View source for BSEP-93-0232, 1992 Annual Rept in Accordance W/10CFR50.59

{{Adams
| number = ML20062M404
| issue date = 12/31/1992
| title = 1992 Annual Rept in Accordance W/10CFR50.59
| author name = Levis W
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-93-0232, BSEP-93-232, NUDOCS 9401070056
| document type = ANNUAL OPERATING REPORT, TEXT-SAFETY REPORT
| page count = 43
}}

=Text=
{{#Wiki_filter:- -- . -                 - -           -.                  . - .                     .   --     _         . - .           . ~ - ~
CP84 C-arolina Power & Light Company wilM.rzM22MuwcnwtwNun Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461-0429 DEC 31 1993                           SERIAL: BSEP 93-0232                     !
10CFR50.59 U. S. 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 ANNUAL REPORT IN ACCORDANCE WITH 10 CFR 50.59 Gentlemen:                                                                                                               ;
The purpose of this letter is to transmit the annual report for 1992 in accordance with the '
requirernents of 10 CFR 50.59 for the Brunswick Nuclear Plant (BNP). This report contains brief functional summaries of procedures and plant modifications which are changes to the facility as described in the FSAR during 1992. The report also contains summaries of those tests or experiments conducted in 1992 which are not described in -
the FSAR. As required by 10 CFR 50.59, records of these changes in facility, changes in                                  ,
procedures, and tests or experiments are available for inspection at Brunswick Nuclear Plant.                                                                                                                   .
Enclosure 2 provides a List of Regulatory Commitments contained in this submittal. Please refer any questions regarding this submittal to Mr. G. Honma at (910) 457-2741.                                          ,
Very truly yours,                                                        J W. Levis, Manager-Regulatory Affairs; Brunswick Nuclear Plant JCPTjcp Enclosures cc:    Mr. S. D. Ebneter, Regional Administrator, Region 11                 .
Mr. P. D. Milano, NRR Senior Project Manager - Brunswick Units -1 and 2 Mr. R.' L. Prevatte, Brunswick' NRC Senior Resident inspector.
9401070056' 921231'            [
PDR    ADOCK-05000324                                                                     f .
                  .R                      pop    g@N                                                                    lj t-r .                   -   _                                         . . - - -              , , , _         . - . ,

I i
Enclosure 1 i
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 l
1992 ANNUAL REPORT IN ACCORDANCE WITH 10 CFR 50.59 T
e t
5 t
t I
                                                                          -l 1
                                                                          'l

Table of Contents Lttro                                                                                                   P_agels)
En_gineerina Desian Packanes EDP 92-005, Unit 2 - Decommissioning Spent Resin Pump Pressure Switch, 2-G16-PSL-4392                . . .... ........                                . . .... ....                1 Direct Replacement Packanes DR 89-0348, Unit 2 - Replacement of Gate Valve 2.B32-V22 With Globe Valve                ... . ..                     . . .......                       . . .         . 2-DR 90-0122, Unit 2 - Replacement of Stuffing Box Extension for Heater Drain Pumps . ......... . ..                                        . ... ..                 . ......       3 DR 91-0055, Unit 2 - Direct Replacement of 2-E41-F022                                    .         .............                 4 DR 91-0097, Unit 2 - Replacement of TBCCW Heat Exchanger Velan Gate Vent and Drain Valves with Conval Globe Valvec .... ..                                              .......         .5 DR 92-0293, Unit 2 -Installation of Replacement Gasket - MSIV F028D Only . . . . .       .. .....                        .       . ..            .          ... .. ...           6' Plant Modification Packanes PMs 80-260 and 80-261, Unit 1 and Unit 2 - Addition of Plant Air Compressors   ..    ..      ..        ....,. ... . .....                                  .. .... . ..              7 PM 86-084, Replacement of Diesel Generator Cell Fire Protection Ionization Protectors with Flame and Heat Detectors . . . . . .                                   .         .   ...8 PM 87-002, Unit 2 - Modification of Control Circuits for E11-F068 Valve .                                          .......9 PM 87-203, Unit 1 - Modification to the Unit 1 Turbine Building Sample System PM 87-204, Unit 2 - Modification to the Unit 2 Turbine Building Sample System . . . .                                           10 PM 89-029, Unit 2 - HPCl/RCIC Reliability improvements . . . . . . . . .                                ...........             11 PM 91-044, Unit 2 - Circulating Water Alternate Biocide injection and Sampling Points - . . ... .                      ...           , .            ................                    12-PM 92-108, Unit 1 and Unit 2 - Control Building Emergency Air Filtration System improvements . . .                        ... ... . ........... ..                              13 Enaineerina Evaluation Rerlpfts EER 90-119, Evaluation of the Requirement / Necessity of Cable Tray Covers on "D" Level Cable Trays . . . . . . . .          ....... ... ............ ...                                           14 EER 90-0182, Unit 1 and Unit 2 - Evaluation of CAC/ CAD PCIS Function Based Upon Separation Discrepancies Found . . . . . . . . . . . . . ................                                            15 i

