ML20155H127
| ML20155H127 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/13/1988 |
| From: | Eury L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20155H130 | List: |
| References | |
| NLS-88-117, NUDOCS 8806200197 | |
| Download: ML20155H127 (7) | |
Text
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--.u P. o. Box 1551
- Raleigh. N. C. 27602 a
JUN 13 $88 LYNN W. EURY.
SERIAL:
NLS 88-117 senior vice presi*nt 10CFR50.90 D" "8 **
87TSB02 United States-Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555' BRUNSWICK STEAM ELECTRIC PIANT, UNIT NOS.'l AND 2
- DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT RADIOACTIVE 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
'Stean Electric Plant (BSEP), Units 1 and 2.
The proposed changes to Technical Specifications 3.3.5.8 and 3.3.5.9 clarify the limiting conditions for operation by simplifying the options available when a monitoring instrument is found with a non conservar.ive alarm / trip setpoint. provides a detailed description of the proposed changes and the basis for the changes. details the b_ asis 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. provides the proposed Technical Specification pages for
. Unit 1. provides the proposed Technical Specification pages for Unit 2.
In accordance with the requirements of 10CFR170.12, a check for $150 is also enclosed.
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~8806200197 880613 PDR ADOCK 05000324 9
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'..'Documsnt-Control - Desk NLS-88-ll7 / Page 2 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.-Stephen D.
Floyd at-(9193 036 6901.
Yours very truly,
/
/hW L. W. Eury BAB/bab(\\cor\\87tsbO2)
Enclosures:
1.
Basis for Change Request 2.
10CFR50.92 Evaluation 3.
Instructions for Incorporation 4.
Summary List of Revisions 5.
Unit 1 Technical Specification Pages 6.
Unit 2 Technical Specification Pages cc:
Mr. Dayne H. Brown Dr. J. Nelson Grace Mr..W. H. Ruland Mr. E. D. Sylvester L. W. 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 agents of Carolina Power &
Light Company.
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t ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 & 50-324 OPERATINC LICENSES DPR 71 & DPR-62 REQUEST FOR LICENSE AMENDMENT BASIS FOR CHANGE REQUEST Pronosed Channe Delete the phrase "or change the setpoint so it is acceptably conservative" fr's Action Statements 3.3.5.8.a and 3.3.5.9.a.
Basis The radioactive liquid and gaseous effluent monitorin5 instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid and gaseous effluents during actual or potential releases of such effluents. The alarm / trip setpoints are calculated in accordance with the Offsite Dose Calculation Manual to ensure that the alarm / trip will occur prior to exceeding the limits of 10CFR50 Part 20.
Currently, three options are described in Technical Specifications 3.3.5.8 and 3.3.5.9 for dealing with a monitoring instrument which is found with'a non conservative alarm / trip setpoint:
(1)
Immediately suspend the effluent release monitored by the channel, (2)
Declare the channel inoperable, or (3)
Change the setpoint so it is acceptably conservative.
.The proposed change deletes the third action option, thereby focusing attention un either immediate suspension of releases or declaracion of the instrument as inoperable. By declaring the instrument inoperable, the operator follows the action statement requirements for an inoperable instrument, which requires suspension of releases unless samples are periodically taken to show that the appropriate limits are not being violated.
The action statements describe acceptable short-term corrective actions and are not irtended to describe specific long-term corrective actions, such as restoration of the non-conservative setpoint to an acceptable value.
Restoration of the required function to the "normal" condition is always an available, and preferable, option.
However, in problem situatione, main concern lies with environmental safety, and the short term actions will provide immediate protection.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT 10CFR50.92 EVALUATION The Commission has provided standards in 10CFR50.92(c) for determining l.
whether a significant hazards consideration exists. A proposed amendment to an operatin5 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 l
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:
Pronosed Channe Delete the phrase "or change the setpoint so it is acceptably conservative" from Action Statements 3.3.5.8.a and 3.3.5.9.a.
Basis The change does not involve a significant hazards consideration for the following reasons:
l 1.
Elimination of the short term option to correct a setpoint found i
to be non-conservative focuses attention on the two remaining options which provida immediate actions to preclude any unwarranted radiation releases via the liquid or gaseous effluent pathways. Restoration of the non-conservative setpoint to an acceptable value remains a viable long-term option; however, in the short term, the more immediate actions provided to preclude releases will be considered first, thereby reducing the possibility that harmful effluents will be released while the problem is being evaluated.
Thus, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
This change v3.11 provide for immediate mitigative action if an effluent monitoring instrumentation setpoint is found to be non-conservative, thereby precluding unwarranted effluent release. No l
new or different types of accidents become possible since deleting l
the statement "or change the setpoint so it is acceptably 1
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8 conservative" focuses attention on mitigating potential accidents already evaluated rather than on recalibration of the instrument.
3.
Attention will be focused on immediate actions to be taken if setpoints are found to be non-conservative. This could provide a quicker operator response and, therefore, less potential for o release of harmful effluents. Therefore, the proposed amendmen.*.
does not involve a significant reduction in the margin of safety.
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.s ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 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:
i UNIT 1 Remove Page Insert Page 3/4 3-62 3/4 3-62 3/4 3-68 3/4 3-68 UNIT 2 Remove Page Insert Pare 3/4 3-62 3/4 3-62 3/4 3-68 3/4 3-68 E3-1
.s 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
SUMMARY
LIST OF REVISIONS UNIT 1 Za&A1 Descriotion of Chanres 3/4 3-62 Delete "or change the setpoint so it is acceptably conservative" and add "or" to the statement prior to that.
3/4 3-68 Delete "or change the setpoint so it is acceptable conservative."
UNIT 2 Pages Descriotion of Channes 3/4-3-62 Delete "or change the setpoint so it is acceptably conservative" and add "or" to the statement prior to that.
3/4 3 68 Delete "or change the setpoint so it is acceptable conservative."
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