ML20196F515

Forwards RAI Re Extension of Balance of Plant & Emergency Electrical Bus Aot,Submitted as Part of Application for Converting to ITS for Plant,Units 1 & 2 Dtd 961101.Response Requested within 30 Days from Receipt of Ltr

ML20196F515
Person / Time
Site:	Brunswick
Issue date:	12/02/1998
From:	Trimble D NRC (Affiliation Not Assigned)
To:	Keenan J CAROLINA POWER & LIGHT CO.
References
TAC-MA3738, TAC-MA3739, NUDOCS 9812070056
Download: ML20196F515 (6)

Text

._ _ ..

, Deceter 2,19%

Mr. J. S. Kcenan, Vice Pr:sid:nt Carolina Power & Light Company Brunswick Steam Electric Plant Post Office Box 10429 Southport, North Carolina 28461 1

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING EXTENSION OF l BALANCE OF PLANT AND EMERGENCY ELECTRICAL BUS ALLOWED 1 OUTAGE TIME - BRUfJSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC NOS. MA3738 AND MA3739)

Dear Mr. Keenan:

Carolina Power & Light Company (CP&L), as part of its application for converting the Brunswick Steam Electric Plant Units 1 and 2 (BSEP 1 & 2) to improved Standard Technical Specifications (ITS), proposed, by letter dated November 1,1996, lengthening the allowed outage times (AOTs) for the balance of plant and emergency electrical buses from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 7 days. The NRC later determined that additional information was needed from CP&L regarding the impact of the AOT extension on plant risk. Thus, on September 14,1998, CP&L provided supplementalinformation in support of the AOT extension. ,

As a result of examining this latest submittal, the NRC staff has identified a need for further information, which has been discussed with Mr. Mark Turkal of your staff and is described in the enclosed request. A mutually agreeable response time of 30 days from your receipt of this letter was established. If circumstances result in the need to revise this target date or should you have any questions regarding this request, please call me at the earliest opportunity.

Sincerely, Original signed by:

David C. Trimble, Project Manager Project Directorate 11-3 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosure:

As stated cc w/ encl: See next page Distribution

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DEceter 2,1998

> Mr. J. S. Kc:ntn, Vice Presid;nt

, Carolina Power & Light Company Brunswick Steam Electric Plant Post Office Box 10429 Southport, North Carolina 28461 I l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING EXTENSION OF BALANCE OF PLANT AND EMERGEMCY ELECTRICAL BUS ALLOWED l OUTAGE TIME - BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC l NOS. MA3738 AND MA3739)

Dear Mr. Keenan:

Carolina Power & Light Company (CP&L), as part of its application for converting the I Brunswick Steam Electric Plant Units 1 and 2 (BSEP 1 & 2) to improved Standard Technical Specifications (ITS), proposed, by letter dated November 1,1996, lengthening the allowed l

outage times (AOTs) for the balance of plant and emergency electrical buses from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 7 days. The NRC later determined that additional information was needed from CP&L regarding the impact of the AOT extension on plant risk. Thus, on September 14,1998, CP&L provided supplementalinformation in support of the AOT extension.

As a result of examining this latest submittal, the NRC staff has identified a need for further information, which has been discussed with Mr. Mark Turkal of your staff and is described in the enclosed request. A mutually agreeable response time of 30 days from your receipt of this letter was established. If circumstances result in the need to revise this target date or should you have any questions regarding this request, please call me at the earliest opportunity.

Sincerely, Original signed by:

David C. Trimble, Project Manager Project Directorate ll-3 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosure:

As stated cc w/ encl: See next page Distribution Docket File PD 11-1 RF A.El-Bassioni ACRS D.O'Neal J. Zwolinski PUBLIC L. Plisco, Rll OGC B.Bonser, Rll FILENAME - G:\BRUNSWIC\ BRA 3738.RAI OFFICE PM:PDll-1 LA:PDll-1 SPSB [ PD:PDil-3 NAME DTrimble Dunnington Memo FHe on 197 ,cys Date DATE 12/498 /.2///98 11 4/98 ..-

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l cnn,rq g i UNITED STATES g j NUCLEAR REGULATORY COMMISSION o $ WASHINGTON, D.C. 200664 201 l

Dececher 2,1998 Y..D%.o#

Mr. J. S. .Keenan, Vice President Carolina Power & Light Company ,

Brunswick Steam Electric Plant Post Office Box 10429 i Southport, North Carolina 28461

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING EXTENSION OF  !

BALANCE OF PLANT AND EMERGENCY ELECTRICAL BUS ALLOWED l OUTAGE TIME - BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC NOS. MA3738 AND MA3739)

Dear Mr. Keenan:

Carolina Power & Light Company (CP&L), as part of its application for converting the Brunswick Steam Electric Plant Units 1 and 2 (BSEP 1 & 2) to improved Standard Technical Specifications (ITS), proposed, by letter dated November 1,1996, lengthening the allowed outage times (AOTs) for the balance of plant and emergency electrical buses from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 7 days. The NRC later determined that additional information was needed from CP&L regarding  ;

the impact of the AOT extension on plant risk. Thus, on September 14,1998, CP&L provided  ;

supplementalinformation in support of the AOT extension. i l

As a result of examining this latest submittal, the NRC staff has identified a need for further information, which has been discussed with Mr. Mark Turkal of your staff and is described in the enclosed raquest. A mutually agreeable response time of 30 days from your receipt of this  ;

letter was established. If circumstances result in the need to revise this target date or should i you have any questions regarding this request, please call me at the earliest opportunity.

