ML20155B155
| ML20155B155 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/27/1988 |
| From: | Mcduffie M CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20155B158 | List: |
| References | |
| NLS-88-230, TAC-65316, TAC-65317, NUDOCS 8810060210 | |
| Download: ML20155B155 (6) | |
Text
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Cp&L Carolina Power & Ught Compet.y SEP n lg SERIAL: NLS 88-230 10CFR50.90 TSC 88TSB17 United States Nuclear Regulatory Comrnission 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 MAIN STACK RADIATION MONITOR (TAC NOS. 65316/65317)
Gentlemen:
In accordance with the Code of Federel Regulations Title 10, Parts 50.90 and 2.101, Carolina Power 6 Light Company (CP&L/ hereby requests a revision to the Technical Specifications for the Brunswick Stearn Electric Plant (BSEP), Units 1 and 2.
The NRC Staff issued a Safety Evaluation Report (SER), dated March 5, 1987, which approved Carolina Power & Light Company's (CP&L) proposed design to meet the requirements of NUREO 0737 Itern II.E.4.2(7), at the Brunswick Steam Electric Plant.
However, two conditions were irnposed.
They were:
(1) to provide operability Technical Specifications for the main stack radiation isolation signal circuitry; and (2) to establish setpoints on the stack monitor for the purge and vent line isolation signal.
On April 23, 1987, CP&L submitted justifications for not inaking the required Technical Specification additions. On June 3,1988, the NRC, based on another Safety Evaluation Report, required that the Technical Specification changes be accomplished. This submittal provides proposed Technical Specification revisions to meet the irnposed conditions. provides a detailed description of the proposed changes and the basis for the changes. details the basis for the Company's decertaination that the proposed changes do not involve a significant hazards consideration. ptovides instructions for incorporation of the proposed changes into the Technical Specifications fur each unit. provides a summary of the proposed Technical Specification changes for each unit on a page by page basis. provides the proposed Technical Specification pages for Unit 1.
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t Documsnt Control D2sk NLS SS 230 / Page 2 provides the proposed Technical Specification pages for Unit 2.
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, bo 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. Stephen D. Floyd at (919) 836 6901.
Yours very truly, haa sp M. A. McDuffie Senior Vice President PDM / (\\cor\\88TSB17A)
Enclosures:
1.
Basis for Change Request 2.
10CFR50.92 Evaluation 3.
Instructions for Incorporation 4.
Summary List of Revisions 5.
Technical Specification Pages Unit.
6.
Technien1 Specification Pages Unit 2 cc:
Mr. Dayne H. Brown D. J. Nelson Grace Mr. W. H. Ruland Mr. B. C. Buckley M. A. McDuffie, having beer first duly sworn, did depose and way 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
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s ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIS 1 Al'3 2 NRC DOCKETS 50 325 & 50 324 OPERATING LICENSES DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDME.TI MAIN STACK RADIATION MONITOR BASIS FOR CHANGE REQUEST Pronosed Change 1 Revise BSEP TS 3/4.3.2 to include Limiting Conditions for Operation and Surveillance Requirements to ensure the capability of the main stack monitor signal circuitry to isolate containment purge and vent valves.
Proposed Change 2 Revise pages affected by Proposed Change 1 as necessary to correct editorial errors and to conform to formatting requirements such as repagination.
Basis NUREG-0737, Item II.E.4.2, "Containment Isolation Dependability," states that containment isolation dependability should include Position 7, "Containment Purge and Vent Valves must close on a high radiation signal." Additionally, 10 CFR Part 50.34a and Part 50, Appendix I require that radioactive material in effluents released to unrestricted areas be kept as low as reasonably achievable.
Primary containment isolation would normally occur from safety related low reactor water level and high containment pressure isolation signals which are already addressed in Technical Specifications. However, the nonsafety related main stack monitor provides another means to deteet and indicate a significant abnormal degradation of the reactor coolant cressure boundary. Also, the stack monitor signal is one of several i
signals that can initiate isolation of containment purge and vent valves
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(which are fission product burriers) and the stack monitor isolation function provides another level of assurance that the consequences of a l
loss of coolant accident will be mitigated.
Thus, the nonsafety related i
main stack monitor signal to close containment purge and vent isolation valvas on a high radiation signal is additional assurance that i
containment isolation.<ill occur when necessary.
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Corrispondence related to this issue is listed and annotated in the F
references portion of this enclosure.
The balance of the changes are editorial and make no chan6es to the technical content or requirements of cte Technical Specifications.
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In summary, the NRC has determined that the main stack radiation monitor and associated logic circuitry, as nonsafety-related equipment performing a safety related function, should be addressed in Technical Specifications.
References 1.
