ML20217E832
| ML20217E832 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/01/1997 |
| From: | Trimble D NRC (Affiliation Not Assigned) |
| To: | Hinnant C CAROLINA POWER & LIGHT CO. |
| References | |
| TAC-M97243, NUDOCS 9710070241 | |
| Download: ML20217E832 (35) | |
Text
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e . 't October 1. 1997 Mr!C.5.Hinnant.VicePresident Carolina Power & Light Company Brunswick Steam Electric Plant i Post Office Box 10429 Southport. North Carolina 28461
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATION CHANGE REQUEST TO CONVERT TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR THE BRUNSWICK STEAM ELECTRIC PLANT.
UNITS NO. 1 AND 2 (TAC NOS. M97243 AND M97244)
Dear Mr. Hinnant:
By letter dated November 1. 1996. you submitted a request to convert the current Technical Specifications (TS) for the Brunswick Steam Flectric Plant.
Units 1 and 2. to be consistent with the Improved Standard Technical Specifications (ISTS) in NUREG-1433. " Standard Technical Specifications -
General Electric Plants. BWR/4." Revision 1. dated April 1995. To complete our review we need additional information requested in the enclosed table.
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.
} (Originni Signed Ily)
David C. Trimble. Pro ect Manager Project Directorate 1 -1 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
As stated cc w/ enclosure:
See next page /s l Distribution
' Docket File ~ W. Beckner PUBLIC OGC g ;O/
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&gPD11-1RF B. Boger J. Johnson RIl oo M. Weston D. Clark EPn E. Tomlinson FILENAME - G:\BRUNSWIC\BR97243.RA3 h 0FFICE PM:PDil-1 LA:PDIl-1 PD: PDM 1 h NAME DTrimblell7 Dunningt@ JLy$
g DATE dil/97 9/h/97 10/I/97
"" COPY (Vit/No (fes/No Yes/No V 0FFICIAL RECORD COPY ll !Illli .lil,I)ll, Il G M C E ER88PY
a .. "r 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. Jerr.y 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 Resident Inspector U.S. Nuclear Regulatory Commission Mr. W. Levis <
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 Commission 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 Resources Mr. Dan E. Summers 3825 Barrett Dr. Emergency Management Coordinator <
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- I Post Office Box 10429 Manager Southport, North Carolina 28461 Performance Evaluation and <
Regulatory Affairs Public Service Commission Carolina Power & Light Company State of South Carolina 412 S. Wilmington Street Post Office Drawer 11649 Releigh, North Carolina 27601
- Columbia, South Carolina 29211 Mr. K. R. Jury .
Mr. Milton Shymlock 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
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SIMtSWICK INIIT I & 2 -
CTS MARKUP 3.8.1 ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE- DATE DATE C0!TTENTS or REF OPENED CLGSE JFD # D 3.8.1-1 L.2 LCO 3.0.5 The CTS is scre restrictive 4-28-97 DOC should be Pg. 3/40-1 than the proposed ITS, and revised to address the difference is not the staff concern.
accurately identified or adequately justified.
3.8.1-2 L.3 Action a.3 The DOC '.ppears to indicate 4-28-97 Revise the DOC such Pg. 3/48-1 that the licensee considers that the 6 day the NUREG 6 day limitation limitation is only to be appilcable to applicable to overlapping inoperabilities overlappir.g of offsite circuits or DGs, inoperabilities of not o.fsite circuits AMD offsite circuits and DGs. DGs. Also, revise Condition 8.
The second part of this DOC (which references Sect. The second part of 1.3) appears to be the DOC should be incorrect. Extended deleted.
completion times such as those proposed for Condition B&C are not covered by the provisions of Section 1.3. i I
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BRINISWICK INIIT 1 & 2 CTS MARKUP 3.8.1 ,
ISSUE # DOC f CTS /STS DESCRIPTION OF ISSUE' DATE DATE- C0fMENTS or REF OPENED CLOSE JFD # D 3.8.1-3 L.4 Action b.2 The proposed change is 4-28-97 Revise the DOC to Pg. 3/4 8-2 acceptable. However, the address the staff's DOC could be improved. For concerns.
example, the DOC appears to be written with only 2 DGs as opposed to the 4 DGs at Brunswick. A better case can be made for not testing the remaining DGs if the absence of a common mode failure can be established, and a better case can be made for the proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time.
3.8.1-4 L.3 Action b.3 See discussion on DOC L.3 4-28-97 Revise the DOC Pg. 3/48-2 in comument 3.8.I-2. The similar to the DOC NUREG limitation on revision for comment overlapping inoperabilities 3.8.1-2.
applies to offsite circuits and DGS.
2
nesmewICK UNIT I & 2 -
CTS MARKUP 3.8.1 ISSUE i DOC f CTS /STS DESCRIPTION OF ISSUE DATE DATE CON U TS or REF OPENED CLOSE JFD # D 3.8.1-6 A.2 Action d.1 Two or more offsite .