I Table of Contents Lte_m                                                                                                     Page))
EER 91-0299, Unit 1 and Unit 2 - Operational Requirements for AT-4409/4410 Hydrogen / Oxygen Analyzer .. . ..                                . .. ......                          . .             16 EER 91-0400, Unit 1 and Unit 2 - Battery Room Chart Recorder installation . .                                              .      . 17  -
EER 91-0449, Unit 2 - Temporary Repair of Recirculation Drain Lines . .                                .........                    18 i
EER 92-0048, Unit 1 - Use Of Fire Protection Water For Battery Testing                                    ... ....                  19 EER 92-065, Unit 1 and Unit 2 - Suppression Pool Oxygen increase During RCIC Operation          ..            .. ...            ...          . .....                    ....         20 EER 92-0076, Unit 1 and Unit 2 - Raising Discharge Temperature                                                                          '
Switch Setpoints for Joy Compressors           .          . ..           ...           . . ..                    .              . 21 EER 92-0090, Unit 1 and Unit 2 - Turbine Building Power Roof Ventilator Temporary Blank-Off .   . .                             .. .              .        . .... . . . . . .                    22  r EER 92-0186, Unit 1 and Unit 2 - Permanent Repair of Turbine                                                                              i Building Cooling Tower           .    . .         .... ..                ..          ...... ... ...                             . 23 EER 92-0261, Unit 1 and Unit 2 - Standby Gas Treatment System Heat Detection Circuit Fuse Assessment . .                   .....          ..         ..              ........                     24 EER 92-0300, Unit 1 - Control of Reactor Building Static Pressure EER 92-0228, Unit 2 - Control of Reactor Buildint, Static Pressure . .                              ..         .. .           . 25    ,
EER 92-0305 Unit 2 - RHR "B" Temporary Flow / Pressure Instruments                                  . ..                   .      . 26 EER 92-0370 and EER 92-0371, Unit 1 RHR "A" & Unit 1 RHR "B" Temporary Flow / Pressure Instruments     ....... .......... ........ ......                                                        27.
EER 92-0387, Unit 1 and Unit 2 - Radwaste HVAC Abnormal Fan Lineups . . .                                            ....28 EER 92-0392, Unit 1 - Temporary Alternate Reactor Level Alarm Installed Due to Work on PM 89-001 ..... .. .................. ..                                                         ..        29 l
EER 92-0406, Emergency Substation Tie Breaker                                                                                             ,
Undervoltage Trip Device Removal ......... ........ ... . ..                                                  ...            .. 30    )
EER 92-0534, Unit 1 - Temporary Modification for Equalization                                                                             )
of 1-SA PDIS-4489       . .. ..    . . .            ....             ...          ........                       ..          .. 31 EER 92-0566, installation of Temporary Potable Water Supply                                    ...........                        . 32 l
ii

