ML20212F069

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Application for Amend to Licenses DPR-71 & DPR-62,revising Tech Specs Re Definition of Operable.Fee Paid
ML20212F069
Person / Time
Site: Brunswick  
Issue date: 03/02/1987
From: Cutter A
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20212F073 List:
References
NLS-87-006, NLS-87-6, NUDOCS 8703040609
Download: ML20212F069 (6)


Text

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Cp&L Carolina Power & Light Company M 2M SERIAL: NLS-87-006 86TSB18 10 CFR 50.90 United States Nuclear Regulatory Commission ATTN: 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 SPECIFICATIONS 3.0.3 AND 3.0.5 Gentlemen:

SUMMARY

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 (TS) for the Brunswick Steam Electric Plant, Units 1 and 2. The proposed revisions affect the definition of OPERABLE provided in Section 1.0 and Specifications 3.0.3,3.0.5, and 3.8.1.1. The revisions to these specifications are discussed in detail in the following section. Changes to the Bases Sections which reflect the proposed revisions and include a new discussion of the surveillance requirements for the batteries are included for your information.

DISCUSSION The current definition of OPERABLE in the Brunswick TS states:

A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electric power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function (s) are also capable of performing their related support function (s).

The proposed revision requires that " electrical power" be implicit, deleting the reference l

to normal and emergency power. The proposed revision to the definitlun of OPERABLE is consistent with the guidance provided in the GE BWR/4 Standard Technical Specifications and is administrative in nature.

Specification 3.0.3 provides actions to be taken when a Limiting Condition for Operation and/or the associated action requirements cannot be satisfied. Currently, under these l

circumstances, the unit must be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and achieve l

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3 Unit d St:t:s Nuctrar Regulatory Commission NLS-87-006 / Page 2 COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless corrective measures are completed. The proposed revision requires the unit to be placed in STARTUP within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As in the current Specification 3.0.3, the provisions of the proposed specification require the unit to achieve COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. However, the revised specification provides an increase in operational safety by allowing an orderly progression from POWER OPERATION to STARTUP to HOT SHUTDOWN to COLD SHUTDOWN, thereby possibly avoiding a manual reactor scram should any difficulties (such as a rod block) arise while shutting the unit down. This change is consistent with the guidance provided in the GE BWR/4 Standard Technical Specifications.

The final change addressed in this request involves the relocation of the requirements of Specification 3.0.5 into the action statements for Specification 3.8.1.1 (AC Sources).

Specification 3.0.5 was incorporated into the Brunswick TS to preserve the single failure 1

criterion for systems that are relied upon in the Safety Analysis Report. Two conditions are provided in Specification 3.0.5 which must be met in order to declare equipment operable should this equipment be inoperable solely due to a loss of its emergency or normal power source: (1) the corresponding normal or emergency power source must be operable, and (2) all redundant systems, subsystems, trains, components, and devices must be operable. If these conditions are not met, the unit must be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. In order to provide better control of system operability when a power source is lost, Specification 3.0.5 has been rewritten in ACTION format and incorporated as ACTIONS a.2 and b.2 of Specification 3.8.1.1. Merging the actions required in the event of an inoperable emergency power source into the ACTION statements dealing with this situation prevents the possible oversight of the Specification 3.0.5 requirements.

In addition, ACTIONS a.2 and b.2 include: (1) an allowance of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the operator to verify operability of the required systems, subsystems, trains, components, and devices which are powered from the remaining diesel generators, and (2) an extension of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to the shutdown schedule for achieving HOT SHUTDOWN. COLD SHUTDOWN will still be achieved within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> as is required by the current Specification 3.0.5. These schedules allow sufficient time to verify that the required equipment is operable and provide for a more orderly shutdown should it be required. This shutdown schedule is consistent with that proposed for Specification 3.0.3.

The ACTION statements for Specification 3.8.l.1 have been reformatted to provide easier identification of required actions. The proposed changes to Specification 3.8.1.1 and the deletion of Specification 3.0.5 are consistent with the guidance of the GE BWR/4 Standard Technical Specifications.

SIGNIFICANT HAZARDS ANALYSIS The Commission has provided standards in 10 CFR 50.92(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 evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power & Light Company has reviewed this request and determined that

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The proposed amendment doss not involve a significant increase' in the

. probability or consequences of an accident previously evaluated. Deleting -

the reference to normal and emergency power from the definition of

. OPERABLE has no affect on operation of the Brunswick Plant. Revised ACTION statements of Specification 3.8.1.1 ensure that upon loss of a power source, the alternate power supply is operable and that the redundant 7

. equipment is~ operable. As such, this change does not affect the redundancy

' of required safety systems and, therefore, does not increase the probability

or consequences of an accident previously evaluated.

