ML20137F124
| ML20137F124 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/20/1985 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20137F129 | List: |
| References | |
| NLS-85-220, NUDOCS 8508260155 | |
| Download: ML20137F124 (2) | |
Text
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g Cp&L Carolina Power & Light Company SERIAL: NLS-85-220 AUG 2 01985 Director of Nuclear Reactor Regulation Attention:
' Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licersing 1
United States Nuclear Regulatory Commission l
Washington, DC 20555 BRUNSWICK STEAM ELECTRIC P; ANT, UNIT NOS.1 AND 2 i
DOCKET NOS. 50-325 & 50-324/LICtNSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT ECCS ACTUATION INSTRUMENTATION
Dear Mr. Vassallo:
SUMMARY
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Technical i
Specifications (TS) for the Brunswick Steam Electric Plant, Units 1 and 2. The proposed l
TS revises Table 3.3.3-1, Emergency Core Cooling System (ECCS) Actuation i
Instrumentation, by adding a footnote to allow required surveillance without placing the j
trip system in the tripped condition.
DISCUSSION Currently, when performing required surveillance on the Emergency Core Cooling System (ECCS) Actuation Instrumentation, the TS requires that the inoperable channel be placed i
in the tripped condition and/or that the associated ECCS be declared inoperable. This requirement places an unnecessary restriction on plant operation during instrument testing.
The proposed TS adds a footnote to Table 3.3.3-1, ECCS actuation
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instrumentation, to allow placing a channel in an inoperable status for up to two hours for required surveillance without placing the trip system in the tripped conditton provided at least one operable channel in the same trip system is monitoring the atfected parameter.
This change reflects the guidance provided in the GE BWR/4 Standard l
Technical Specifications (STS). In addition, this capability is already allowed by the TS for instrumentation of the Reactor Protection System (TS 3/4.3.1), Isolation Actuation (TS 3/4.3.2), Control Rod Withdrawal Block (TS 3/4.3.4), and Reactor Core Isolation Cooling System (TS 3/4.3.7). The proposed TS also reformats the table notations in Table 3.3.3-1; this is an administrative change only.
SIGNIFICANT HAZARDS ANALYSIS The Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50.92(c)). 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 consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from accidents previously evaluated; or (3) involve a significant reduction in a margin of. safety.
Carolina Power & Light Company has determined that the requested amendment:
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Does not involve a significant increase in the probability or consequences of accidents previously evaluated because allowing for testing of a channel as specified by the proposed TS does not prevent the instrumentation from performing its designed function. The proposed TS provides the limiting conditions for operation necessary to preserve the ability of the system to perform its intended function even l
during periods when instrument channels may be out of service because of maintenance. Therefore, when necessary, one channel may be made inoperable for brief intervals to conduct surveillance.
2.
Does not create the possibility of a new or different kind of accident than previously evaluated for the same reasons as described in item (1) above.
3.
Does not involve a significant reduction in the margin of safety. In addition to the reasons already given above, the proposed TS is consistent with the guidance provided in the GE BWR/4 STS and the other safety-related instrumentation listed above. The proposed change will not significantly affect the ability of the system to meet its design functions of initiating actions to mitigate the consequences of accidents. The margin of safety, therefore, is maintained.
l Based on the above, CP&L has determined that the proposed _ changes meet the criteria of l
10 CFR 50.92 (c) and, therefore, do not involve significant hazards considerations.
ADMINISTRATIVE INFORMATION The proposed Brunswick-1 and Brunswick-2 TS pages~are provided in Enclosures I and 2.
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 is enclosed as payment of this fee.
Should you have any questions concerning this submittal, please contact Mr. S. R.
Zimmerman at (919) 836-6242.
You s very t ly,
/4
. B. Cutter - Vice P sident Nuclear Engineering & Licensing GB/crs (1629NLU)
Enclosures cc:
Mr. W. H. Rutand (NRC-BNP)
Dr. 3. Nelson Grace (NRC-RII)
Mr. M. Grotenhuis (NRC)
Mr. Dayne H. Brown 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 belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.
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