4-28-97 Revise the DOC to circuits inoperable is not more adequately an allowance in the CTS, address why allowing and DOC A.2 does not make "two or more*
an adequate case for offsite circuits to including it in the ITS. be inoperable at the same time. (This could mean all 4 circuits inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.).
3.8.1-7 L.3 Action d.3 See discussion on DOC L.3 4-29-97 Revise DOC and the in comment 3.8.1-2. submittal for Condition 8.
3.8.1-8 L.4 Action e.1 See discussion on DOC L.4 4-29-97 Revise DOC L.4.
in coussent 3.8.1-3, above.
3.8.1-9 L.3 Action e.3 See discussion on L.3 in Revise DOC and consnent 3.8.1-2. submittal.
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BRUNSWICK UNIT 1 F 2 CTS MARKUP 3.8.1 ,
1 ISSUE f DOC i CTS /STS DESCRIPTION OF ISSUE DATE DATE ComENTS or. REF OPENED CLOSE JFD #
D 3.'o.2-10 A.7 SR 4.8.1.1.1 The proposed Note does not 4-30-97 Revise the submittal appear to be acceptable. to ensure all The Note states that the SR required offsite is only applicable to Unit circuits are treated 1 offsite circuits, but the same.
some Actions require verifying the OPERA 8ILITY of offsite circuits by performing the SR. In those cases, the Unit 2 offsite circuits are excluded even though the LCO requires them.
3.8.1-11 LO.1 SR The change from 18 months 4-30-97 4.8.1.1.1.b to 24 months for the SR frequency is beyond the scope of the ITS conversion.
3.8.1-12 L.6 SR The DOC references 4-30-97 Provide specific 4.8.1.1.2.a " studies" that have been reference to the conducted regarding
- studies" and staggered testing. include them in a Hecaver, none of the revised DOC.
studies is identified.
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BRUNSWICK UEIT 1 & 2 -
CTS MARKUP 1
3.8.1 ISSUE # DOC i CTS /STS DESCRIPTION OF ISSUE DATE DATE C0f98ENTS or REF OPEMED CLOSE JFD # D 3.8.1-13 A.8 SR The Note proposed to be 4-30-97 4.8.1.1.2.a.4 added to these SRs in the SR ITS could be more clear.
4.8.1.1.2.a.5 SR 4.8.1.1.2.d.2 Note * '
SR 4.8.1.1.d.3 SR 4.8.1.1.2.d.5 i
4 3.8.1-14 7 SR The discussions associated 4-30-97 . Provide a 4.8.1.1.2.a.4 with changes to this SR do justification for not address deleting the 10 - deleting the 10 second start reqetrement. second start requirement.
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BRUNSWICK UNIT 1 & 2 -
CTS MARKUP 3.8.1 ISSUE # DOC f. CTS /STS DESC8.'IPTION OF ISSUE DATE DATE C0fetENTS or REF OPENED CLOSE JFD #
- D 3.8.1-15 L.ll SR The proposed frequency 4-30-97 Revise the submittal 4.8.1.1.2.a.3 change does not appear to. to require pump be acceptable. Verifying testing every 31 that the fuel oli transfer days, or provide a pump operates automatically justification for is determined by how often why this is not the pump must operate to required that does replace fuel oil used not reference ASME during DG testing (usually Section H.
every 31 days). It is not a function of ASME Section M requirements.
3.8.1-16 LD.1 SR The change in frequency 5-1-97 4.8.1.1.2.d from 18 months to 24 months is beyond the scope of ITS conversion.
3.8.1-17 LA.I SR Relocating this SR is 5-1-97 Provide a location 4.8.1.1.2.d.1 acceptable in concept, but ,
for this SR which there should be some are adequate controls associated with controls.
it. Plant procedures do not provide adequate controls.
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BRUNSWICK UNIT I & 2 '
CTS IWIKUP 3.8.1 ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE- DATE DATE C0fMENTS or REF OPENED CLOSE JFD # D 3.8.1-18 M.6 CTS Note
- The DOC incorrectly 5-I-97 Indicates that an engine Correct the D0C.
prelube period is mandatory. A prelvbe period is allowed, but not required.
3.8.1-19 LA.2 CTS Note
- The DOC indicates that a 5-I-97 part of this Note will be If the CTS relocated material requires relocated to procedures and controls, relocate controlled under 10 CFR it to a different 50.59 Procedures are not place such as the subject to control under 10 CFR 50.59.
Bases. If controls are not required, revise the DOC to address why controls are not r.ccded.
