ML20150C413
| ML20150C413 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/10/1988 |
| From: | Eury L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20150C418 | List: |
| References | |
| NLS-88-022, NLS-88-22, NUDOCS 8803180237 | |
| Download: ML20150C413 (16) | |
Text
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-.y P. O. Box 1551. Ralett, H. C. 27602 WMR 10 Mes SERIAL:
NLS-88-022 10CFR50.90 LYNN W. EURY 86TSB06 Sew vee nescet 86TSB13 Operations Support United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 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 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Gentlemen:
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 Specifications for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.
The proposed revision to TS Tables 3.3.5.9-1 and 4.3.5.9-1 change: (1) Action 121 a.,
Table Notation "***", and Table Notation "(f)" to remove out-of-date reference to the Augmented Off-Gas System (AOG) operation, (2) the applicability of the Main Condenser Off-Gas Treatment System noble gas activity monitor, (3) the required channel calibration gas standards for trip setpoint calibration of the Main Condenser Off-Gas Treatment System hydrogen monitor, (4) the applicability of the Main Condenser Off-Gas Treatment System hydrogen monitors, (5) the BSEP-2 bases 3/4.3.5.9 to remove the out-of-date hydrogen monitoring applicability statements, and for consistency, (6) table notations. provides a detailed description of the proposed changes and the basis for the changes. details the basis for the company's determination that the proposed changes do not involve a significant hazards consideration. provides instructions for incorporation of the proposed changes into the Technical Specifications for each unit. provides a summary of the proposed Technical Specification changes for each unit on a page by page basis.
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Documsnt Control D3sk NLS-88-022 / Pago 2 provides the proposed Technical Specification pages for each unit.
In accordance with the requirements of 10CFR170.12, a check for
$150 is also enclosed.
In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.
Please refer any questions regarding this submittal to Mr. Leonard I. Loflin at (919) 836-6242.
Yours very truly,
/
W N A' L. W.
Eury Senior Vice President EKN/ekn (86TSB06&l3)
Enclosures:
1.
Basis for Change Request 2.
10CFR50.92 Evaluation 3.
Instructions for Incorporation 4.
Summary List of Revisions 5.
Technical Specification Pages cc:
Mr. Dayne H.
Brown Dr. J.
Nelson Grace Mr. W. H. Ruland Mr.
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Eury, 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 e. gents of Carolina Power & Light Company.
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION BASIS FOR CHANGF REQUEST The Main Condenser Off-Gas Treatment System is utilized to reduce the concentration of radioactive non-condensible gases removed from the main condenser prior to releasing them out the plant stack.
Non-condensible gases are discharged from the main condenser via two, two stage, steam-jet air ejectors.
These gases then pass through off-gas preheaters, recombiners, after condensers, a 30 minute holdup line and high efficiency particulate filters as part of the Condenser Off-Gas System.
The gases then pass through the Augmented Off-Gas System, which contains a charcoal adsorber system, before being discharged via the stack. to this enclosure contains a diagram, taken from the updated FSAR (Figure 11.3.2-1, Amendment 4),
displaying the entire Main Condenser Off-Gas Treatment System.
The Condenser Off-Gas System has the capability of continuously monitoring the level of radioactivity, as well as the concentration of hydrogen within the process flow.
The radiation monitor's function is to prevent exceeding the release limits of 10CFR20 and Appendix I to 10CFR50.
The hydrogen monitor provides AOG System protection from explosive gas mixtures by initiating system bypass when high concentrations of hydrogen (2% by volume) are detected.
An additional alarm function is provided when the hydrogen concentration reaches the flamability limit (4% by volume).
The proposed amendment would revise the following areas:
1.
Presently BSEP-2 TS, Table 3.3.5.9-1 Action 121 a.,
contains information which describes the interim Gaseous Radwaste Treatment System prior to AOG System installation.
