BSEP-97-0144, Suppl to Application for Amends to Licenses DPR-71 & DPR-62, Revising Tech Specs 3.0 & 4.0 & Respective Bases for Sections to Incorporate Guidance Contained in NRC GL 87-09

Suppl to Application for Amends to Licenses DPR-71 & DPR-62, Revising Tech Specs 3.0 & 4.0 & Respective Bases for Sections to Incorporate Guidance Contained in NRC GL 87-09

ML20137Y785
Person / Time
Site:	Brunswick
Issue date:	04/14/1997
From:	Campbell W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137Y791	List: BSEP-97-0144, Suppl to Application for Amends to Licenses DPR-71 & DPR-62, Revising Tech Specs 3.0 & 4.0 & Respective Bases for Sections to Incorporate Guidance Contained in NRC GL 87-09 ML20137Y794
References
BSEP-97-0144, BSEP-97-144, GL-87-09, GL-87-9, TSC-87TSB16, NUDOCS 9704230235
Download: ML20137Y785 (8)

Text

4 CP&L Carolina Power & Light Company William R. Campbell PO Box 10429 Vice President Southport NC 28461 0429 Brunswick Nuclear Plant APR 141997 SERIAL: BSEP 97-0144 10 CFR 50.90 TSC 87TSB16 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 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS APPLICABILITY AND SURVEILLANCE REQUIREMENTS Gentlemen:

By tetter dated April 4,1996 (Serial: BSEP 96-0126), and supplemented by letters dated January 24,1997 (Serial: BSEP 97-0024), March 31,1997 (Serial: BSEP 97-0100), and April 2, 1997 (Serial: BSEP 97-0141), Carolina Power & Light (CP&L) Company requested a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2.

These proposed license amendments revise Technical Specifications 3.0 and 4.0, and respective Bases for these sections, to incorporate guidance contained in NRC Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specification (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements."

The purpose of this submittalis to revise' proposed Technical Specifications 4.0.1 and 4.0.3 to more closely conform with the guidance contained in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision 1, April 1995. These changes are being incorporated to support more expeditious NRC staff review of this license amendment request. As previously discussed with the NRC Project Manager, CP&L has requested i separate issuance of the portion of this license amendment request which adds to Technical l Specification 4.0.3 an allowance for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay before requiring declaration of the i equipment inoperable when a surveillance interval has been inadvertently exceeded. As a result, the enclosed revisions only address the necessary changes to Technical Specifications 4.0.1,4.0.3, and their associated Bases. Enclosure 1 provides a description of the specific revisions being made to incorporate the NUREG-1433 guidance.

CP&L has reviewed the proposed revisions described herein and has determined that the i conclusions of the significant hazards evalueuon published in the Federal Register on July 17, k;o{ j 1996 (61 FR 37297), remain valid.

9704230235 970414 l PDft ADOCK 05000324 ElIlflhl!hggg l

q. P PDR I M UO.7,9 Tel 910 457 2496 Fax 910 457 2803

l Document Control Desk i BSEP 97-0144 / Page 2 l

I Carolina Power & Light Company is providing, in accordance with 10 CFR 50.91(b), Mr. Mel Fry of the State of North Carolina with a copy of the proposed license amendments.

Please refer any questions regarding this submittal to Mr. Keith R. Jury, Manager - Regulatory Affairs, at (910) 457-2783.

l Sincerely, hM William R. Campbell WRM/wrm

Enclosures:

1. Description of Revision to License Amendment Request

2. Page Change Instructions

3. Typed Technical Specification Pages - Unit 1

4. Typed Technical Specification Pages - Unit 2 William R. Campbell, 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, and agents of Carolina Power & Light Company, h

0 0 Notary (Seal)

My commission expires: ll 4001 1

l l

l l

1 1

Oocument Control Desk

- BSEP 97-0144 / Page 3 pc (with enclosures): 1 U. S. Nuclear Regulatory Commission ATTN.: Mr. Luis A. Reyes, Regional Administrator l