CP&L letter (NLS 86 256) dated August 26.1986 This letter stated that, on December 16, 1983, CP6L committed to provide drywell vent and purge valve isolation on primary containment high radiation signals in accordonce with NUREG 0737, Item II.E.4.2(7). It also provided a dese:*iption of the modifications to be performed and a schedule.
2.
GE6L 1cteer (NLS 86-439) dated December 17. 1986 This letter responded to NRC questions from NRC/CP&L November 13, 1986 and December 1, 1986 conference calls that requested f
i additiona'i information concerning separation of safety from nonsafety portions of the isolation circuitry, a relay used, and cables in the circuit.
3.
NRC letter dated March 5. 1987 l
This letter cransmitted the Safety Evaluation Report and the NRC's t
acceptance of CP&L's tiethod for compliance with NUREG 0737, ltem II.E.4.2(7).
However, two requirements were imposed:
(1) add TS for operability of the main stack monitor isolation signal i
circuitry and (2. add TS for the stack monitor setpoints and surveillance.
4 CP&L ?etter (MLS 87 088) dated April 23. 1987 CF6L submitttd justifications for not makin6 the required TS additions.
6 5.
EF G_lttle r da t e d June 3. '988 Af ter teviewing Cs&L's April 23, 1988 letter, the NRC transmitted ar.other Safsty Evaluation. Report that required the TS additions.
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6.
CP&L letter (NLS 88 159) dated July 22. 1988 This letter stated that CP6L plans to submit the required TS additions no later than September 30, 1988.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 6 50 324 OPCRATING LICENSES DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT MAIN STACK RADIATION MONITOR i
10CFR50.92 EVALUATION L
f.
The Commission has provided standards in 10CFR50.92(c) for determining I
whether a significant hatards consideration exists. A proposed amendment to an operating license for a facility involves no significant i
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 passibility of a new or different kind of accident from any accident previcusly evaluated, or (3) involve a significant j
reduction in a margin of safety, Carolina Power & Light Company has reviewed this proposed license amendment request and determined tha.t its adoption would not involve a significant hazards consideration.
The i
bases for this determination aru as follows:
Proposed Chance 1 Revise BSFP TS 3/4.3.2 to include Limitit.g Conditions for Operation and Surveillance Requirements to ensure the capability of the main stack monitor signal circuitry to isolate containment purge and vent valves.
Basis The change does not involve a significant hazards consideration for the fc11owing reasons:
1.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes do not affect the function or physical nature of any component or system associated with the probability of a Design Basis Accident (DBA) or Transient Analysis. The nonsafety related main stack radiation monitor signal circuitry to isolate the containment purge and vent valves is in addition to safety related signsla from the low reactor water level instrumentation and high containment pressure instrunentation for which there are existing Technical Specifications.
Thus, the main stack monitor signal provides i
additional assurance that, when necessary, primary containment i
vill be isolated.
Further, this function provides additional
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assurance that the consequences of an accident will be mitigated t
such that radiological effluents released to unrestricted areas l
will be kept as low as is reasonably achievable.
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2.
The main stack radiation monitor and associated signal circuitry are nonsafety related. The nonsafety related circuitry is electrically isolated from the existing safety related isolation logic circuitry. Thus, a failure of the nonsafety related main stack monitor and/or the associated nonsafety related circuitry will not affect the existirg safety related isolation signals and therefore, will not create the potential for a new or different kind of accident from any accident previously evaluated.
3.
The proposed amendment does not involve a significant reduction in the trargin of safety. The main stack radiation monitor signal setpoints are listed and controlled in the Brunswick Offsite Dose Calculation Manual (ODCM).
Changes to this document are submitted to the Staff as part of the Semi Annual Radioactive Effluent Release Report in accordance with BSEP TS 6.13.2.
As noted in an NRC letter dated June 3,1988, the setpoints are based on the guideline values of 10 CFR Parts 20 and 50, which are more i
conservative than those of 10 CFR Part 100.
Based on this fact, the proposed amendment actually augments the margin of safety, l
I Proposed Change 2 Revise pages affected by Proposed Change 1 as necessary to correct editorial errors and to conform to formatting requirements such as repagination.
Basis l
The change does not involve a significant hazards consideration for the following reasons:
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The changes are editorial only and make no changes to the i
technical content or requirements of the Technical Specifications.
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Therefore, the proposed amendment does not involve a significant j
increase in the probability or consequences of an accident j
previously evaluated.
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2.
The changes do not affect the function or physical nature of any component or system. Therefore,the proposed amendment does not
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create the: possibility of a new or different kind of accident from any accident previously evaluated.
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The changes are administrative only and as such are not applicable j
to any safety parameter. Therefore,the proposed amendment does not involve a significant reduction in the margin of safety.
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