Information is also included in BSEP-2 TS Table 3.3.5.9-1, Notation "***" and Table 4.3.5.9-1, Notation "(f)" relative to the applicabf'ity once the AOG System is fully operational.
Since he AOG System is now installed and operational this information is unnecessary and no longer applies.
This proposed TS change would remove this out-of-date information.
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2.
The noble gas activity monitor of the Main Condenser Off-Gas Treatment System (see TS Table 3.3.5.9-1, Item 5.a and TS Table 4.3.5.9-1, Item 5.a) is currently required to be operable at all times.
The proposed TS change would require operability only during operation of the AOG System.
The monitor cannot perform its designed function unless the AOG System is in service; therefore, no purpose is served by requiring the monitor to be operable at all times.
The same is true for the Main Condenser Air Ejector Radioactivity Monitor (see TS Table 3.3.5.9-1, Item 4.a and TS Table 4.3.5.9-1, Item 4.a), which is only required when the Main Condenser Air Ejector is operable.
3.
Two separate hydrogen analyzers are located downstream of the recombiner of each condenser off-gas train.
The hydrogen concentration, in percent, is continuously displayed (digitally), as well as, fed to a recorder from the analyzer when the main condenser air ejectors are operable.
As stated previously, the hydrogen monitors utilize two trip setpoints (2% and 4% by volume).
The current requirements of TS Table 4.3.5.9-1 state that calibration shall be performed using both a 2% and 4% by volume hydrogen gas standard.
The proposed TS change would eliminate the specific reference to the 2% and 4% gas calibration standards, and would only require that gas standards alth a 0%-4%
hydrogen concentration be used.
This will provide needed flexibility in the calibration methodology and assure that appropriate gas standards are utilized to provide the greatest degree of accuracy in establishing the hydrogen monitor trip setpoints.
With the present specification there is no way to obtain a true 0%
hydrogen measurement or calibration.
The proposed change would, however, allow calibration at 0%
hydrogen, thus allowing a true 0% hydrogen measurement / calibration.
The true 0% hydrogen calibration would also allow detection and correction of the "zero shift" found in some detectors which causes displays of negative hydrogen concentrations.
Additionally, the Brunswick Plant is planning to upgrade the present Condenser Off-Gas System hydrogen monitors.
The proposed TS change would allow the flexibility to perform the channel calibration within the setpoint range of the monitor.
4.
The present TS Tables 3.3.5.9-1 and 4.3.5.9-1 specify that the hydrogen monitor shall be operable during recombiner train operation.
The proposed TS change revises this to state that the hydrogen monitor will be El-2
I operable during operation of the Main Condenser Air Ejector, since the recombiner train can be operable only when the Main Condenser Air Ejector is operable.
This will provide consistency in the operational conditions specified within the tables.
5.
The BSEP-2 Bases section 3/4.3.5.9 presently describes the provisions for explosive gas monitoring (hydrogen monitoring) as part of the Radioactive Gaseous Effluent Monitoring Instrumentation.
This section also contains statements which were placed in the Bases prior to installation of the recombiners to describe interim and future hydrogen monitoring applicability.
The proposed TS change removes this out-of-date information since the recombiners are now fully operational and the statements no longer apply.
6.
Presently, TS Tables 3.3.5.9-1 and 4.3.5.9-1 contain notations which describe the operability requirements of the Main Condenser Off-Gas Treatment System noble gas monitor, calibration gas standards required for Condenser Off-Gas System hydrogen monitor calibration, and operability requirements of the Condenser Off-Gas System hydrogen monitor as stated in the previous sections.
Revision of the applicable notations within these tables will be necessary to support the previously described proposed changes.
The symbols designating the individual notations will be modified to provide consistency throughout the notation section of the table.
These proposed TS changes are considered to be administrative and will not affect the operation of the Condenser Off-Gas or AOG Systems or their i
designed functions.
These proposed TS changes will not alter the intended functions of the Main Condenser Off-Gas Treatment System noble gas and hydrogen monitors.