Sincerely, b 0.ad( hk David C. Trimble, Project Manager Project Directorate 11-3 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosure:

As stated cc w/ encl: See next page

. \

Mr. J. S. Keenan l Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 cc: 1 i

Mr. William D. Johnson Ms. Karen E. Long

! Vice President and Senior Counsel -

Assistant Attomey General Carolina Power & Light Company State of North Carolina Post Office Box 1551 Post Office Box 629 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 l Mr. Jerry W. Jones, Chairman Mr. Robert P. Gruber Brunswick County Board of Commissioners Executive Director Post Office Box 249 Public Staff- NCUC Bolivia, North Carolina 28422 Post Office Box 29520 Raleigh, North Carolina 27626-0520 l Resident inspector l U.S. Nuclear Regulatory Commission l 8470 River Road Director l Southport, North Carolina 28461 Site Operations l

Brunswick Steam Electric Plant Regional Administrator, Region ll Post Office Box 10429 U.S. Nuclear Regulatory Commission Southport, North Carolina 28461

, Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 l Atlanta, Georgia 30303 Mr. William H. Crowe, Mayor City of Southport Mr. Mel Fry, Director 201 East Moore Street Division of Radiation Protection Southport, North Carolina 28461 N.C. Department of Environment l and Natural Resources Mr. Dan E. Summers i l 3825 Barrett Dr. Emergency Management Coordinator i Raleigh, North Carolina 27609-7721 New Hanover County Department of  ;

Emergency Management Mr. J. J. Lyash Post Office Box 1525 Plant Manager Wilmington, North Carolina 28402 Carolina Power & Light Company Brunswick Steam Electric Plant Ms. D. B. Alexander Post Office Box 10429 Manager Southport, North Carolina 28461 Performance Evaluation and l Regulatory Affairs CPB 9 l Public Service Commission Carolina Power & Light Company l State of South Carolina Post Office Box 1551 Post Office Drawer 11649 Raleigh, North Carolina 27602-1551 Columbia, South Carolina 29211 i

Mr. K. R. Jury Chief, Reactor Projects Branch 4 Manager- Regulatory Affairs U. S. Nuclear Regulatory Commission Carolina Power & Light Company Atlanta Federal Center Post Office Box 10429 61 Forsyth Street, SW, Suite 23T85 Southport, NC 28461-0429

Atlanta, Georgia 30303 l

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REQUEST FOR ADDITIONAL INFORMATION QUESTIONS l

1) Discuss the need for the Technical Specification amendment. What type of work is planned? How often is this work required? Is work planned for a balance of plant (BOP) bus,4kv bus, and subsystem buses simultaneously or sequentially? How long would the work take to complete?

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2) The submittal indicates that the safety function determination program (SFDP) would be l relied upon for Tier 2 and Tier 3 considerations. Please explain, including example (s),

l how the SFDP would be applied during the proposed work, and discuss any training provided on the SFDP.

3) For each BOP /4kv bus circuit and dedicated emergency diesel generator (EDG) planned to be out of service (OOS) simultaneously, please provide the following for a 7-day limiting condition for operation (LCO): 1) conditional Core Damage Frequency (CDF); 2)

Incremental Conditional Core Damage Probability (ICCDP); 3) unavailabilities of buses and EDG assumed in the probabilistic risk assessment (PRA) model corresponding to the baseline CDF; 4) impact of the proposed 7-day LCO on the unavailabilities given in part 3 of this question (state assumptions); 5) CDF corresponding to the unavailabilities given in part 4 of this question; 6) unavailability goals of buses and EDG for the Maintenance Rule; 7) CDF corresponding to these unavailability goals for the Maintenance Rule; 8) Risk Reduction Worth; and 9) Fussel-Ve ssely Worth.

4) a) The submittal states that the impact from external events on tne proposed Allowed Outage Time (AOT) extensions is not significant. Discuss and justify this conclusion, quantitatively or qualitatively (include discussion on fires and high winds).

b) In addition, the submittal states 'the proposed AOT extensions do not impose any additional challenges to containment performance and, therefore, the incremental conditional large early release probability (ICLERP) is not significant." Discuss and justify this conclusion. Provide the baseline Large Early Release Frequency (LERF).

5) Discuss the relative contribution bv ccident type Ior accident initiator) which contributes to the baseline CDF, as well as to the conditional CDF given a BOP /4kv circuit and dedicated EDG OOS for maintenance. Please provide the CDF sequences which dominate the CDF increase given a BOP /4kv circuit and dedicated EDG OOS. Also, provide the top 30 CDF cut sets, with basic event probabilities, which contribute to the CDF increase.

6) Discuss measures to ensure quality of PRA model updates and calculations. Also, how often is the PRA model planned to be updated?

l 7) The Brunswick Updated Final Safety Analysis Report indicates that the residual heat removal (RHR) capacity per RHR pump is 33%%. The Brunswick Individual Plant Examination PRA model uses a 1 of 4 LPCI pump success criteria for Loss-of-Coolant Accident (LOCA) initiators. What is the basis for this success criteria?

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! 8) How long would it take to restore equipment impacted by the proposed work if it is I needed? )

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9) For the shutdown unit, expand on how procedures maintain adequate shutdown cooling, l LOCA, and Loss of Offsite Power mitigation capability during proposed work on the BOP /4ky bus circuit. '

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