1 l
l Table of Contents item                                                                          P. agetsj l
Chan.ges to Procedures As Described in the FSAR 0-OP-37.2, Radwaste Building Heating and Ventilation System Operating Procedure . . . ......           ..... ...  . ..... ..... .....                       33 0-SP-92-003, Operations Support for OM-6 Qualification of Service Water Pumps . . . . . ..               ... ..            ,.... ..              ...   .. 34       i Tests or Experiments Not Described in the FSAR OSP 91-011, Testing Instrument Air Dewpoint              ..          ....            .. .              L 'i OSP-91-092, OM-6 Service Water Pump Vibration Testing .                 . .       ...         .        '2 2-SP 92-039, Unit 2 - Test of ClamTrol for Macrofouling Control in Circulating Water System      ....           . ..    ... . ... . . ...                    . 37 t
i 1
                                                                                                                +
l iii l
r

CHANGE TO FACILITY AS DE!;CRIBED IN THE FSAR TITLE:       EDP 92-005, Unit 2 - Decommissioning Spent Resin Pump Pressure Switch, 2-G16-PSL-4392 i
BRIEF DESCRIPTION:
l EDP 92-005 evaluates the feasibility of decommissioning the spent resin pump low suction pressure trip function.                                                                           .j l

==SUMMARY==
OF THE SAFETY EVALUATION:                                                                   l l
The Spent Resin Pump low suction pressure trip function protects the pump from damage
                                                                           ~
I caused by operating dry. This pump protection is also provided by an existing pump trip on low tank level, 'In addition, the affected equipment is non-Q and has no impact on plant operation. Consequently, this change: (1) does not increase the probability or consequences of an accident previously evaluated in the FSAR, (2) does not create the possibility of a new or different type of accident than previously evaluated in the FSAR,           i and (3) does not reduce the margin of safety as defined in the basis of any Technical               ,
Specification.                                                                                      '
l l
l l
l i
l l
l 1

i f
CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       DR 89-0348, Unit 2 - Replacement of Gate Valve 2-832-V22 With Globe Valve BRIEF DESCRIPTION:
This DR evaluated replacement of a 3/4" Volan gate valve with a Conval globe valve. The existing Velan gate valve failed the LLRT.

==SUMMARY==
OF THE SAFETY EVALUATION:
The Conval valve installed in place of the Velan valve for 2-832-V22 was evaluated in DR 89-0348 to meet design requirements for the specific application, meet all requirements of      l the FSAR, and does not change the mechanical operating characteristics of the                   j Recirculation System. Tne valve replacement does not increase the probability of                .
occurrence or conseque ices of any FSAR Chapter 15 accident.
Design considerations (including mechanical, electrical, seismic, interface, etc.) for the Conval valve have been evaluated and shown to meet or exceed the original valve requirements. This DR (including EER 90-0023, Rev.1) has addressed the torque requirements and operating margins of the valve and motor operator to ensure the safety function of the valve is not affected. Thus this valve replacement will not reduce the margin of safety as defined in the bases of the Technical Specification.
P i
s 8
4 b
2

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:          DR 90-0122, Unit 2 - Replacement of Stuffing Box Extension for the Heater Drain Pumps l
BRIEF DESCRIPTIO_N_:
This DR evaluates replacement of the existing stuffing box design for the Unit 2 heater drain pumps with the new three-element stuffing box design recommended by the pump manufacturer. The upgraded stuffing box design was not supplied with a quench type packing gland as it was removed from the product line as obsolete. Consequently, this DR also evaluates deletion and removal of the gland seal quench piping (smothering supply-line) to the pump packing gland.
StJMMARY OF THE SAFETY EVALUATION:
The replacement stuffing box design performs the same design function as the existing                [
stuffing box. The replacement stuffing box design will increase the performance and reliability of the subject pumps, provide a more reliable pressure boundary, and reduce the probability of a radiological release to the surrounding environment. The heater drain               t system is not classified as nuclear safety-related and would be isolated in an accident situation. The proposed stuffing box upgrade and smothering line removal will not affect             t the operation of safety-related equipment. The heater drain pumps are not designed as equipment for mitigating an accident. The proposed change is of a manuf acturer's standard design and does not adversely affect equipment which is important to safety.
9 f
3