The ability of these monitors to function as designed during system operation will not be affected.
None of the accident analyses presented in Chapter 15 of the Updated Final Safety Analysis Report (FSAR) will be affected by these changes.
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i ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION 10CFR50.92 EVALUATION The. Commission has provided standards in 10CFR50.92(c) for determining.whether a significant hazards _ consideration exists.
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 any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration.
The bases for this determination are as follows:
The Main Condenser off-Gas Treatment System is utilized to reduce the concentration of radioactive non-condensible gases, removed from the main condenser, prior to releasing them out the plant stack.
The system has the capability of continuously monitoring the level of radioactivity, as well as the concentration of hydrogen within the process flow.
The radiation monitor's function is to prevent exceeding the release limits'of 10CFR20 and Appendix I to 10CFR50, while the hydrogen monitor provides AOG System protection from explosive gas mixtures by initiating system bypass when high concentrations of hydrogen (2% by volume) are detected.
An j
additional alarm function is provided when the hydrogen concentration reaches the flamability limit (4% by volume).
PROPOSED CHANGE 1:
This change would remove the out-of-date information contained in TS Table 3.3.5.9-1, Action 121 a., and Notation
"***" and in TS Table 4.3.5.9-1 Notation "(f)".
The information was placed in these sections to deacribe the interim Gaseous Radwaste Treatment System prior to AOG System installation and the applicability once the AOG System was fully operational.
The AOG Systen has since been E2-1 l
installed and placed in operation; therefore, the information is no longer applicable or necessary.
Basis The change does not involve a significant hazards consideration for the following reasons:
1.
The proposed change is an administrative change to the TS which will clarify Action 121 by removing out-of-date information relative to the description of the interim Gaseous Radwaste Treatment System prior to AOG System installation.
The applicability information contained in Notations "***" and "(f)" will also be administratively removed since it is no longer necessary.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The proposed change is purely administrative and has no affect on the design or operation of the Main condenser Off-Gas Treatment System and, therefore, does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed change will reduce potential confusion and enhance the ability to interpret TS Tables 3.3.5.9-1 and 4.3.5.9-1 by administratively removing the out-of-date information.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant reduction in the margin of safety.
PROPOSED CHANGE 2:
This change would require operability of the Main condenser Off-Gas Treatment System noble gas monitor only during operation of the AOG System rather than at all times as currently required.
The monitor cannot perform its designed function unless the AOG System is in service; therefore, no purpose is served by requiring the monitor to be operable at all times.
Basis The change does not involve a significant hazards consideration for the following reasons:
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1 1.
The accidents' analyzed in Chapter 15 of the Updated FSAR are not affected by-the proposed changes to the condenser Off-Gas System noble gas radiation monitor.
The Main Condenser Off-Gas Treatment System noble gas monitor will still perform its designed function of providing a high radiation alarm when the radiation level in the AOG Charcoal Adsorber System gaseous discharge reaches a predetermined level during system operation.
Based on this reasoning,_CP&L has determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The designed function of the Main Condenser Off-Gas Treatment System noble gas monitor is to alarm locally and in the control Room, when the radiation level in the AOG Charcoal Adsorber System gaseous discharge reaches a predetermined level, during AOG System operation.
The designed function of this monitor will not be altered by the proposed change.
The change in noble gas monitor operability requirements will be i
consistent with the monitor's design function.
Based on this reasoning, CP&L has determined that the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The noble gas monitor serves no purpose when the AOG System is out of service.
Revising the operability requirements of the monitor to be consistent with that of the AOG System will not affect the design function of the monitor and, therefore, does not involve a significant reduction in the margin of safety.
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PROPOSED CHANGE 3:
This change would eliminate the specific reference to the 2%
and 4% gas calibration standards currently required for calibration, and would only require that gas standards with a 0%-4% hydrogen concentration be used.
This added flexibility would permit calibration at 0% hydrogen, thus allowing a true 0% hydrogen measurement / calibration.