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 l

1 U. S. Nuclear Regulatory Commission l ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738 The Honorable J. A. Sanford l Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Mel Fry Acting Director- Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS APPLICABILITY AND SURVEILLANCE REQUIREMENTS DISCUSSION:

By letter dated April 4,1996 (Serial: BSEP 96-0126), as supplemented by letters dated January 24,1997 (Serial: BSEP 97-0024), March 31,1997 (Serial: BSEP 97-0100), and April 2, 1997 (Serial: BSEP 97-0141), Carolina Power & Light (CP&L) Company requested revisions to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2.

These proposed license amendments revise Technical Specifications 3.0 and 4.0, and respective Bases for these sections, to incorporate guidance contained in NRC Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements."

Generic Letter 87-09 provides increased flexibility with regard to Technical Specification 3.0.4 by removing unnecessary restrictions on operational mode changes in those cases where conformance with an Action requirement already provides an acceptable level of safety for continued operation in any mode for an unlimited period of time. In addition, Generic Letter 87-09 includes a change to Technical Specification 4.0.3 to eliminate unnecessary plant I shutdowns caused by this specification when surveillance intervals are inadvertently exceeded.

The purpose of this submittal is to revise proposed BSEP Technical Specifications 4.0.1 and 4.0.3 to more closely conform with the guidance contained in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision 1, April 1995. These changes are being incorporated to support more expeditious NRC staff review of this license amendment request. I As previously discussed with the NRC Project Manager, CP&L has requested separate issuance of the portion of this license amendment request which adds to Technical Specificat;on 4.0.3 an allowance for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay before requiring declaration of the equipment inoperable when a surveillance interval has been inadvertently exceeded. As a result, the enclosed revisions only address the necessary changes to Technical Specifications 4.0.1,4.0.3, and their associated Bases. The portion of the license amendment request which allows operational mode changes in those cases where conformance with an Action requirement permits continued operation in any mode for an unlimited period of time will be submitted separately.

NUREG-1433, Revision 1 incorporates the guidance of NRC Generic Letter 87-09. CP&L's April 4,1996, license amendment request modified the existing Technical Specification wording consistent with the guidance of NRC Generic Letter 87-09. However, during review of the proposed license amendment request, the NRC staff expressed a preference for the specific wording and location of the applicable requirements, as contained in NUREG-1433.

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The existing BSEP Technical Specification 4.0.1 states the following:

Surveillance Requirements shall be applicable during the OPERATIONAL CONDITIONS or other states specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance requirement.

J In addition, the existing BSEP Technical Specification 4.0.3 provides further requirements regarding demonstration of meeting OPERABILITY requirements through surveillance testing.

The existing BSEP Technical Specification 4.0.3 states the following:

Performance of a Surveillance Requirement within the specified time interval shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated ACTION statements unless otherwise required by the specification. Surveillance requirements do not have to be performed on inoperable equipment.

The corresponding NUREG-1433 requirements are contained in Improved Technical Specification (ITS) Surveillance Requirement 3.0.1, which states:

SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Adopting ine wording NUREG-1433 Surveillance Requirement 3.0.1 as a replacement for BSEP Technica; Specifications 4.0.1 and 4.0.3 is an administrative change bccause the general requirements of NUREG-1433 Surveillance Requirement 3.0.1 are already contained in the two existing BSEP Technical Specifications. Therefore, CP&L is adopting the specific wording of NUREG-1433 Gurveillance Requirement 3.0.1 as a replacement for BSEP Technical Specifications 4.0.1. CP&L is also replacing the existing BSEP Technical Specification 4.0.3 l with the Generic Letter 87-09 allowance for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay before requiring declaration of the equipment inoperable when a surveillance interval has been inadvertently exceeded. The wording for the revised Technical Specification 4.0.3 parallels that contained in NUREG-1433.