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BRUNSNICK UNIT 1 & 2 CTS fWUlKUP 3.8.2 ,
ISSUE # DOC i CTS /STS DESCRIPTION OF ISSUE DATE DATE CoretENTS or REF OPENED CLOSED JFD #
3.8.2-1 A.2 iC0 The staff does not 5-12-97 Provide a discussion to M.I 3.8.2.b understand why these two ru nor.d to the staff LCO parts of the same LCO questions. Revise the 3.8.2.C have different wording. DOCS as necessary. The Does the proposed wording LCD should be clear as mean that LCO 3.8.8 does to whether or not the not address the Unit 2 ventilation requirements systems / components of Section 3.77 Does required by Unit I must this wording mean that have DG backurr.
the Sectlan 3.7 ventilation systems do not require DG hackup?
i Alsc, the warding of LCO
' 3.8.2.b is confusing. Is the requirement for 2 DGs, each capable of powering the same bus, or 2 DGs, each capable of powering a different bus?
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1 BRUNSWICK UNIT 1 & 2
, CTS MAltKUP 3.8.2
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1 i ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENED CLOSED l JFD #
3.8.2-2 A.5 Action A lTheproposedNoteisnot 5-12-97 Delete the Nots Re: ,
Note necessary, and possibly ) 3.0.3 applicability.
confusing. In Modes I, 2, or 3, if the AC or DC t sources are inadequate to support fuel handling, the AC or DC sources operating LCOs will require a plant shutdown, and 3.0.3 is not a i concern.
3.8.2-3 L.2 SR If Unit I is in Mode 4 or 5-12-97 Provide a respo- to A.6 3.8.2.1 5 era either of the Unit the staff on- ...
Note 2 DGs required to support and, as app.ecabit w Unit 17 If not, why not? the licensee proposed If either Unit 2 DG is to address the issue of required, the proposed Unit 2 OPERABILITY Note to this Unit 1 LCO requirements.
would not require several SRs to be performed on (Reverse the question Unit 2 DGs. This for Unit 2 in Mcies 4 violates the Unit 2 or 5 and Unit 1 in OPERABILITY requiremerits Modes 1-3.)
i of LCO 3.0.1.
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i BIMISWICK WITS 1 & 2 -
CTS MARKUP j 3.8.3 ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE DATE r a fE CormENTS or REF OPENEb CLOSED JFD #
There are no cosaments on this section.
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BRUNSWICK istITS 1 Afe 2 -
CTS NutKUP 3.8.4 ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE ComENTS or REF OPENED CLOSED JFD #
1 N/A Sr Part b. of CTS SR 4.8.2.3.a 8-12-97 The licensee 4.8.2.3.1.b includes a requirement to should provide verify the alignment of power a justification conversion modules to the for the Division II bus b (Unit I and apparent Unit 2). The CTS markup deletion, or indicates this requirement is retain the CTS.
moved to LCO 3.8.7. However, a review of the proposed ITS did not show this ites as part of LCO 3.8.7, the LCO Actions, or the LCO SRs.
This apparent deletion of a CTS requirement is not justified.
2 N/A LCO The CTS markup shows LCO 8-12-97 The ifcensee 3.8.2.3.2.b.2 3.8.2.3.a.1 (a 250/125 volt should provide bus) as being moved to ITS a justification LCO 3.8.7. However, a review for the of the proposed ITS did not apparent show this item as part of LCO deletion, or 3.8.7, the LCO Actions, or retain the CTS.
the SRs. This apparent deletion of a CTS requirement is not justified.
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BRUNSWICK IMITS 1 AND 2 -
CTS MMtKUP 3.8.4 ISSUE f DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE COPMENTS or REF OPENED CLOSED JFD #
3 M.S SR . The CTS markup and DOCS M.S 8-12-97 The licensee LA.2 4.8.2.3.2.b.2 and LA.2 show the value of should revise connection resistance as the submittal moved to the Bases. This is to retain Not Acceptable. These valves resistance should be retained as part of valves as part the SR, consistent with CTS of the SR.
and NUREG-1433.
4 LD.I SR The proposed change in 8-12-97 This is a 4.8.2.3.2.c.3 frequency for performance of beyond scope SR SR 4.8.2.3.2.C.3 from every issue.
4.8.2.3.2.d 18 months to every 24 months is beyond the scope of a conversion to the ITS. This is also true of the proposed change in frequency from 18 months to 24 months for SR 4.8.2.3.2.d.
2 t_________.
BRUNSWICK UNITS I Me 2 -
CTS RMIKUP 3.8.4 ISSUE i DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE CON *ENTS or REF OPENED CLOSED JFD #
5 L.2 SRs The Notes added to SR 8-12-97 The licensee 4.8.2.3.2.d.I 4.8.2.3.2.d.1 ar.d SR should revise 4.8.2.3.2.e 4.8.2.3.2.e are not the submittal necessary. A generic change to delete the has been approved for SR proposed Notes, 3.0.2 which covers unplanned and adcpt the events that satisfy the NUREG generic criteria of the SR. The change.
licensee should adopt the generic resolution of this issue in lieu of adding notes to individual surveillances.
3
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BittNISNICK UNITS I & 2 -
CTS R4flKUP 3.8.6 .
