel to their required positions. Times shall include diesel generator -- ,
! starting and sequence loading delays where applicable, l REACTOR PROTECTION SYSTEM RESPONSE TIME t
The REACTOR PROTECTION SYSTEM RESPONSE TIME shall be that time interval from t
when the monitored parameter exceeds its trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids.
l Technical Specification 4.3.1.3 states the following:
The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip function" shall be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function.
- Neutron detectors are exempt from response time testing.
Technical Specification 4.3.2.3 states the following:
The ISOLATION SYSTEM RESPONSE TIME of each isolation function'shall be
. demonstrated to be within its limit at least once per 18 months. Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific isolation ;
' function.
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- Radiation monitors are exempt from response time testing.
Technical Specification 4.3.3.3 states the following:
The ECCS RESPONSE TIME of each ECCS function shall be demonstrated to be within the limit at least once per 18 months. Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months, where N is the ,
total number of redundant channels in a specific ECCS function. ;
Technical Specification 4.0.3 states that performance of a Surveillance Requirement within the specified time interval constitutes compliance with OPERABILITY requirements for a Umiting Condition for Operation and associated ACTION statements unless otherwise required by the- j specification. If Surveillance Requirements have not been performed, the licensee must comply !
I with the appropriate ACTION statements.
i 2. Circumstances Surroundina The Situation and Root Cause:
I L On March 21,1997, the NRC notified CP&L of an issue documented in a letter sent to ,
Washington Nuclear Power Unit 2 (WNP-2) on March 20,1997, regarding compliance with the l l Technical Specification definition fer instrumentation response time testing. For the issue E1-2 l, i
described by the NRC, verbatim compliance with the Technical Specification definition of response time testing for the affected instrumentation would require testing from the monitored parameter exceeding its setpoint at the sensor up to the actuating equipment. However, response time testing of some sensors, components, and systems has been eliminated through implementation of a BWR Owners' Group Ucensing Topical Report, NEDO-32291-A, " System Analyses For The Elimination of Selected Response Time Testing Requirements." Using the guidance of NRC Generic Letter 93-08,
- Relocation of Technical Specification Tables of instrument Response Time Limits," CP&L has relocated these instrument tables from the Technical Specifications to the Updated Final Safety Analysis Report. This change was approved as Amendments 171 and 202 to the Operating Licenses for BSEP Unit No.1 and BSEP Unit No. 2, respectively.
The NRC documented its review and acceptance of the BWR Owners' Group Licensing Topical Report NEDO-32291 in a letter dated December 28,1994. While elimination of some response time testing activities (such as response time testing of some instrument sensors) has been technically accepted by the NRC staff if such testing is performed in accordance with the guidelines of the NEDO-32291-A report, licensees have not been seeking license amendments to clarify the response time testing definition contained in the Technical Specifications based on the NRC approval of revised response time testing methodology.
CP&L has reviewed this issue and determined that the issue is also applicable to BSEP Unit No.1 and BSEP Unit No. 2. The root cause of this situation appears to be an oversight which occurred during the 10 CFR 50.59 review of the BWR Owners' Group revised response time verification methodology for implementation. CP&L has concluded that there is no unreviewed safety question based on the 10 CFR 50.59 evaluation that was prepared for the implementation of NEDO-32291-A.
CP&L requests that the NRC exercise enforcement discretion from the requirements of the applicable Technical Specifications for a sufficient period of time for the NRC staff to review and approve a license amendment application to incorporate the appropriate changes to c!arify the response time testing requirements for RPS, ECCS, and isolation actuation instrumentation.
The need for prompt action is required because failure to satisfy the response time testing specified in Technical Specifications 4.3.1.3,4.3.2.3, and 4.3.3.3 requires that the applicable systems be declared inoperable. This involves instruments for RPS, Isolation Actuation, and ECCS Actuation, and requires that both BSEP Unit No.1 and BSEP Unit No. 2 be taken to cold shutdown.
- 3. Safety Basis For The Reauest:
Qualitative response time testing has been completed in accordance with NEDO-32291-A for those instruments for which enforcement discretion is being requested.
The equipment in question are sensors associated with the RPS, Isolation Actuation, and ECCS Actuation instrumentation. The affected instrumentation has been tested in accordance with NEDO-32291-A. This provides assurance of equipment operability. These components are also l subject to periodic functional testing by channel functional testing and logic system functional testing. No failure mechanism has been identified that results in response time degradation for i these components. CP&L has determined that there is no impact on the BSEP Probabilistic Safety Assessment (PSA) core damage frequency estimate as a result of this condition.
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l CP&L believes that the RPS, Isolation Actuation, and ECCS Actuation Instrumentation are capable of performing their intended functions within designed response times and has verified response of these components using the alternate methodology in NEDO-32291-A. Based on the above, CP&L has determined that there is no safety significance and no potential adverse consequences associated with the proposed enforcement discretion.
- 4. No Unreviewed Safety Question or Sianificant Hazards Evaluation involved:
The NRC has provided standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists. A proposed license 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 consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. CP&L has reviewed this proposed enforcement discretion request and concluded that it's adoption does not involve a significant hazards consideration. The basis for this determination follows.
- a. The proposed enforcement discretion does not involve a significant increase in the probability or consequences of an accident previously evaluated.