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE: DR 91-0055, Unit 2 - Direct Replacement of 2-E41-F022                                            I BRIEF DESCRIPTION:
P This change is a direct replacement of a 2 inch Velan stop check valve with a 2 inch                   l Conval stop check valve.
i f

==SUMMARY==
OF THE SAFETY EVALUATION:                                                                      .
The stop check valve in question is the HPCI Turbine EHX Drain Pot Valve to the torus which isolates on reactor vessel low level, high drywell pressure and individual system leak-          ,
detection. The replacement valve satisfactorily performs the same functions as the original valve and meets or exceeds the design requirements of the original valve. The replacement valve materials, size, and weight were reviewed and found to be acceptable
                                                                                                             .i to this application. Consequently, this change: (1) does not increase the probability or               ,
consequences of an accident previously evaluated in the FSAR, (2) does not create the possibility of a new or different type of accident than previously evaluated in the FSAR,              j and (3) does not reduce the margin of safety as defined in the basis of any Technical                  ,
Specification.                                                                                         i i
f                                                                                                             ?
4 e
i 4                                                         i l

k CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:      DR 91-0097, Unit 2 - Replacement of TBCCW Heat Exchanger Velan Gate Vent and Drain Valves with Conval Globe Valves BRIEF DESCRIPTION:
This DR evaluates replacement of 3/4 inch Velan gate vent and drain valves (Velan Model W4-254B-2TS) with 3/4 inch Conval globe valves (Conval Model 0.75-11 G2J-105-5E).
i

==SUMMARY==
OF THE SAFETY EVALUATION:
These replacements are part of a program to replace Velan valves due to their high                    l maintenance, low reliability, and difficulty in obtaining spare parts. The replacement valves perform the same functions as the valves to be replaced and meet or exceed the design requirements of Specification 248-117. The replacement valves will better ensure             .i the performance, reliability, and integrity of the subject valves is not degraded.
J i
i 5

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:      DR 92-0293, Unit 2 -installation of Replacement Gasket - MSIV F028D Only BRIEF DESCRIPTION:
The purpose of this DR is to install a replacement spiral wound gasket to suit the modified body bore for MSIV 2-821-F028D.                                                               -

==SUMMARY==
OF THE SAFETY EVALUATION:
The subject MSIV body was align bored to improve the valves disk / piston stem alignment with the valve body bore and seat. This repair requires a replacement gasket with slightly    I enlarged inside and outside diameter to fit the finished dimensions of the repaired valve. l The function and operation of the MSIVs are unchanged by this spiral wound gasket replacement. The valve will still be capable of isolating the primary containment within      '
Tech Spec time limits while the overall reliability of the valve has been improved.
h i
s 6

I 3
1 CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLEi:    PMs 80-260 and 80-261, Unit 1 and Unit 2 - Addition of Plant Air Compressors BRIEF DESCRIPTION:
These modifications added compressors 1D and 2D to the plant compressed air system.

==SUMMARY==
OF THE SAFETY EVALUATION:                                                                1 The added compressors increased the capacity of the existing compressed air system. No challenges to the plant barriers or transient initiators result from the changes; therefore, no  ,
unreviewed question is introduced by this change.                                                j t
7

. _                          .~.      .                        .          _.  ..     ,     _ _ _ .
l i
CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       PM 86-084, Replacement of Diesel Generator Cell Fire Protection Ionization Protectors with Flame and Heat Detectors.
BRIEF DESCRIPTION:
l PM 86-084 changed out the smoke detectors in certain fire zones in the Diesel Generator            i Building to flame and heat detectors.                                                              l