ISSUE DOC # CTS /STS DESCRIPTION OF ISSUE DALE DATE COPetENTS
- or REF OPENED CLOSED JFD #
L.1 SR DOC L.I could be improved. 8-12-97 The license should 4.8.2.3.2.b.3 The justification for revise DOC L.1 to decreasing the number of provide more cells that are checked for support for the temperature from all change.
connected cells (approximately 58-60 per 125 vdc battery) to representative cells (10%
of connected cells, or 6 cells) should also address such things as "all cells are in the same location with a common ventilation system *, and "other tests on all connected cells will call attention to cells that may be heating up i, because of some problem."
In its present form, DCC L.1 does not make a strong case for this less restrictive chance.
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m a N ICK IMITS 1 & 2 -
CTS IWIKUP !
3.8.6 i
ISSUE DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE COPMENTS
- or REF OPENED CEOSED :
JFD # '
2 M.1 Footnote Footnote C to CTS Table 8-12-97 The licensee should 4.8 2.3.2-1 requires that revise DOC M.I to float voltage readings be address staff corrected for electrolyte concerns, or retain temperature. This CTS CTS.
requirement is rot included in the ITS. The rationale is that the CTS footnote is
- . permissive, not a requirement, and that deleting the footnote is a more restrictive action.
The staff does not agree with this position. It is the staff's view that the footnote constitutes a requirement and that deleting it is a less restrictive change that has not been justified.
2
BRUNSNICK UNITS 1 & 2 CTS MARKUP 3.8.7 ,
ISSUE DOC i CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS i or REF OPENED CLOSED JFD #
1 LA.1 LCO LCO 3.8.2.1 (CTS) includes the 8-12-97 The licensee 3.8.2.1 requirement that tie breakers should reefse the between redundant busses must be submittal to open in order to establish address staff OPERABILITY. The licensee concerns.
proposed to move this requirement to the Bases as discussed in DOC LA.I. In the staff's view, this DOC does not make a very strong argument in support of this change. In light of this, the staff is of the opinion that the CTS requirement should be retained, a possibly as part of proposed ITS SR 3.8.7.1. The licensee should revise the submittal, or provide a better justification for why the proposed change is acceptable.
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BRUNSWICK UNITS 1 & 2 --
CTS MARKUP 3.8.7 .
ISSUE DOC f CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS i f or REF OPENED CLOSED j JFD # l 2 N/A LCO The CTS markup for LCO 3.8.2.3 8-13-97 The licensee 3.8.2.1 does not appear to be should revise the acceptable. Proposed ITS Action submittal to C is the primary concern. The address staff CTS allow "one or more" j/ concerns.
batteries / chargers "in one Division" to be inoperable for up to 7 days. This allowance, however, is only applicable if all redundant systems / components are OPERABLE. Proposed Condition C would allow multiple "DC electrical power distributies subsystems" to be inoperable in either Division, subject only to the constraint of Condition E. This is a less restrictive thange that has not been identified and has not been justified. The submittal should be revised to address this concern.
2
BRUNSWICK UNITS 1 & 2 -
CTS MARKUP 3.8.7 .
I ISSUE DOC # CTS /STS DESCRIPTIDN OF ISSUE DATE DATE COMMENTS
- or REF OPENED CLOSED JFD #
3 LA.1 SR The CTS SR 4.8.2.3.1 requirement 8-13-97 The licensee 4.8.2.3.1 to ensure the tie breakers are should revise the open is moved to the Bases in submittal to the ITS. The justification for address staff this change is provided in DOC concerns.
LA.I. As stated in issue No.1 above, the staff does not feel that DOC LA.1 presents a strong argument in support of this proposed chan:n, and that the requirement should be retained.
The licensee should revise the submittal, or provide a better justification for why the proposed change is acceptable.
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BRUNSWICK UNITS 1 & 2 l CTS MARKUP 3.8.7 ,
ISSUE DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE CopMENTS
- or REF OPENED CLOSED JFD #
4 LA.2 SR CTS SR 4.8.2.3.1.b, which 8-13-97 The licensee 4.8.2.3.1.b requires verifying that no more should revise the than 2 power conversion modules submittal to are aligned to the Division.II address staff Bus B,"is proposed to be moved concerns.
to tiie Bases. The justification for this change (DOC LA.2) does not provide a strong argument in support of this change. The staff is of the opinion that this requirement should be retained in TS. The licensee should' revise the schnittal to address staff concerns, or provide a better justification for why the proposed change is acceptable.
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BRUNSWICK UNITS 1 & 2 CTS NARKUP 3.8.7 -
i 1
ISSUE DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS
- or REF OPENED CLOSED JFD #
5 LA.] LCO Proposed changes to Actions of L.1 3.8.2.4.1 CTS 3.8.2.4.1 as justified by DOCS LA.1 and L.1 are acceptable in concept. However, the staff has some concern regarding the i use of the term "ismediately initiate action to" as found in ITS Condition B. The staff understands why this terminology was selected, but is still concerned about the lack of a definitive time constraint where it is used. The proposed Condition (B) could be interpreted as being met for an indefinite period of time provided some form of action to transfer to the alternate power source was initiated immediately. This, in turn, could leave affected safety equipment inoperable for the same time period. The staff suggests that the Required Actions be revised as follows:
B.l.1 Initiate action to 5
h BRUNSWICK UNITS 1 & 2 CTS MARKUP 3.8.7 .
