ML20154L164
| ML20154L164 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/19/1988 |
| From: | Mcduffie M CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20154L168 | List: |
| References | |
| NLS-88-174, NUDOCS 8809260114 | |
| Download: ML20154L164 (8) | |
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Cp&L Carolina Pcwer & Light Company SEP 10 1968 I
SERIAL:
NLS 88174 10CFR50.90 88TSB18 United States Nuclear Regulatory Cor:nission ATTENTION: Document Control Desk Vashington, DC 20555
'1RUNSWICK STEAM ELECTRIC PLRIT, UNIT NOS. 1 AND 2 DOCKET NOS. 50 325 6 50 324/ LICENSE NOS. DPR.71 6 DPR 62 REQUEST FOR LICENSE AMENDMENT DRWELL SUPPRESSION CHAMBER VACUUM BREAKER ACTIONS Centlemen:
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 Steem Electric Plant (BSEP), Units 1 and 2.
The proposed change revises the actions==sociated with Teebnical Specification 3/4.6,4 to clarify the alternative actions to be ta).an if the existing actions cannot be taken. To do this, existing Action 3/4.6.4 d is being incorporated into Actions 3/4,6.4 a.
3/4.6.4,b, and 3/4.6,4,c, and being deleted as a separate action. 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 locorporation of the proposed changes into the Technical Specifications for each unit.
Enclosurc 4 provides a summary of the proposed Technical Specification changes for each unit on a page by page basis.
Erclosures 5 and 6 prnvide the proposed Technical Specification pages for each unit.
In accordanco with the requirements of 10CpR170,12, a chack for $150 is also enclosed.
In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, Cr&L requests that the proposed amendments, once approved by the NRC, be issued with an Il w /ckP d 4,5,
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I Documsnt Control Dssk NLS 88174 / Page 2 effective date to be no later than 60 days from the issuance of the amendment.
Please refer any questions regarding this submittal to Mr. Stephen D.
Floyd at (919) 836 6901.
l Yours very truly,
)g?l8l" M. A. McDuffie Senior Vice President i
Nuclear Generation l
BAB/bab(\\cor\\88tsbl8)
Eaclosures:
1.
Basis for Change Request 2.
10CPR50.92 Evaluation 3.
Instructions for Incorporation 4
Suttmary List of Revisions 5.
Unit 1 Technical Specification Pages 6.
Unit 2 Technical Specificatton Pages i
ec:
Mr. Dayne M. Brown Dr. J. Nelson Crace Mr. V. H. Ruland Mr. B. C. Buckley M. A. McDuffie, 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, cepleyees, contractors, and aEents of Carolina Power 6 Light Cortpany.
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r ENCLOSURE 1 l
I BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 l
NRC DOCKETS 50 325 & 50-324 OPERATING LICENSES DPR 71 & OPR-62
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REQUEST FOR LICENSE AMENDMENT BASIS FOR CRANGE REQUEST j
L Proposed Change i
Incorporate the requirements of Action 3.6,4.1.d into each of the previous Actions, 3,6.4.1.a. 3.6.4.1.b, and 3.6.4.1.c, and delete
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existing Action 3.6,4.1 d.
Basis 1
Technical Specification 3.6.4.1 requires that all drywell suppression
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chambor vacuum breakers be OPERABLE and in the closed position with the t
position indicator OPERABLE, and an opening setpoint of f 0.5 paid.
This requirement applies in Operational Conditions 1, 2, and 3.
t There are currently four action statements associated with Technical Specification 3.6.4.1.
Action 3.6,4.1.a applies if no more than two drywell suppression chamber vacuum breakere are inoperable for opening but are known to be in the closed position, Operation may continue until the next cold shutdown provided that Surveillance Requirement 4,6.4.1 a. which requires that each vacuum breaker be exercised through l
one complete cycle and verified closed, is performed on the operable vacuum breakers within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and at least once per 15 days thereafter until the inoperable vacuum breakers are restored to operable status.
Action 3.6.4.1.b applies iC one drywell suppression chamber vacuum breaker is in the open position, as indicated by the position indlesting system, Operation may continue provided that Surveillance Requirement 4.6,4.1.a. which requires that each vacuum breaker be exercised through one complete cycle and verified closed, is performed on the operable vacuum breakers and Surveillance Requirement 4.6.4.1,b, which requires that a test be conducted that verifies that the differential pressure is maintained greater than 1/2 of the initial differential pressure for one hour without nitrogen makeup, is perforced within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter untti the inoperable vacuum breaker is restored to the closed position.
Action 3.6,4,1.c applies if the position indicator of any drywell-suppression chamber vacuum breaker is inoperable.