==SUMMARY==
OF THE SAFETY EVALUATION:
The NRC Staff has reviewed the proposed modification and associated Technical Specification changes and agreed with the licensee's appraisal of the potential problems with the existing type of the detection system instruments. The Staff found the proposed changes to be consistent with the guidance of SRP BTP 9.5-1 and NFPA 72D, Standard for the installation. Maintenance and Use of Proprietary Sianalina Systems, published by the National Fire Protection Association.
The modifications proposed by the licensee for the fire detection systems in the
* emergency diesel-generator buildings and the corresponding changes to their operating Technical Specifications are, therefore, acceptable to the NRC Staff.
e i
5 1
1 t
I 8
i
                                                                                                   -l

I CHANGE TO FACILITY AS DESCRIBED IN THE FSAR                            [
TITLE:        PM 87-002, Unit 2 - Modification of Control Circuits for Valve 2-E11-F068 l
J BRIEF DESCRIPTION:
                                                                                               ?
This modification replaces the automatic control loop for Unit 2 valve 2-E-11-F068B with a manual control switch. in addition, a key-locked switch will be installed that will allow manual control of 2-E11-F068B under conditions of loss of DC control power and if both RHR service water pumps are not running. The switch eliminates the need to perform wire-fifts currently being performed under the system operating procedure.

==SUMMARY==
OF THE SAFETY EVALUATION:
Replacement of the automatic controls with manual controls does not reduce the capability of the E11-F0688 valve to perform its design functions in the required time; therefore, no unreviewed safety question is introduced as a result of this modification.                   ,
e t
l j
l I
9 l
i

1 CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:      PM 87-203, Unit 1 - Modification to the Turbine Building Sample System PM 87-204, Unit 2 - Modification to the Turbine Building Sample System              l I
BRIEF DESCRIPTION:
PM 87-203 and PM 87-204 upgrade and relocate equipment in the Unit 1 and Unit 2 Turbine Building Sample Stations (TBSS), respectively, and also install a dissolved hydrogen analyzer for hydrogen water chemistry analysis in each Unit.

==SUMMARY==
OF THE SAFETY EVALUATION:
Modification and upgrade of the Unit 1 and Unit 2 TBSS does not change any assumptions or analyses in the FSAR. Functional capability of the existing systems is enhanced by the changes being made. Technical Specification sampling requirements are not negatively affected by these changes. These modifications result in improved functional capability of the systems; therefore, no unreviewed safety question is introduced as a result of these changes.                                                                                      >
p I
I 1
l 10                                                 j

i CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:        PM 89-029, Unit 2 - HPCl/RCIC Reliability improvements i
BRIEF DESCRIPTION:
Plant Modification 89-029 includes the following HPCl/RCIC reliability improvements:           i (1) removal of the auto open logic for valves E41-F002, E41-FOO3, E51-F007, and E51-F008; (2) installation of key lock switches in control room relay cabinets for valves E41-F002, E41-F003, E51-F007, and E51-F008; and (3) changing the Steam Tunnel                  i Temperature High Alarm for the HPCI and RCIC systems from annunciating at 175 degrees          !
F to 155 degrees F.