DOC # DESCRIPTION OF ISSUE DATE DATE COMMENTS ISSUE CTS /STS or REF OPENED CLOSED JFD #
' transfer DC electrical power '
subsystem to its alternate source AND B.I.2 Declare required features supported by the inoperable DC electrical ;
power distribution subsystem inoperable. The Completion Time for B.I.1 would be immediately, and the Completion Time for B.I.2 would be immediately and continuing until the power transfer is complete. With this wording, the A0Ts associated with the inoperable equipment would drive the completion of the power transfer while the wording of B.1.1 would still ,
preclude entering a default :
statement. The licensee should consider the staff suggestion and revise the submittal as considered appropriate.
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BRUNSWICK
.IRIREG MARKUP 3.8.1 ,
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ITEM i JFD # CTS /STS DESCRIPTION OF; ISSUE: ColffENTS STATUS.
LCO' 1 4 LCO 3.8.1 In proposed ITS Condition D, the The licensee should Condition D licensee proposed to add the term "or provide a better more".immediately following "Two" and justification for ahead of."offsite circuits the proposed inoperable." This does not appear to change.
be acceptable because it means that all offsite circuits could be inoperable at the same time and no other actions beyond that for two offsite circuits inoperable is required. JFD 4 does not specifically address this issue and is, therefore, not adequate to support this proposed change. The licensee should withdraw this proposed change, or provide an adequate justification.
The above discussion is also applicable to proposed Condition F with the exception that the issue addressed "two or more" DGs inoperable. (Note: This is probably acceptable because the time' allowed is only 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s- w/o this change, 3 DG inoperable would mean 3.0.3 which invokes shutdown in one hour as opposed to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in the proposed ITS Condition.)
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BRINISWICK IRIREG MARKUP 3.8.1 .
ITEN #- JFD'i: CTS /STS: DESCRIPTION OF ISSUEL COMIENTS- STATUS LCO '
2 8 SR The proposed deletion of Note I in The licensee should 3.8.1.2' NUREG-1433 SR 3.8.1.2 is acceptable reconsider deleting because this note is a pemissive, NUREG Note 1.
not a requirement. The licensee is not obligated in any way to include permissives in the ITS. However, the.
staff does not agree with the licensee's perception as discussed in JFD #8. The staff is not aware of anything in NUREG-1433 or any other document that specifically states, in a generic sense, that one SR may be substituted for another SR.
Consistent with this view, the OGs have considered it necessary to include a generic statement in Section 3.0 of the NUREGs which allows unplanned events to satisfy the requirements of a SR. The staff recommends that the licensee reconsider this proposed deletion.
3 9 SR JfD 9 is acceptable. However, the The licensee should 3.8.1.2 and submittal could be improved by adding revise the 3.8.1.3 a discussion of how the issue of submittal to NUREG Table accelerated testing will be covered address staff 3.8.1-1 in the Brunswick implementation of concerns.-
the Maintenance Rule.
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t SIMISNICK HUREG MHKUP 3.8.1 ,
ITEM i ' JFD # CTS /STS DESCRIPTION OF,. ISSUE Cof9 TENTS - STATUS-LCO 4 12. SR Proposed SR 3.8.1.6 i somewhat The licensee should 3.8.1.6 confusing. The engine mounted tank provide a response contains only 150 gallons of fuel. to the staff Most, if not all of this fuel will be question and/or consumed during a monthly revise the surveillance, and makeup from the day submittal.
tank will be necessary. kith this in mind, why is the frequency for this SR established at 92 days?
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BRUNSWICK NUREG MARKUP 3.8.1 ,
ITEM i 'JFD f CTS /STS DESCRIPTION OF ISSUE COMMENTS STATUS- :
, LCO 5 2 SR Proposed Note 2 to ITS SR 3.8.1.8 is 3.8.1.8 confusing. Is this Note really 1 Notes necessary? If so, can it be reworded l SR to be more clear? The plant design 3.8.1.15 precludes an automatic transfer from the preferred offsite source to the alternate (or normal) source, so why is a Note necessary? The Note could also be interpreted to mean this capability never needs to be tested.
To illustrate this, consider the following. The plant is in Mode 3 through 5 and powered from its associated SAT - the Note says the automatic transfer SR is not required. Now, the plant transitions to Mode 2. The Mode restriction of Note I now precludes performing the test. When is the SR performed?
There is a possibility that NUREG-1433 Note 1 is also incorrect.
