ML20196A236
| ML20196A236 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/22/1988 |
| From: | Eury L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20196A242 | List: |
| References | |
| NLS-88-114, NUDOCS 8806290494 | |
| Download: ML20196A236 (7) | |
Text
,
Carolina Power & Ught Comper {
P. o Bou 1551
- Ra5gh, N C 27602 JUN 2 21988 LYNN W. WRY SERIAL:
NLS-88 114 Senior Vice President 10CFR50,90 ocerations succort 87TSB05 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 RFOUEST FOR LICENSE AMENDMENT Rm0TE SHUTDOWN MONITORING INSTRUMENTATION SURVEILIANCE Gentlemen:
In accordanca 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 changes to Section 3/4 3.5 delete two residual heat removal (RHR) service water discharge differential pressure instruments for which operability is not required to ensure that the RHR and service water systems function ac designed. provides a detailed description of the proposed changes and the basis for the charges. 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.
Enclosures 5 and 6 provide 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 gk into copies of the Technical Specifications, CP&L requests thet the g
proposed amendments, once approved by the NRC, be issued with an p
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.Decument Control Dask NLS 88-114 / Page 2 effective dato 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,
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L. W. Eu V
i BA3/ bah (\\cor\\87tsb06) i Enclosutes:
1.
Basis for Chcnge 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. B. C. Buckley 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 l
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l 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 AMENDHEIC BASIS FOR CHANGE REOUESI Prooosed Change Delete Item 9, "Residual Hest Reseval Service Water Discharge Differential Pressure" from Tahl;s 3.3.5.2 1 and 4.3.5.2 1.
Basis Technical Specification Bases Section 3/4.3.5.2 states that the OPERABILITY of the remote shutdown monitoring instrumentation ensures that sufficient capability is available to permit shutdown and maintain HOT SHUTDOWN from locations outside the control room.
This capability is required in the event control room habitability is lost.
Its r6quirement is consistent with General Design Criterion 19 of 10CFR50.
Technical Specification 3/4.3.5.2 specifies operability requirements for remote shutdown monitoring instruments Ell PDT N002BX and Ell-PDI 3344.
Instrument E11 PDT N002BX measures the pressure differential between the shell, or RHR side, and the tube, or service water side, of the RHR heat exchanger and transmits the signal to indicator Ell PDI 3344 which is located on the Remote Shutdown Panel (RSDP).
During remote shutdown, the RHR heat exchanger serves as the heat sink for suppression pool cooling and shutdown cooling.
Indicator Ell PDI :344 does not provide the operator any indication that the RHR and/or RHR servic, water systems are operating or "in service."
The instrument provides information on relative system pressures only; it does not enhance the~ operation of the RHR heat exchanger or RHR service water system with cespect to establishing or mainteining hot or cold shutdown.
A detailed procedure, "Plant Shutdown from Outside Control Room,"
provides specific instructions for placing the RHR and RRR service water systems into suppression pool coolins and shutdown cooling modes.
Both modes of cooling are established and aaintained by setting the RHR service water booster pump run currents and the RHR system flow to predetermined values.
The Ell PDI 3344 indicator is not used to establish or verify flow rates and reference to RHR heae exchanger tube.
to-shell side pressure differential is never made in the procedure.
Because these instruments are not relied urson as remote shutdown monitoring instruments, they need not be listed as r-mote shutdown monitoring instruments in Tables 3.3.5.2 : and 4.3.3.2 1.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 4 50 324 OPERATING LICENSES DPR 71 & DPR 62 RIQUEST FOR LICENSE AMENDMENT 10CFR50.92 EVALUATION The Cammission 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 e.a.uated, 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:
Prooosed Chance Delete Item 9, "Residual Heat Removal Service Water Discharge Differential Pressure" from Tables 3.3.5.2 1 and 4.3.5.2 1.
HAa.La The change does not involve a significant hazards consideration for tile following reasons-1.
The design, function, and operation of the plant systems will remain unchanged.
Item 9, "Residual Heat Removal Service Water Discharge Differential Pressure," and instruments Ell PDT N002BX and E11 PDI 3344 are bein5 deleted from Tables 3.3.5.2-1 and 4.3.5.2 1 because they are not required to ensure that the RRR and service water systems function as designed.
The RHR heat exchanger differential pressure is not an indicator of heat exchaager performance; therefore, it does nothing to ensure that sufficient capability is available ta permit shutdown and a
maintenance of hot shutdown from locations outside the control room.
Thus, these instruments should not be considered remote shutdown monitoring instruments and should be deleted from Tables 3.3.5.2-1 and 4.3.5.2-1.
Since they are not remote shutdown monitoring ins: ruments, their deletion from Tables 3.3.5.2 1 and 4.3.5.2-1 will not increasc the probability of an accident, nor will it change the consequences of an accident previously evaluated.
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2.
Instruments Ell-PDT-N002BX and Ell-PDI-3344 provide relative system pressure only and are not relied upon for remote shutdown.
Thus, these instruments need not be considered remote shutdown monitoring instruments and should be removed from Tables 3.3.5.2 1 and 4.3.5.2-1.
Their deletion will not create the possibility of a new or different kind of accident because they were not relied upon under accident conditions for remote shutdown purposes and they will continue to perform their design function in the same manner as before.
3.
The capability to permit shutdown and maintain hot shutdown of the facility from outside the control room is not compromised by deleting Instruments Ell PDT-N002BX and E11-PDI-3344 from Tables 3.3.5.2-1 and 4.3.5.2-1.
These lastruments currently do not perform a remote shutdown monitoring function; they only provide a relative system differential pressure which is not relied upon in the BSEP remote shutdown procedures to achieve remote shutdown.
Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.
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4 4
ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC ~t E, 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:
UNIT 1 Remove Pare Insert Page 3/4 3-48 3/4 3 48 3/4 3 49 3/4 3 49 UNIT 2 Remove Page Insert Pace 3/4 3 48 3/4 3-48 3/4 3 49 3/4 3 49 j
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ENCLOSURE 4 i
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 Egggg Descriotion of Channes 3/4 3-48 Delete Item 9. "Residual Heat Removal Service Water Discharge Differential Pressure" 3/4 3 49 Delete Item 9, "Residual Heat Removal Service Water Discharge Differential Pressure" UNIT 2 Eggga Descrintion of Channes 3/4 3 48 Delete Item 9, "Residual Heat Removal Service Water Discharge Differential Pressure" 3/4 3 49 Delete Item 9 "Residual Heat Removal Service Water Discharge Differential Pressure" i
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