ML20236U746

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Submits Addl Info in Response to 871016 Request Concerning Request for Amend to License Re Tech Specs 3.0.3 & 3.0.5. Action Statement a.2 Revised in 870302 Tech Spec Change Request
ML20236U746
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/30/1987
From: Zimmerman S
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
87TSB18, NLS-87-268, NUDOCS 8712030341
Download: ML20236U746 (6)


Text

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CNLL Carolina Power & Light Company NOV 30 INR SERIAL:

NLS-87-268 10CFR50.90 87TSB18 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 TECHNICAL SPECIFICATION 3.0.3 AND 3.0.5 SUPPLEMENT

References:

1.

CP&L Letter from A.

B.

Cutter dated March 2, 1987, Serial N LS 0 0 6, " Specifications 3.0.3 and 3.0.5" 2.

NRC Letter from E.

D.

Sylvester, dated July 30, 1987,

" Technical Specifications 3.0.3 and 3.0.5 - Proposed License Amendment 86TSB18 - Request for Additional Information -

Brunswick Steam Electric Plant, Units 1 and 2 (TAC Nos. 64910

& 64911)"

3.

CP&L Letter from S.

R. Zimmerman dated September 2,

1987, Serial NLS-87-180, " Technical Specifications 3.0.3 and 3.0.5" 4.

NRC Letter from E.

D.

Sylvester dated October 16, 1987,

" Proposed Amendment to Facility Operating License Nos. DPR-71

& DPR-62 Regarding Technical Specifications 3.0.3, 3.0.5, and l

3.8.1.1, Brunswick Steam Electric Plant, Units 1 & 2 (TAC Nos. 64910 & 64911)"

Gentlemen:

On October 16, 1987, the NRC requested additional information from Carolina Power & Light Company relating to the Brunswick Steam Electric Plant (BSEP) request for license amendment concerning Technical Specifications 3.0.3 and 3.0.5.

Responses to the three l

concerns is provided below.

l 1.

Provide justification for the proposed change to Action l

Statements a.2 and a.3.

Action Statement a.2 In the original submittal of the Technical Specification change request, dated March 2, 1987, Action Statement a.2 I

was revised to state:

Verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that all redundant systems, subsystems, trains, components, and devices required to be OPERABLE that depend on the remaining offsite circuit as a source of power are also OPERABLE; y\\

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4 Document Control Desk NLS-87-268 / Page 2 otherwise be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; This wording was revised in the September 2, 1987 submittal in response to NRC concerns.

Action Statement a.2 now states:

Verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that all redundant systems, subsystems, trains, components, and devices required to be OPERABLE are also OPERABLE; otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; The wording was chosen to reflect the intent of TS 3.0.5, which allows a piece of equipment that is determined to be inoperable solely because either its emergency or normal power source is inoperable, to be considered operable if its redundant equipment is operable, for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation.

On the loss of one offsite power source, the redundancy criteria would not be met unless equipment redundant to that which was powered from the lost source is powered from the remaining operable offsite power source.

Action Statement a.3 In the March 2, 1987 submittal, Action Statement a.3 was revised to state:

1 Demonstrate the OPERABILITY of any diesel generator not currently running by performing Surveillance Requirement 4.8.1.1.2.a.4 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter; f

In the NRC request for information of July 30, 1987, justification was requested for testing only one diesel generator.

As noted in the March 2, 1987 submittal, surveillance would be required on any diesel generator not currently running and not only for one diesel generator as l

implied by the NRC question.

On September 2, 1987, CP&L submitted a response to the July 30 request for additional information in which the wording of Action Statement a.3 was changed to the following:

Demonstrate the OPERABILITY of the diesel generators by performing Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter on those diesels not already operating;

Document Control Desk NLS-87-268 / Page 3 The justification for either wording is the same.

On a loss of an offsite power circuit, at least one of the emergency buses will be de-energized.

On the loss of power to the emergency bus, the diesel generator for that bus will automatically start and tie on to the bus to supply emergency power.

It would be inappropriate to secure the diesel generator that is running and supplying power to the emergency bus, thereby causing a blackout on the emergency bus, to perform operability testing.