The true 0% hydrogen calibration would also allow detection and correction of the "zero shift" found in some detectors which causes displays of negative hydrogen concentrations.
Additionally, the proposed change would allow the flexibility to perform channel calibrations within the r
setpoint range of the upgraded hydrogen monitor planned for future installation.
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s Basis The change does not_ involve a significant hazards consideration for the following reasons:
1.
The accidents analyzed in Chapter-15 of the Updated FSAR are not affected by tha proposed change to the r
Condenser Off-Gas System hydrogen monitor.
The condenser Off-Gas System hydrogen monitor will still perform its designed function of system protection against potentially explosive gas mixtures.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The designed function of the Condenser Off-Gas System hydrogen monitor is to initiate system bypass, upon exceeding the monitor's setpoint, when the AOG System is in service.
The designed function of this monitor will not be affected by the proposed change.
The change in hydrogen analyzer / monitor calibration will enhance the calibration methodology, but will not alter the monitor's setpoints.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed change to the hydrogen analyzer / monitor calibration will not alter the monitor's setpoints or corrective actions should a setpoint be exceeded.
The change will merely provide an enhanced means for calibration of the hydrogen concentration displays and setpoints.
This will provide additional capability for establishing the accuracy of the displays and sotpoints, thus enhancing the margin of safety.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant reduction in the margin of safety.
t PROFOSED CHANGE 4:
This change would modify the notations of Table 3.3.5.9-1 and Table 4.3.5.9-1 to specify operation of the hydrogen monitors when the main condenser air ejectors are operable rather than wuen the recombiner train is operable.
This change will provide consistency of the operational designations specified in these tables.
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Basis The change does not involve a significant hazards consideration for the following reasons:
1.
The hydrogen monitor is designed to protect the AOG system from potentially explosive gas mixtures during system operation.
This function will not be affected, since the recombiner train cannot be operational unless the main condenser air ejectors are in service.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
As stated previously, the change in hydrogen monitor operability designation will not affect the designed function of the monitor.
The change is only being made to provide consistency in the operational conditions specified in the notations of Table 3.3.5.9-1 and Table 4.3.5.9-1 and, therefore, does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed change in hydrogen monitor operability designation will provide clarification and consistency within the specification to enhance its interpretation, but will not alter the actual operation of the monitor.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant reduction in the margin of safety.
PROPOSED CHANGE 5:
This change would remove the out-of-date information contained in the BSEP-2 Bases 3/4.3.5.9.
This information was placed in the Bases section to describe the provisions for explosive gas monitoring prior to the installation of recombiners, along with a deceription of an interim system.
Since the Recombiner Trains and AOG System are now installed and operational, this information no longer applies.
A 10CFR50.92 significant hazards evaluation is not provided for this change since the Bases are only summary statements in support of the Technical Specifications, and are not considered part of the actual Technical Specifications consistent with the provisions of 10CFR50.36.
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PROPOSED CHANGE 6:
This change revises the applicable notations within TS Tables 3.3.5.9-1 and 4.3.5.9-1 in support of the previously described proposed changes, and revises the single asterisk, multiple asterisk, and alpha character notational symbols to alpha chare.cters only.
Basis The change does not involve a significant hazards consideration for the following reasons:
1.
The proposed change is an administrative change to the TS which will provide notational consistency throughout Tables 3.3.5.9-1 and 4.3.5.9-1 and, therefore, does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The proposed change is purely administrative and aside from the notational changes previously described, does not represent a change in the content of the notations.
The change will provide clarity and consistency within the tables, thereby enhancing their interpretation.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed change administratively supports the previously decribed proposed changes and provides consistency of notational symbols throughout Tables 3.3.5.9-1 and 4.3.5.9-1.
Based on this reasoning, CP&L has determined that the proposed chango does not involve a significant reduction in the margin of safety.
