ML20248G127
| ML20248G127 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/02/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20248G125 | List: |
| References | |
| NUDOCS 9806050114 | |
| Download: ML20248G127 (5) | |
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UNITED STATES l
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NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 30666 4001
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" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 200 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO. 230 TO FACILITY OPERATING LICENSE NO. DPR-62 CAROLINA POWER & LIGHT COMPANY BRUNSWlCK STEAM ELECTRIC PLANT. UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 l
1.0 INTRODUCTION
l By letter dated April 4,1996, as supplemented on January 24,1997, March 31,1997, April 2, 1997, April 14,1997, March 24,1998, and May 20,1998, Carolina Power and Light Company (CP&L or the licensee) requested amendments to Facility Operating Licenses Nos. DPR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2, respectively. The proposed amendments would change the plant Technical Specifications (TS) based upon the recommendations provided by the NRC in Generic Letter (GL) 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." The licensee requested the following revisions to TS 3.0.4,4.0.3, and 4.0.4.
The revision to TS 3.0.4 would allow entry into an OPERATIONAL CONDITION in accordance with ACTION requirements when conformance to the ACTION requirements provides an l
acceptable level of safety for continued operation of the facility for an unlimited period of time.
To prevent operator confusion, the ACTION requirements of appropriate Limiting Conditions for Operation (LCO) would be revised to remove specific reference to the nonapplicability of TS 3.0.4.
The revision to TS 4.0.3 would incorporate a delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in implementing I
ACTION requirements upon identification of a missed Surveillance Requirement when the ACTION requirements provide a restoration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The revision to TS 4.0.4 would add a clarifying statement that "This provision shall not prevent entry into OPERATION CONDITIONS or other specified applicability states that are required to comply with ACTION requirements."
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2 Revisions to the Bases sections associated with TS 3.0.4,4.0.3 and 4.0.4 reflecting the above changes were also proposed by the licensee.
2.0 EVALUATION The changes proposed by the licensee have been reviewed considering the guidance set forth in GL 87-09 for TS 3.0.4,4.0.3, and 4.0.4.
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GL 87-09 recognizes, in part, that TS 3.0.4 unduly restricts facility operation when conformence to the ACTION requirements provides an acceptable level of safety for continued operation in any mode. For an LCO that has ACTION requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those ACTION requirements. The restriction on change in operational modes or other specified conditions should apply only where the ACTION requirements establish a specified time interval in which the LCO must be met or a shutdown of the facility would be required or where entry into that operational mode would result in entry into an ACTION statement with such time constraints. However, nothing in GL 87-09 should be interpreted as endorsing or encouraging plant startup with inoperable equipment. GL 87-09 itself states that startup with inoperable equipment should be the exception rather than the rule.
By letter dated January 24,1997, the licensee provided confirmation that the remedial measures prescribed by the ACTION statement for each change involving TS 3.0.4 is consistent with the Updated Final Safety Analysis Report (UFSAR) and its supporting safety J
analyses. Further, the licensee has provided confirmation that appropriate administrative controls and procedures will be put in place prior to implementation of this TS 3.0.4 amendment for goveming the use of TS 3.0.4 exceptions. Additionally, no changes are proposed that affect plant configuration, setpoints, operating parameters, or the operator / equipment interface.
Based on review of the licensee's proposal, and confirmations related above, the NRC staff concludes in granting the exceptions proposed in response to GL 87-09 that: 1) the remedial measures proscribed by the ACTION requirement for each change involving the applicability of the TS 3.0.4 exception should provide a sufficient level of protection to permit operational mode changes and safe long-term operation consistent with the plant's UFSAR; and 2) the licensee has in place adequate administrative controls and procedures which will ensure that it will be the exception rather than the rule that startup of the plant with important safety features inoperable will occur.
I The staff, therefore, finds the following change to TS 3.0.4 proposed by the licensee to be acceptable:
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"When a Limiting Condition for Operation is not met, entry into an OPERATIONAL
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' CONDITION or other specified applicability state shall not be made except when the.
i associated ACTIONS to be entered permit continued operation in the OPERATIONAL CONDITION or other specified operability states for an unlimited period of time. This specification shall not prevent changes in OPERATIONAL CONDITIONS or other I
specified applicability states that are required to comply with ACTION requirements.
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l Exceptions to this specification are stated in the individual specifications. These exceptions allow entry into OPERATIONAL CONDITIONS or other specifed applicability states when the associated ACTIONS to be entered allow unit operation in the OPERATIONAL CONDITIONS or other specified applicability states only for a limited period of time."