The diesel generator would already be performing its design function, thereby demonstrating its operability.

2.

Provide an evaluation in accordance with 10CFR50.91 relative to the significant hazards considerations for the September 2, 1987 submittal.

The September 2, 1987 submittal incorporated minor revisions to address NRC Staff concerns, and one minor technical change to Action a.3.

The minor revisions did not change the conclusions of the significant hazards analysis provided in our March 2, 1987 request.

The proposed revisions to the action statement requirements of TS 3.8.1.1 merely incorporate the requirements of TS 3.0.5.

As permitted by TS 3.0.5, equipment declared inoperable only because its normal power source is inoperable cen be considered operable if its redundant equipment is operable or satisfies the requirements of TS 3.0.5.

The changes provided in the September 2, 1987 submittal do not change the intent of the original request; i.e, the requirement that an alternate power source be operable and redundant equipment be operable.

Therefore, the probability and consequences of previously evaluated accidents are not increased, the possibility of a new or different kind of accident not previously evaluated is not introduced, and the margin of safety is not reduced.

This conclusion was previously provided in our March 2, 1987 submittal.

The changes to Action Statement a.3 were made to address a concern that if a diesel generator is running and supplying power during a loss of offsite power, the diesel should not have to be taken out of service to perform operability testing.

Taking a diesel generator out of service when it is operating could cause a blackout to the emergency bus, resulting in the loss of equipment being powered from the bus.

Adequate demonstration of the operability of the diesel generator is provided by the diesel performing its design function (i.e.,

1 running and providing emergency power to the emergency bus).

Thus, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated, does not create the possibility of any new or different kind of accidents, and does not involve a reduction in the margin of safety.

l

9 Document Control Desk NLS-87-268 / Page 4 The remainder of the September 2, 1987 submittal revisions incorporated an NRC approved license amendment issued after submittal of our initial request.

Therefore, an evaluation of

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these changes is not necessary 3.

Address an apparent typographical error in Action statement a.4 for Unit 1.

The error in Action Statement a.4 of the Unit 1 Technical Specifications is a typographical error.

Action Statement a.4 has been corrected to state; Restore the inoperable offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Page 3/4 8-1 is resubmitted in Enclosure 1.

Please refer any questions regarding this submittal to Mr. Stephen D.

Floyd at (919) 836-6901.

Yours very truly, S.

mmerman Manager Nuclear Licensing Section BAB

(\\cor\\ts303)

Enclosure cc:

Dr. J. Nelson Grace Mr. W. H. Ruland Mr. E.

D. Sylvester Mr. Dayne H. Brown

__.-_m.-__._

-.--____.____m_m__.____.__2

A 4

ENCLOSURE 1 REVISED TECHNICAL SPECIFICATION PAGE l

r (BSEP-1-93) 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.f.1 A.C. SOURCES OPERATION OF ONE OR BOTH UNITS LIMITINC CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

Two physically independent circuits between the offsite transmission a.

network and the onsite Class 1E distribution system, and b.

Four separate and independent diesel generators, each with:

1.

A separate engine-mounted fuel tank containing a minimum of 100

)

gallons of fuel,-

2.

A separate day fuel tank containing a minimum of 22,650 gallons of fuel, and 3.

A separate fuel transfer pump.

c.

A plant fuel storage tank containing a minimum of 74,000 gallons of fuel.

t APPLICABILITY: OPbRATIONALCONDITIONS*1,2,and3.

ACTION:

a.

With one offsite circuit of the above required A.C. electrical power sources not capable of supplying the Class 1E distribution system:

1.

Demonstrate the OPERABILITY of the remaining A.C. offsite source by performing Surveillance Requirement 4.8.1.1.1.a within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter; 2.

Verify within 'J hours that all redundant systems, subsystems, trains, components, and devices required to be OPERABLE are also OPERABLE; otherwise be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; 3.

Demonstrate the OPERABILITY of the diesel generators by performing Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter on those diesels not already operating; 4.

Restore the inoperable offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BRUNSWICK - UNIT 1 3/4 8-1 Amendment No.

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