Consider the plant is Mode I but reducing power in preparation for a shutdown. At some point before entering Mode 3 (and possibly Mode 2), the power must be shifted from the UAT to the SAT. This can not be avoided, yet Note I would make 4
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l BRUNSWICK NUREG NMIKUP 3.8.1 ,
ITEM i JFD #J CTS /STS DESCRIPTION OFJISSUE ComENTS STATUS LCO -
this a TS violation. More thought The licensee'should needs to be given to both Notes 1 and reconsider both
- 2. Notes I and 2, and revise the The proposed frequency change for SR submittal, as 3.8.1.8 from 18 months to 24 months' necessary. Also, is beyond the scope of the ITS 18 for 24 months i<.
conversion, beyond the scope of this conversion.
6 2 SR The proposed frequency change for SR The change from 18 3.8.1.9 3.8.1.9 from 18 months to 24 months months to 24 months is be 2nd the scope of the ITS is beyond sco,w.
conversion.
7 15 NUREG JFD 15 contains statements with which The licensee should SR the staff is not necessarily in revise JFL 15.
3.8.1.10 agreement and which may be difficult 3.8.1.15 to substantiate. It is suggested this JFD be revised to simply state that the BNP current licensing basis does not include this requirement and the licensee does not wish to adopt it.
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i ORINISWICK '
IRIREG MARKUP :
3.8.1 . !
- I
~
i ITEM f. 'JFD'#? CTS /STS DESCRIPTION OFL ISSUEi d offlENTS; C
tcg; ; - -
STATUS I ;
8 17 NUREG The staff does not fully understand The licensee.should ;
SR JFD'17. The discussion appears to revise the 'l 3.8.1.11 say that all of the requirements of submittal to 3.8.1.12 j NUREG-1433 SRs 3.8.1.11 and 3.1.12 address staff
IIUREG SR 3.8.1.11 demonstrates proper system operation in the event of a LOOP, but without a LOCA, and involves only safe shutdown loads.
flUREG SR 3.8.1.12 demonstrates, among ,
other things, that permanently
- connected loads remain energized and emergency loads are sequenced on to
! .the offsite power system. ITS SR 3.8.1.14 ' (IIUREG SR 3.8.1.19) ,
2 demonstrates sequencing of emergency i loads on to the EDG. All three SRs h-ave ways in which they are different from each other and, for which .
reason, they should be performed.
The licensee'should reconsider the proposed deletion of IIUREG SRs l
3.8.1.11 and-3.8.1.12. '
9 2 SR The frequency change for ITS SR The change from 18 t 3.8.1.10 3.8.1.10 and SR 3.8.1.11 from 18 months to 24 months 3.8.1.11 months to 24 months is beyond the is beyond scope.
scope of the ITS conversion. !
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BRUNSWICK NUREG MARKUP 3.8.1 .
ITEM i JFD # CTS /STS DESCRIPTIDN OF ISSUEL COMMENTS STATUS LCO '
10 19 SR JFD 19 appears to indicate a lack of The licensee should 3.8.1.11 understanding of NUREG-1433. It is reconsider deleting not the intent of NUREG-1433 SR the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run 3.8.1.14 to subject a EDG to overload from the ITS.
conditions that could result in requiring an engine teardown (e.g.,
by exceeding a 2000 hr rating). The interst of this SR is to demonstrate the DEMA capability of the individual DGs by subjecting them to a 10%
overload for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. However, this is only a portion of the SR. The main emphasis of the SR is to run the EDG for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at or near full (centinuous) load to demonstrate capability for sustained operation.
This is not adequately , ,nstrated by operating at 3500-385G.;. for 60 minutes once per refueling. The licensee should reconsider deleting this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run from the Brunswick ITS.
)
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BMNtSNICK IRIREG HARKUP 3
3.8.1 :
ir ITEM i 'JFD # CTS /STS, DESCRIPTION 0F: ISSUE) CopetENTS : STATUS' LCO-l 11 20 NUREG The BNP CTS require a LOCA/ LOOP SR to The licensee should i SR . be performed once per refueling. To reconsider .
3.8.1.16 restore the plant to normal status including NUREG- '
without causing a loss of power 1433 SR 3.8.1.15 in !
condition requires paralleling with the BNP ITS. !
the grid and transferring power.back
- to offsite. This is implicit in the i j recovery from the LOOP /LOCA that,, in ,
the interest of clarity, is stated I i
separately in the NUREG. The ~
licensee should reconsider including this SR in the BNP ITS. :
i 12 21 SR The licensee should provide an The licensee should 3.8.1.12 expanded version of-JFD 21 which more revise the i clearly describes how proposed SR- submittal to 4
3.8.1.12 is a " logic" test, only. address staff The expanded JFD should also explain concerns. The i how a logic test satisfies the NUREG change in frequency i
- criteria of demonstrating that the DG from 18 months to
- returns to running standby from test 24 months is beyond !
mode in the presence of an ECCS the scope of ITS. '
- actuation signal.