Operation may continue provided that Surveillance Requirement 4.6.4.1,b, which requires that a test be conducted that verifies that the differential pressure is maintained greater than 1/2 of the initial differential pressure for one hour without nitrogen makeup, is performed within El 1
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1 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and at least c,nce per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter until the inoperaole position indicator is returned to Operable status, j
Action 3.6.4.1.d states, "Otherwise, be in at least HOT SI'"TDOWN within i
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
l The intent of Action 3.6,4.1.d is to provide alternate action I
requirements if the requirements specified in Action 3.6.4.1.a.
l 3.6.4.1.b. or 3.6.4.1.c cannot be met, for example, if the 1
circumstances described in Action 3.6.4.1.a apply but Surveillance Requirement 4.6.4.1.a cannot be perfurned on the vacuum breakers within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, Action 3.6.4.1.d applies.
Likewise, if the circumstances 4
described in Action 3.6.4.1.b apply but Surveillance Requirerents 4.6.4.1.a and 4.6.4 1.b cannot be performed in the specified time, j
Action 3.6.4.1.d applies.
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The way in which the existing actions are listed could imply that if the circumstances of Actions 3.6.4.1.a. 3.6.4.1.b, or 3.6.4.1.c do not apply, then Action 3.6.4.1.d should be taken instead of following the requirements of Technical Specification 3.0.3, which requires that the unit be placed in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless corrective measures are i
completed that permit operation under the permissible action statements.
Or, the existing actions could imply that Technical Specification 3.0.0 applies if the requirements of Actions 3.6.4.1.a. 3.6.4.1.b or 3.6.4.1.c cannot be met.
l The proposed change will eliminate confusion over the interpretation of 1
Technical Specification 3.6.4.1 action statements.
The requirement described in Action 3.6.4.1.d vill be included in eaah of the previous Action statements, 3.6.4.1.a. 3.6.4.1.b. and 3.6.4.1.c. ao that it is clear that tne alvernative action is not Technical Specification 3.0.3, but to be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOW within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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ENCLOSURE 2 BRUNSWICK STFAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 & 50 324 OPERATING LICENSES DPR.71 & DPR.62 REQUEST TOR LICENSE AMENDMENT 10CTR50.92 EVAI.l'ATION The Commission has provided standards in 10CTR50.92(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 prev ously 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 l
adoption vo11d not involve a significant hazards consideration. The bases for this determination are as follows:
Procosed Change I
Incorporate the requirements of Action 3.6.4.1.d into each of the previous Actions, 3.6.4.1.e, 3.6.4.1.b. and 3.6.4.1.c and delete i
existing Action 3.6.4.1.d.
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1 The change does not involve a significant hazards consideration for the following reasons:
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The proposed change clarifies the existing requ'.rement of Technical Specification 3.6.4.1.
It does not impact plant equipment or design; it only provides a clearer statement of the actions to be taken if Technical Specification 3.6.4.1 cannot be met,thereby providing assurance that the proper actions are taken when necessary. The probability of an accident is not increased because the requirement of Technical Specification 3.6.4.1 and its actions have not changed; the actions have only been clarified.
The same is true for the consequences of an accident they have not changed because the requirements of Technical Specification 3.6.4.1 and its actions have not changed.
2.
The proposed amendaent does not create the possibility of a new or different kind of accident from any accident previously evaluated because the requirements of Technical Specification 3.6.4.1 and its actions have not changed. The proposed change requires that if Actions 3.6.4.1.a. 3.6,4.1.b or 3.6.4.1.c cannot be met, the unit must be in hot shutdown within 12 hou:4 and in cold shutdown E2 1
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within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, just as Technical Specification 3.6.4.1 l
and its actions currently require.
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The proposed amendment only clarifies the existing requirement of
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Technical Specification 3.6.4.1 and its actions.
It does not
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change the design or operation of plant equipment, nor does it change the intent of any requirements provided in the Technical Specifications. Therefore, it does not involve a significant reduction in the margin of safety.
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V ENCLOSURE 3 SRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 6 50-324 OPERATING LICENSES DPR 71 & DPR-62 REQUEST FOR LICENSE AMENDMENT 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 Par.e Insert Page 3/4 6 18 3/4 6 18 b
UNIT 2 Remove Page Insert Pare 3/4 6 18 3/4 6 18 4
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ENCLOSURE 4 BRUN, WICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50 324 OPERATING LICENSES DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT
SUMMARY
LIST OF REVISIONS UNIT 1 Pages Description of Changes 3/4 6 18 Move the requirements described in Action 3.6.4.1.d into Actions 3.6.4.1.a, 3.6.4.1.b, and 3.6.4.1.c and delete Action 3.6.4.1.d.
UNIT 2 Pages Description of Changes 3/4 6-18 Nove the requirements described in Action 3.6.4.1.d into Actions 3.6.4.1.a, 3.6.4.1.b, and 3.6.4.1.c and delete Action 3.6.4.1.d.
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