ML20198G335

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Forwards RAI Re TS Change Request to Allow 3 DG Surveillance Tests to Be Performed During Plant Operational Conditions 1 & 2.Response Requested within 30 Days of Receipt of This Ltr
ML20198G335
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 12/29/1997
From: Trimble D
NRC (Affiliation Not Assigned)
To: Hinnant C
CAROLINA POWER & LIGHT CO.
References
TAC-MA0093, TAC-MA0094, TAC-MA93, TAC-MA94, NUDOCS 9801130002
Download: ML20198G335 (4)


Text

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Mr. C. S. Hinnant. Vice Pres 1 cent Carolina Power & Light Company Brunswick Steam Electric Plant

. Post Office Box 10429 Southport. North Carolina 28461

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATICN CHANGE REQUEST TO ALLOW THREE DIESEL GENERATOR SURVEILLANCE TESTS TO BE PERFORMED DURING PLANT OPERATIONAL CONDITIONS 1 AND ? - BRUNSWICK STEAM ELECTRIC PLANT.-UNITS NO 1 AND 2 (TAC NOS. MA0093 AND MA0094)

Dear Mr. Hinnant:

By letter dated November 6. 1997. you submitted a Technical Specifications change request to allow three 18 month diesel generator (PG) surveillance re uirements (SRs) to be >erformed durin both lant operation (Operational Cor ditions 1 and 2) and slutdown (Operat onal C nditions 3.4, and 5) rather than, as currently required, only during shutdown.

The first SR is a DG inspection involving a partial disassembly. The second ensures that non-critical DG protective functions are bypassed on a Emergency Core Cooling system actuation signal. The third verifies that the DG operates for at least 60 minutes under post accident loading.

To complete our review, we need additional information as described in the enclosure to this letter.

To support the NRC staff's review schedule, your written response to this request for additional information is expected within 30 days of the receipt of this letter.

Should you have any questions, do not hesitate to contact me at (301) 415-2019.

Sincerely.

(Original Signed By)

David C. Trimble. Project Manager Project Directorate 11-1 Division of Reactor Frojects - 1/11 Of fice of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324 ebsue:

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Mr. C. S. Hinnant Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 cc:

Mr; William D. Johnson Ms. Karen E. Long Vice President and Senior Counsel Assistant Attorney 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 Mr. Jerry W. Jones. Chairman Mr. Robert P. Gruber Brunswick County Board of Comissioners Executive Director Post Office Box 249 Public Staff NCUC Bolivia, North Carolina 28422 Post Office Box 29520 Raleigh, North Carolina 27626-0520-Resident Inspector U.S. Nuclear Regulatory Comission

-8470 River Road Director-Southport. North Carolina 28461 Site Operations Brunswick Steam Electric Plant Regional Administrator. Region 11 Post Office Box 10429 U.S. Nuclear Regulatory Comission Southport. North Carolina 28461 Atlanta Federal Center 61 Forsyth Street. SW. Suite 23T85 Atlanta, Georgia 30303 Mr. William H. Crowe, Mayor City of Southport Mr. Mel Fry, Acting Director 201 East Moore Street Division of Radiation Protection Southport. North Carolina 28461-N.C. Department of Environment.

Health and Natural Resource:

Mr. Dan E. Summers 3825 Barrett Dr.

Emergency Management Coordinator Raleigh, North Carolina 27609-7721 New Hanover County D?partment of Emergency Management Mr. J. J. Lyash Post Office Box 1525 Plantilanager 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 Regulatory Affairs Public Service Comission Carolina Power & Light Company State of South Carolina 412 S. Wilmington Street Post Office Drawer 11649 Raleigh, North Carolina 27601 Columbia. South Carolina 29211 Mr. K. R. Jury Mr. Milton Shymlock-Manager - Regulator Affairs U. S. Nuclear Regulatory Comission Carolina Power & Li ht Company Atlanta Federal Center Post Office Box 104 9 61 Forsyth Street, SW. Suite 23T85 Southport, NC 28461 0429

-Atlanta, Georgia 30303

E, rut SWICK STEAM ELECTRIC PLANT DIESEL GENERATORT ES11NG AT POWER VERSUS SHUTDOWN OUESTIONS 1.

For testing performed at power and at shutdown:

a) What is the expected duration of Emergency Diesel Generator (EDG) unavailability to perform each part of the test?

b) What is the limiting time to recover the EDG if it is needed?

2, a) For the 7 day EDG limiting condition for operation (LCO), evaluate, to the extent possible, for each EDG:

impact en Core Damage Frequency (CDF), incremental Conditional Core Damage Probability (ICCDP), and incremental Conditional large Early Release Probability (ICLERP).

Provide this information for the expected duration of the on line EDG maintenance also, if the Individual Plant Examination (IPE) CDF has changed from the August 1992 IPE submittal, indicate the new baseline CDF.

b) For each EDG evaluated in part: what is the change in CDF of dominant contributors such as loss of offsite power (LOOP) initiators -station blackout (SBO), and transient with loss of decey heat removal?

If dominant contributors to CDF have changed since the August 1992 IPE submittal, discuss the change in CDF to these contributors, c) Discuss risk insights gained from this evaluation, d) Provide modeling assumptions which are impartant for understanding the risk insights gained.

For example, indicate if maintenance unavailabilities are set to zero for other components while in the EDG LCO, if the EDG out of service is considered to be non-recoverable with a proNbility of 1, etc.

Also, discuss any pertinent changes in the August 1992 IPE submittal.

3.

Indicate EDG success criteria used in IPE for: single and dual unit LOOP.

4.-

How will performance of the EDG work affect maintenance uravailability?

Describe, for the maintenance rule, the EDG unavailability goal, and how it compares to the values assumed in the IPE, Please indicate the

-correspondence between the maintenanc.e rule goal unavailability and the change in CDF, as discussed in a conference call with your staff on December 17, 1997.

5.

Please provide a copy of the procedure which is used for:

a) establishing measures to ensure that no risk-significant plant equipment outage configurations would occur while the plant is subject to the EDG LCO, J

1 b) evaluating if this EDG work should be performed (eg., approach of a hurricane), or evaluating EDG work-(which may be in progress) if an unexpected contingency should arise (eg., component / system-operability question).

Discuss any other measuret, or controls used for assessing the risk of on line EDG work. Also discuss measures and controls for assessing the:

risk of EDG work at shutdown.

6.

Discuss qualitatively, and where >ossible, quantitatively. risk insights of performing this EDG work for tie following cases:

1) both units at power, 2) one unit at power and one unit shutdown, and 3.' both units i

shutdown. The discussion should not be limited to only the unit which i

is performing the EDG work, but should also address the opposite unit.

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