13 2 SR The proposed frequency change from SR The. frequency i 3.8.1.13 3.8.1.13 and SR 3.8.1.14 from 18 change from 18 i 3.8.1.14 months to 24 months is outside the months to 24 months l scope of an ITS conversion. is outside the scope of ITS.
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1 e BRUNSWICK IENtEG MMtKUP 3.8.2 ,
ITEM JFD # CTSS/STS DESCRIPTION OFLISSUE~ COMMENTS < STATUS' i LCO 1 4 LCO 3.8.2 The NUREG-1433 markup adds a Note The licensee should Action A regarding LCO 3.0.3 not being revise the applicable. The markup indicates this submittal to is in accordance with TSTF-38. TSTF-38 address staff deals with batteries. The staff concerns.
believes the correct reference is TSTF-36, which has been rejected. The submittal should be changed accordingly.
Condition A of NUREG-1433 is modified by adding the term "or more" ahead of
" required offsite...". This is acceptable.. However, JFD 4 does not make an adequate case in support of this change. Specifically, the JFD does not address that this is the only practical way to address (in the Actions) the fact that more than one offsite circuit is required at BNP, and that the only actions that'can be taken in the e unt of offsite circuit inoperability are the same with one or both circuits inoperable. The JFD should be revised accordingly.
1 1.-. g.
BRUNSWICK NUREG MARKUP 3.8.2 ,
ITEM JFD # CTSS/STS DESCRIPTION OF ISSUE COP 91ENTS STATUS
- LCO 2 23 LCO JFD 23 addresses the BNP requirement for The licensee should 3.8.2.b two DGs to be OPERABLE during shutdown revise the and is acceptable. However, LCO 3.8.2.b submittal to appears to have a wording problem. The address staff LCO is worded such that it could be concerns.
interpreted as meaning two DG capable of supplying the same Class IE electrical power distribution subsystem. The licensee should consider changing LCO 3.8.2.b to read something like "two DGs, each capable of supplying it associated Class IE AC etc...."
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- BRUNSWICK 3.8.2 i
ITEM JFD # CTSS/STS.' DESCRIPTION OF ISSUE " ComENTS
- 1 STATUS' LCO ' '
s 3 4 SR- The staff does not fully agree with the The licensee'should- i 3.8.2.1 wording of proposed SR 3.8.2.1, as revise the. .i follows. SR 3.8.1.13 is, in the staff's submittal to "
i view, Not Applicable because it involves address staff i testing of intervals between timing concerns. .!
relays that are only needed to respond to a ECCS initation. An ECCs initiation '
is not postulated in Modes 4 and 5, so i the relays are not required to be. i OPERABLE and the SR is not required. SR !
' 3.8.1.15, however, is applicable since it addresses opposite unit SRs which j l
must be perfomed in order to maintain r system / component OPERABILITY for the i offsite unit.
The staff suggests expanding SR 3.8.2.1 to include 3 categories of SRs from LCO 3.8.1, and clearly identifying which SRs ,
fall into each of the categories. The suggested categories include 1-Applicable and must be performed, 2-Applicable but not required to be i . performed, and 3- Not Applicable. !
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BRUNSWICK -
NUREG MARKUP -
3.8.2 ,
ITEM JFD # CTSS/STS DESCRIPTION OF ISSUE COMMENTS STATUS
- LCO .
4 10 SR The staff does not agree with proposed The licensee should 3.8.2.2 SR 3.8.2.2. This SR is not necessary revise the and is potentially confusing. The SR submittal to only deals with SR 3.8.1.1 of the address staff opposite unit. This could be concerns.
misinterpreted as meaning that only SR :
3.8.1.1 from the opposite unit is j required. By making SR 3.8.1.15 ;
applicable, proposed SR 3.8.2.2 and any potential confusion associated with it will be eliminated. ,
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BRtMSWICK NUREG MARKUP e 3.8.3 ,
ITEM f JFD f CTS /STS- DESCRIPTION OF ISSt;E- ComENTS STATUS LCO -
1 25 LCO In JFD 25, the licensee The licensee should 3.8.3 states that the DG provide a response to starting air system also the staff questions.
provides engine control air. Is this control air required at all times for the DG to function; e.g.,
required to both start the DG and to operate the DG for an extended period of time? If control air is lost, will the DG fall?
The licensee should provide appropriate details.
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i samsurcx. -
- l IRREG MARKUP 3.8.4 ,
ITEM # JFD # CTS /STS; OESCRIPTION OF ISSUEf '
COPMENTS STATUS 1 LCO 1 32 SR The markup of SR 3.8.4.2 shows the The license 3.8.4.2 resistance valves being moved to the should revise the Bases. ,This is not acceptable. submittal to These valves should be retained as address staff acceptance criteria in the SR. concerns.