TS 4.0.3 l'
L in GL 87-09 the NRC staff stated that it is overly conservative to assume that systems or
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components are inoperable when a Surveillance Requirement (SR) has not. been performed, because the vast majority of surveillance demonstrate that systems or components are in fact operable. Because the allowable outage time limits for some TS ACTION requirements do not provide an appropriate time limit for performing a missed SR before shutdown requirements apply, the TS should include a time limit that would allow a delay of the required actions to permit performance of the missed SR; This time limit should be based upon considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the SR, as well as the safety significance of the delay in completion of the SR. After reviewing possible limits, the staff concluded that, I
based on these considerations,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed SR when the allowable outage times of the ACTIONS are less than this time limit or I
when shutdown ACTIONS apply. The 24-hour time limit would balance the risks associated with an allowance for completing the SR within this period against the risks associated with the j
potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with ACTIONS before the SR can be completed.
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This time limit does not waive compliance with TS 4.0.1. Under TS 4.0.1, the failure to perform l
an SR will continue to constitute noncompliance with the operability requirements of an LCO i
and will bring into play the applicable ACTIONS.
Based on the above, the following change to TS 4.0.3 is acceptable:
"If it is discovered that a Surveillance Requirement was not performed within its specified I
time interval, then compliance with the requirement to declare the Limiting Condition for
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Operation not met may be delayed, from the t.ime of the discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the period of the specified time interval, whichever is less. The delay period is permitted to allow performance of the Surveillance Requirement.
if the Surveillance Requirement is not performed within the delay period, the Limiting i
Condition For Operation must immediately be declared not met, and the applicable ACTION (S) must be entered.
When the Surveillance Requirement is performed within the delay period and the Surveillance Requirement is not met, the Limiting Condition For Operation must immediately be declared not met, and the applicable ACTION (S) must be entered."
TS 4.0.3 was reworded by the licensee so that it would substantially conform with the language set forth in NUREG 1433, Rev.1, " Standard Technical Specifications, General Electric Plants, BWR/4." Similarly, the licensee proposed revised language for TS 4.0.1 that the staff finds acceptable in that it brings that specification into substantial conformance with NUREG 1433.
TS 4.0.1 addresses the conditions when SRs shall be met.
TS 4.0.4 TS 4.0.4 prohibits entry into an OPERATIONAL CONDITION or other specified condition until all required surveillance have been performed. This could cause an interpretation problem when OPERATIONAL CONDITION changes are required in order to comply with ACTION statements. Specifically, two possible conflicts between TS 4.0.3 and TS 4.0.4 could exist. The first conflict arises because TS 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. For example, in the event an ACTION statement requires entry into a target OPERATIONAL CONDITION, TS 4.0.4 could be interpreted to prevent such entry if a Surveillance Requirement for the target OPERATIONAL CONDITION has not been performed within its required interval. The licensee proposed a change to resolve this conflict involving the revision to TS 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the application of the ACTION requirements, as explained above, and e clarification of TS 4.0.4 to allow passage to operational modes as required to comply with ACTION requirements. The second possible conflict between TS 4.0.3 and TS 4.0.4 arises because an exception to the requirements of TS 4.0.4 is allowed when Surveillance Requirements can only be completed after entry into a mode or condition. However, after entry into this mode or condition, the requirements of TS 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowable surveillance interval.
The licensee proposes to resolve these conflicts by providing the following clarifying statement to TS 4.0.4:
"This provision shall not prevent entry into OPERATIONAL CONDITIONS or other i
specified applicability states that are required to comply with ACTION requirements."
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5 The NRC staff has provided in GL 87-09 a clarification that: (a) it is _not the intent of TS 4.0.3 that the ACTION requirements preclude the performance of surveillance allowed under any exception to TS 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in TS 4.0.3 for the applicability of ACTION requirements provides an appropriate time limit for the completion of Surveillance Requirements that become applicable as a consequence of any exceptions to TS 4.0.4.
Consequently, the NRC staff finds the proposed changes to TS 4.0.4 to be clarifying in nature and are therefore acceptable.
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3.0 STATE CONSULTATION
in accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 EliylRONMENTAL CONSIDERATION The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change Surveillance Requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (61 FR 37297). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
l The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
PrincipalContributor: D.Trimble Date: June 2,1998