BWR Owners' Group Licensing Topical Report NEDO-32291-A demonstrates that quantitative response time testing is redundant to other Technical Specification requirements. Qualitative tests are sufficient to identify failure modes or degradations in instrument response time and ensure operation of the associated systems within acceptance limits. There are ne known failure modes that can be detected by response time testing that cannot also be detected by other Technical Specification required tests.
Therefore, the requested enforcement discretion does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- b. The proposed enforcement discretion would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed enforcement discretion does not affect the capability of the associated systems to perform their intended function within the acceptance limits assumed in the plant safety analyses and required for successful mitigation of an initiating event.
This does not change the way in which any plant systems are operated or create the possibility of a new or different kind of accident.
- c. The proposed enforcement discretion does not involve a significant reduction in a margin of safety.
The current Technical Specification response times are based on the maximum allowable values assumed in the plant safety analyses. These analyses conservatively establish the margin of safety. As described above, the reliance on an attemate methodology (i.e., provided in the NEDO-32291-A report) will not affect l
l the capability of the associated systems to perform their intended function within the allowed response time used as the basis for the plant safety analyses.
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Plant and system response to an initiating event will remain in compliance with the assumptions of the safety analyses; therefore, the margin of safety is not affected. l CP&L has also concluded that this request for enforcement discretion does not involve an i unreviewed safety question based on the 10 CFR 50.59 evaluation that was prepared for the implementation of NEDO-32291-A.
- 5. Environmental Evaluation:
10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in an increase in individual or cumulative occupational radiation exposure.
l CP&L has reviewed this enforcement discretion request and concluded that the proposed action meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement of environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows.
- a. The proposed enforcement discretion does not involve a sigr.ificant hazards consideration, as shown in item 4 above.
- b. The proposed enforcement discretion does not result in a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite. The proposed enforcement discretion does not introduce any new equipment nor does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The proposed enforcement discretion does not alter the function of existing equipment and will ensure that the consequences of any previously evaluated accident do not increase.
Therefore, CP&L has concluded that there will not be a significant increase in the types or amounts of any effluent that may be released offsite and, as such, does not involve irreversible environmental consequences beyond those already associated with normal operation.
- c. These amendments do not result in an increase in individual or cumulative occupational radiation exposure.
- 6. Compensatory Measures:
Instrumentation response time testing has been conducted within the required surveillance frequencies for the instrument functions listed in BSEP Technical Specification Tables 3.3.1-1, j 3.3.2-1, and 3.3.3-1. The current response time testing fully complies with the guidelines i contained in the BWR Owners' Group Licensing Topical Report NEDO-32291-A. As previously l noted, this report has been reviewed and accepted by the NRC staff in a letter dated December 28,1994. Therefore, continued qualitative testing will provide an adequate level of testing to verify the proper function and response of the affected components. Therefore, no compensatory measures are needed in conjunction with the request for enforcement discretion.
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- 7. Justification For Duration of the Non-Compliance This non-compliance results from a process issue. The affected instrumentation has been verified functional in accordance with either the qualitative guidance contained in the BWR Owners' Group Licensing Topical Report NEDO-32291-A.
The basis for NEDO-32291-A methodology relies, in part, on the reliability, known failure modes, and the performance of other surveillance tests for the instrumentation. Other surveillance requirements that support operability include channel functional tests, channel calibration tests, and logic system functional tests. These surveillances are up-to-date and thereby provide an I independent verification that instrument channel and logic system operability exists. I 1
CP&L has determined that the issues identified by the NRC staff are applicable to BSEP Unit .
I No.1 and BSEP Unit No. 2. We request that the NRC exercise enforcement discretion from the requirements of Technical Specifications for a sufficient period of time for the NRC staff to review and approve a license amendment application to incorporate the appropriate changes to clarify the response time testing requirements for RPS, ECCS, and isolation actuation instrumentation.
- 8. Plant Nuclear Safety Committee Review:
This request for enforcement discretion and its basis have been reviewed by the BSEP Plant Nuclear Safety Committee (PNSC). The PNSC agrees that this request is in the best interest of 1 nuclear safety.
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- 9. Enforcement Discretion Criteria For The Plant Conditions:
Both BSEP Unit No.1 and BSEP Unit No. 2 are currently operating. Granting of this enforcement discretion is requested to avoid an unnecessary shutdown of both BSEP units as a result of forcing compliance with the Technical Specifications. Avoidance of such a shutdown would minimize potential safety consequences and operational risks associated with this shutdown.
- 10. Technical Specification Paaes For A Follow-up Amendment Reauest Enclosure 2 provides marked up pages for the Technical Specifications. The NRC inspection Manual, Part 9900: Technical Guidance stipulates that a licensee's license amendment request must be submitted with 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> following submittal of the request for enforcement discretion.
Therefore, CP&L will submit the follow-up license amendment request within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the written enforcement discretion request.
- 11. Adoption of Line-Item improvements Would Not Have Obviated The Need No line item improvement exists which would have obviated the need for this request for enforcement discretion. Implementation of the Improved Technical Specifications would not have I obviated the need for this request for enforcement discretion.
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- 12. AdditionalInformation Necessary Before A NRC Staff Decision l CP&L knows of no additional information that is necessary for processing of this request for enforcement discretion, i
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