==SUMMARY==
OF THE SAFETY EVALUATION:
Removal of the auto open logic will not cause a failure of the HPCI or RCIC system to auto initiate as required. The valves will be administratively maintained in the open position except when performing maintenance. Administratively maintaining proper valve line-up to allow safety system operation is an acceptable control. In addition, two PRAs of increased core damage was performed. The first was without the modifications to the auto open signals for the HPCI and RCIC systems. The second was with the modification. The PRAs confirmed the engineering judgement that the change has an insignificant effect on core damage frequency.
Installation and use of override switches for valves E41-F002, E41-F003, E51-F007, and E51-F008 will not degrade the function of the valves or the ability of the HPCI or RCIC        ,
systems to operate. The override switches will keep the valves open in the event of a high     '
differential pressure signal of the associated systems. If the HPCI or RCIC systems receive auto start signals, the valves will be open and will not prevent the systems from performing their functions. The switches will be administratively controlled by procedure      ,
and the key can only be removed in the normal position. Also, the valves receive an           i isolation signal from PCIS isolation signals downstream of the override switch. Therefore the override switch cannot prevent the valves from performing their isolation functions.       l The temperature switches (E41-TS-N600 and E51-TS-N600) for the Steam Tunnel                    !
Temperature High Alarm have no safety related function, however, they can provide early-       !
warning to the control room operators in the event of rising steam tunnel temperature.         !
The HPCI and RCIC systems both isolate with steam tunnel temperature at 165 degrees F.         .
Lowering the Steam Tunnel Temperature High Alarm setpoints to 10 degrees F below the isolation point provides this early warning and has no adverse effect on either system.        ;
t The safety analysis' determined that PM 89-029:(1) does not increase the probability or        l consequences of an accident previously evaluated in the FSAR, (2) does not create the -
possibility of.a new or different type of accident than previously evaluated in the FSAR,      !
and (3) does not reduce the' margin of safety as defined in the basis of any Technical         l Specification.                                                                                 j i
11 j

                                                                                                )
CHANGE TO FACILITY AS DESCRIBED !N THE FSAR                                 f TITLE:       PM 91-044, Unit 2 - Circulating Water Alternate Biocide injection and Sampling Points                                                                              )
BRIEF DESCRIPTION:                                                                              j This modification adds piping to the Circulating Water (CW) System to f acilitate the controlled injection of a biocide downstream of the CW Intake Pumps. The modification
                                                                                                ]
also adds tubing and valves from the condenser outlet water boxes drain tap valves to a         ;
location outside the turbine building to facilitate sampling CW without entering a locked        ,
high radiation area during normal unit operation,                                                1 J

==SUMMARY==
OF THE SAFETY EVALUATION:
The changes made by this modificatica do not change the system or component functions in a manner that would adversely affect safety. No effects on the CW system would affect any analyzed transients; therefore, no unreviewed safety question is introduced by this modification.
                                                                                              .1 i
4 I
12

I CHANGE TO FACILITY AS DESCRIBED IN THE FSAR
                                                                                           -I TITLE:     PM 92-108, Unit 1 and Unit 2 - Control Building Emergency Air Filtration ~       ,
System Improvements                                                              ,
BRIEF DESCRIPTION:
PM 92-108 corrects two potential single f ailures which could adversely impact the Control Building Emergency Air Filtration (CBEAF) system.

==SUMMARY==
OF THE SAFETY EVALUATION:                                                           )
The changes to the BSEP CBEAF System implemented by PM 92-108 were evaluated and accepted by the NRC in their " Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No.161 to Facility Operating License No. DPR-71 and         :
Amendment No.192 to Facility Operating License No. DPR-62, Carolina Power & Light           !
Company, Brunswick Steam Electric Plant, Units 1 and 2," issued March 22,1993 (TAC          :
Nos. M85143 and M85144).                                                                    I l
i 1
1 l
l J
                                                                                             \
l l
13

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 90-0119, Evaluation of the Requirement / Necessity of Cable Tray Covers On "D" Level Cable Trays In The Cable Spread Room (Cont. Bldg.)
BRIEF DESCRIPTION:
EER 90-0119 evaluated the feasibility of non-replacement of cable tray covers on Type IV
("D Level) cable trays, except for divisional separation requirements, in the cable spreading rooms.