2 2 SRs The completion times for SRs 3.8.4.3 The licensee 3.8.4.3 and 3.8.4.4 are changed from 12 should provide a 3.8.4.4 months (NUREG) to 18 months (ITS). response to staff 3.8.4.5 Similarly, the completion time'in SRs questions and 3.8.4.6 3.8.4.5 and 3.8.4..i are changed from revise the 18 months to 24 months. BNP does not submittal, as now have a 24 month refueling cycle, appropriate.
and the change from 18 to 24 months a is outside the scope of the ITS conversion. Is the change from 12 mont'ns to 18 months a reflection of BNP CLB, or is this another change that is outside the scope of the ITS conversion. JFD 2 does not address the out of scope issue.
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BRUNSNICK NUREG MARKUP e 3.8.4 ,
ITEM i JFD #' CTS /STS' DESCRIPTIONOFISSUEl ComENTS STATUS-LCO :
3 32 NUREG NUREE-1433 SR 3.8.4.5 is deleted from The licensee ;
SR' the ITS. JFD 32 states that the should revise the ,
3.8.4.5 option exists to verify battery submittal to -
connection resistance is acceptable, address staff ;
but there is no sequirement to concerns. ~
measure resistance periodically. !
Consequently, in the ITS, if visible corrosion is removed, there would never be a requirement to verify that connection resistance is acceptable. ;
It is the staff's view that CTS SR 4.8.2.3.2.C.2 is a requirement to .
check connection resistance, albeit in a de facto sense. The SR requires !
verification that battery connectors i are " free" of " corrosion". There is !
no mention of visible corrosion, i which means the absence of invisible corrosion must also'be verified.
This can be done by physically !
disassembling the connections, or by taking resistance readings. This CTS requirement is not reflected in !
the ITS, and an adequate '
Justification has'not been provided I for the absence. The licensee should I provide the appropriate justification :
or add the requirement to the ITS. t 2
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BRUNSWICK NUREG MARKUP t 3.8.5 ,
ITEM # JFD f- CTS /STS DESCRIPTION OF ISSUE. COMMENTS STATUS LCO 1 N/A LCO 3.8.5 The proposed generic change to The licer,see Actions adda Note regarding 3.0.3 should delete the applicability has been rejected proposed Note.
by the staff.
2 10 SR The staff has some cancerns The licensee 3.8.5.2 regarding the Note in proposed should provide a SR 3.8.5.2. First, the Note response to the could be confusing because it staff concerns references SR 3.8.5.1, but the and suggestion.
SR proper references SRs in LCO 3.8.4. Second, why would the requirement to perform SRs be set aside just because irradiated fuel is being moved?
The licensee should consider revising the submittal to address these concerns. The staff suggests the licensee consider deleting the Note in favor of including all the information in the SR; e.g.,
"For required Unit (1)(2) DC electrical power distribution subsystems the SRs of LCO 3.8.4 or LCO 3.8.5 are applicable."
I u .
BRUNSWICK NUREG RMtKUP '
3.8.6 ,
ITEM i JFD # CTS /STS DESCRIPTION OF ISSUE CONfENTS STATUS LCO 1 28 LCO 3.8.6 The LCO requires batteries in The licensee 42 both units to be within limits. should However, the LCO is not specific consider as to which limits apply. revising the-Consequently, it could be LCO.
interpreted that Unit 2 batteries must meet the limits of Unit 1 Table 3.8.6-1. In the practical sense this is not a problem since Table 3.8.6-1 will be the same for both units. However, to avoid any potential confusion, the LCO should be revised to indicate that the opposite unit's batteries must be within the limits established for that unit.
2 N/A SR SR 3.8.6.3 may require changes to -
3.8.6.3 reflect responses to staff concerns regarding temperature of connected versus representative cells identified in consents on the CTS markup.
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BRtNISWICK -
IRfREG MARKUP f 3.8.7 ,
ITEM i JFD # CTS /STS DESCRIPTION OF ISSUE ColetENTS STATUS LCD I N/A LCO BNP ITS LCOs 3.8.I-3.8.6 include The licensee 3.8.7 requirements for opposite unit should address AC and DC electrical power staff concerns by subsystems. This LCO, however, revising the does not reflect any of those submittal or other LCO requirements. Only providing the Division I and Division II justification for AC and DC electrical power not changing the distribution subsystems are submittal.
required. Absent any indications to the contrary, one would have to assume the LCO requirements apply only to the associated unit. This conflicts with the remainder of the ITS.
A similar consent applies to ths Conditions and Required Actions.
There is nothing to indicate opposite unit power sources are required or how they should be I treated.
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BRUNSWICK NUREG MARKUP s*
3.8.8 T
'JFD f DESCRIPTION OF; ISSUE C00MENTS STATUS ITEM f CTS /STS LCO 1 N/A LCO The ITS LCO does not The licensee 3.8.8 address the requirement should address ;
for opposite unit power the staff concerns by 'I sources. (See Comment No.
I for LCO 3.8.7 in revising the l comments on NUREG markup.) submittal or providing a ;
discussion for why a change is not necessary.
2 N/A LCO The generic change to add 3.8.8 a Note to the Actions regarding 3.0.3 has not been accepted by the staff.
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