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ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION INSTRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to Operating Licenses DPR-71 and DPR-62) would be incorporated as follows:
UNIT 1 Remove Pace Insert Pace 3/4 3-69 3/4 3-69 3/4 3-70 3/4 3-70 3/4 3-72 3/4 3-72 3/4 3-73 3/4 3-73 3/4 3-74 3/4 3-74 3/4 3-75 3/4 3-75 3/4 3-77 3/4 3-77 UNIT 2 Remove Pace Insert Pace 3/4 3-69 3/4 3-69 3/4 3-70 3/4 3-70 3/4 3-71 3/4 3-71 3/4 3-72 3/4 3-72 3/4 3-73 3/4 3-73 3/4 3-74 3/4 3-74 3/4 3-75 3/4 3-75 3/4 3-77 3/4 3-77 B3/4 3-5 B3/4 3-5 E3-1 i
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ENCLOSURE 4 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SilMMARY LIST OF REVISIONS UNIT 1 Paces Descriotion of Chances 3/4 3-69 Change notation "*" to "(b)"
c 3/4 3-70 Change notation "*" to "(b)",
"**" to "(c)",
"A**"
to "(c)".
and change the applicability of the Noble Gas Activity Monitor to "(d)"
3/4 3-72 Change notation "*" t?. "(b}",
"**" to "(c)", delete notation
"***; At all times during recombiner train operation" and add item "(d), During operation of the Off-Gas Treatment System" 3/4 3-73 Change notation "*" to "(f)"
3/4 3-74 Change nott, tion "*" to
"(f)","**" to "(g)",
and change the mode in which surveillance is required for the Noble Gas Activity Monitor to "(h)"
3/4 3-75 Change notation "*" to "(f)"
and "***" to "(g)"
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3/4 3-77 Change item (e) from "The channel calibration shall include the use of standard gas samples containing a nominal;
Four volume percent hydrogen, balance nitrogen" to "The channel calibration shall include the use of standard gas samples within 0-4 volume percent hydrogen," change notation "*"
to "(f)" and "**" to "(g)",
delete notation "***, During recombiner train operation,"
and add item "(h), During operation of the Augmented Off-Gas Treatment System" UNIT 2 Paaes Descriotion of Chances 3/4 3-69 Change notation "*" to "(b)"
3/4 3-70 Change notation "*" to "(b)",
"**" to "(c)",
"***" to "(d)",
and "****" to"(C)"
3/4 3-71 Delete "(Prior to the Augmented Off-Gas Treatment System becoming operational, the GASEOUS RADWASTE TREATMENT SYSTEM shall refer to the 30-minute holdup line including stack filtration)" from Action 121, item a.
3/4 3-72 Change notation "*" to "(b)",
" * * " to " (c) ", "***" to "(d)",
delete notation "****, At all times during recombiner operation," and change item
"(d)" from "At all times once the Augmented Off-Gas Treatment System becomes operational" to "During operation of the Augmented Off-Gas Treatment System" E4-2
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3/4 3-73 Change notation "*" to "(f)"
3/4 3-74 Change notation "*" to "(f)",
"**" to "(g)", and "***" to
" (h) "
3/4 3-75 Change notation "*" to "(f)"
and "****" to "(g)"
3/4 3-77 Change item (e) from "The che.nnel calibration shall include the use of standard gas samples containing a nominal;
Four volume percent hydrogen, balance nitrogen" to " The channel calibration shall include the use of standard gas samples within 0-4 volume percent hydrogen," change notation "*"
to "(f)" and "**" to "(g)",
"***" to "(h)" delete notation
"****, During recombiner train operation," delete operational contingencies in items (f) and (h) associated with the AOG System, and change item (h) to "During operation of the Augmented Off-Gas Treatment System" B3/4 3-5 Delete "the hydrogen monitors will become applicable...which will serve in the interim" from Bases Section 3/4 3.5.9 i
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l ENCLOSURE 5 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION TECHNICAL SPECIFICATION PAGES l
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