The Bases sections associated w;th BSEP Technical Specification 4.0.1 and 4.0.3 are being combined and relocated to the Bases for Technical Specification 4.0.1. I NUREG-1433 Surveillance Requirement 3.0.3 addresses the area of concern in NRC Generic Letter 87-09 regarding the elimination of unnecessary plant shutdowns caused when surveillance intervals have been inadvertently exceeded. NUREG-1433 Surveillance l Requirement 3.0.3 states the following:

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met l may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of E1-2

the specified Frequency, whichever is less. This delay period is permitted to  !

allow performance of the Surveillance. l d

if the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered. I When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered.

The requirements of NUREG-1433 Surveillance Requirement 3.0.3 are equivalent to the requirements previously proposed in CP&L's license amendment request; therefore, CP&L 1 4

proposes to adopt the NUREG-1433 wording contained in Surveillance Requirement 3.0.3 as a  ;

i replacement for BSEP Technical Specification 4.0.3.

The proposed revisions to CP&L's previously submitted license amendment request are  ;

considered an administrative change to make CP&L's license amendment request consistent with the guidance of NUREG-1433. The first revision simply adopts NUREG-1433 wording j which is functionally equivalent to combining and relocating requirements already contained in

two existing BSEP Technical Specifications (4.0.1 and 4.0.3) to a single location (BSEP Technical Specification 4.0.1). The second revision adopts the NUREG-1433 wording which

, addresses the NRC Generic Letter 87-09 provisions for inadvertently missed surveillances. As such, CP&L has reviewed the proposed revisions described above and has determined that the conclusions of the significant hazards evaluation published in the Federal Register on July 17, 1996 (61 FR 37297), remain valid.

. Enclosure 2 provides page change instructions for incorporating the proposed revisions.

Enclosures 3 and 4 provide typed Technical Specification pages for BSEP Unit Nos.1 and 2, respectively.

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the specified Frequency, whichever is less. This delay period is permitted to a!Iow performance of the Surveillance.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered.

The requirements of NUREG-1433 Surveillance Requirement 3.0.3 are equivalent to the requirements previously proposed in CP&L's license amendment request; therefore, CP&L proposes to adopt the NUREG-1433 wording contained in Surveillance Requirement 3.0.3 as a replacement for BSEP Technical Specification 4.0.3.

The proposed revisions to CP&L's previously submitted license amendment request are i considered an administrative change to make CP&L's license amendment request consistent ,

with the guidance of NUREG-1433. The first revision simply adopts NUREG-1433 wording  !

which is functionally equivalent to combining and relocating requirements already contained in )

two existing BSEP Technical Specifications (4.0.1 and 4.0.3) to a single location (BSEP {

Technical Specification 4.0.1). The second revision adopts the NUREG-1433 wording which l addresses the NRC Generic Letter 87-09 provisions for inadvertently missed surveillances. As i such, CP&L has reviewed the proposed revisions described above and has determined that the conclusions of the significant hazards evaluation published in the Federal Register on July 17, 1996 (61 FR 37297), remain valid.

Enclosure 2 provides page change instructions for incorporating the proposed revisions.

Enclosures 3 and 4 provide typed Technical Specification pages for BSEP Unit Nos.1 and 2, respectively.

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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS APPLICABILITY AND SURVEILLANCE REQUIREMENTS PAGE CHANGE INSTRUCTIONS UNIT 1 Removed page Inserted page 3/4 0-2 3/4 0-2 B 3/4 0-2 B 3/4 0-2 B 3/4 0-3 B 3/4 0-3 8 3/4 0-4 B 3/4 0-4 B 3/4 0-5 PAGE CHANGE INSTRUCTIONS UNIT 2 Removed page Inserted page 3/4 0-2 3/4 0-2 8 3/4 0-2 B 3/4 0-2 8 3/4 0-3 8 3/4 0-3 B 3/4 0-4 8 3/4 0-4 B 3/4 0-5 E21