The schedules for shutdown provided in the revised Specification 3.0.3 require the unit to achieve COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is consistent with the current requirements of Specification 3.0.3. However, operational safety is increased by allowing an orderly progression from POWER OPERATION to STARTUP to HOT SHUTDOWN to COLD SHUTDOWN. This reduces the possibility of having to scram the reactor in order to achieve HOT SHUTDOWN within the required time frame should some difficulty such as a rod block occur. This, in turn, reduces challenges to required safety systems and ultimately reduces the probability or consequences of an accident previously evaluated.

Incorporation of the requirements of Specification 3.0.5 into the ACTION statements for Specification 3.8.1.1 reduces the possibility that they will be overlooked should a diesel generator or an off-site power source become inoperable and, as such, reduces the possibility of operating outside the limits of the Technical Specifications. The revised schedule proposed in ACTIONS a.2 and b.2 ensure redundant equipment is operable and provides for a more orderly shutdown should it be required. These factors increase operational flexibility and reduce the chances of operating the unit in a degraded condition, thereby reducing the probability and consequences of previously evaluated accidents.

Other changes made in this amendment are administrative in nature and, therefore, cannot result in an increase in the probability or consequences of an accident previously evaluated.

2.

The proposed amendment does not create the possibility of a new or different kind of accident than previously evaluated because the changes do not af fect the method in which any equipment performs its intended safety function. The requirements of Specification 3.0.5 associated with inoperable normal or emergency power sources have been incorporated into Specification 3.8.1.1. Therefore, deleting the reference to normal and emergency power from the definition of OPERABLE power does not affect j

the redundancy of required safety systems. Expanding the shutdown schedules in Specifications 3.0.3 and 3.8.1.1, ACTIONS a.2 and b.2, provide increased operational safety by allowing a more controlled shutdown of the unit.

l Other changes made in this amendment are administrative in nature and, j

therefore, cannot create the possibility of a new or different kind of L

accident than previously evaluated.

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. United Stat:s Nuclear R:gul; tory Commission

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The proposed amendment does not involve a significant reduction in a margin of safety. The revisions result in: (1) increased operational safety and flexibility,(2) a reduction in the possibility of operating the plant in a degraded condition due to missed action requirements, and (3) a simplification of the specification through merging of action requirements and reformatting, thereby reducing the possibility of operator confusion. As such, this revision does not involve a significant reduction in a margin of safety.

Based on the above reasoning, the Company has determined that the proposed amendment does not involve a significant hazards consideration.

ADMINISTRATIVE INFORMATION The revised Brunswick-1 and Brunswick-2 TS pages are prm;Jed in Enclosures 1 and 2.

As a result of this amendment, the Bases Sections of the affected TS Sections have been revised. The revised Bases pages are also included for your information. The Company has evaluated this request in accordance with the provisions of 10 CFR 170.12 and determined that a license amendment application fee is required. A check for $150 is enclosed in payment of this fee.

Please refer any questions regarding this submittal to Mr. Sherwood R. Zimmerman at (919) 836-6242.

Your(very tr ly,

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A. B. Cutter - Vice besident MAT /bmc (5030 MAT)

Nuclear Engineering & Licensing Enclosures cc:

Mr. Dayne H. Brown Mr. W. H. Ruland (NRC-BNP)

Dr. J. Nelson Grace (NRC-Ril)

Mr. E. Sylvester (NRC)

A. B. Cutter, 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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ENCLOSURE I TO NLS-87-006 PROPOSED TECHNICAL SPECIFICATION PAGES BRUNSWICK-1 SPECIFICATIONS 3.0.3 AND 3.0.5 (86TSB18)

(5030 MAT /bec )

SUMMARY

LIST OF REVISIONS BRUNSWICK-1 PAGE NO.

DESCRIPTION OF CHANGE l-4 Removed the words " normal and emergency" from the definition of OPERABLE.

3/40-1 Revised Specification 3.0.3.

Deleted Specification 3.0.5.

Reformatted ACTIONS.

3/48-1 Added ACTION a.2 -Incorporates requirements of Specification 3.0.5.

Changed CONDITIONS to OPERATIONAL CONDITIONS 3/48-2 Added ACTION b.2 -Incorporates requirements of Specification 3.0.5.

3/4 8-2a New Page - Required due to reformatting and addition of ACTIONS a.2 and b.2.

B 3/4 0-1 Revised 3.0.1 to reflect previous TS change.

Revised 3.0.3 to reflect requested amendment.

B 3/4 0-ta Pages deleted due to deletion of 3.0.5.

- 3/4 0-lb B 3/4 8-1 Revised to reflect requested amendment.

B 3/4 8-2 New Page.

(5030 MAT /kts)