==SUMMARY==
OF THE SAFETY EVALUATION:
Based on cable characteristics (EMI and RFI protection), administrative controls (physical protection), the f ad itat the cable spreading rooms are mechanical projectile free, and that the covers do not serve as a fire barrier, the EER determined that the cable tray covers are not required in the cable spreading rooms except for divisional separation or cable tray crossover. Consequently, this change: (1) does not increase the probability or consequences of an accident previously evaluated in the FSAR, (2) does not create the possibility of a new or different type of accident than previously evaluated in the FSAR, and (3) does not reduce the margin of safety as defined in the basis of any Technical Specification.                                       "'
                                                                                              )
I 14

l 1
l CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:        EER 90-0182, Unit 1 and Unit 2 ' Evaluation of CAC/ CAD PCIS Function Based Upon Separation Discrepancies Found i
BRIEF DESCRIPTION:
EER 90-0182 evaluated the impact of discrepancies found in the Division I and Division 11 physical wiring separation in the Unit 1/2 CAC System Containment isolation Valves on the N 2 inerting, air purge, and purge / exhaust lines to and from the Drywell and the Suppression Pool. The concern was that there might exist a f ailure mode whereby the isolation valve (s) would not perform their safety related function.

==SUMMARY==
OF THE SAFETY EVALUATION:                                                              ,
Based upon a review of the as-installed system wiring, no single f ailure mode (using the      '
single f ailure analysis) was identified which could prevent containment isolation upon a LOCA signal for the affected valves. Additionally, if one of the valves failed to open upon    j the receipt of a LOCA signal override command, the DC-powered redundant vent / exhaust         ;
path would provide the venting capability. Consequently, the identified discrepancies:         l (1) do not increase the probability or consequences of an accident previously evaluated in     !
the FSAR, (2) do not create the possibility of a new or different type of accident than previously evaluated in the FSAR, and (3) do not reduce the margin of safety as defined in the basis of any Technical Specification.
t j
l 15
                                                                                            =,

t CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 91-0298, Unit 1 and Unit 2 - Operational Requirements for AT-4409/4410 Hydrogen / Oxygen Analyzer BRIEF DESCRIPTION:                                                                      }
This EER evaluates a change in the operation of the drywell hydrogen / oxygen analyzers i from continuous operation to standby operation (operate for sampling and post-accident monitoring).

==SUMMARY==
OF THE SAFETY EVALUATION:
The hydrogen / oxygen analyzers are designed to provHe measurement of hydrogen and oxygen concentration in the drywell following a loss of coolant accident, as well as providing intermittent sampling of the drywellin accordance with the Technical Specifications. Operation of the analyzers in standby during normal operation does not affect the capability of the system to perform its design functions; therefore, no      ,
unreviewed safety question is introduced as a result of this change.                    .
i l
l 16

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 91-0400, Unit 1 and Unit 2 - Battery Room Chart Recorder Installation BRIEF DESCRIPTION:
EER 91-0400 evaluates the feasibility of temporary installation of chart recorders for the 125/250 VDC batteries to assist in ground detection.

==SUMMARY==
OF THE SAFETY EVALUATION:
EER 91-0400 reviewed temporary installation of four Chessel Model 345 chart recorders for the purpose of ground detection. The EER concludes that the chart recorders are non-safety related and are connected to the 125/250 VDC batteries through the non-safety related ground detectors. The ground detectors are isolated from the system via safety related fuses, thereby also isolating the recorders. The recorders are connected between the PN Bus and ground and will not add any additional load to the DC system. The mounting of these chart recorders was also reviewed with respect to seismic loadings.
The installation of the chart recorders does not impact other plant systems. Consequently, this change: (1) does not increase the probability or consequences of an accident previously evaluated in the FSAR, (2) does not create the possibility of a new or different type of accident than previously evaluated in the FSAR, and (3) does not reduce the margin of safety as defined in the basis of any Technical Specification.
17

b l
                                                                                            -l l
CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:        EER 91-0449, Unit 2 - Temporary Repair of Recirculation Drain Lines BRIEF DESCRIPTION:                                                                           ,
This EER evaluates the temporary repair of the two inch Reactor Recirculation System Pump A Suction Header Drain Line by capping the line downstream of valves 2-B32-F051 A       l and 2-832-F052A which are leaking past the seats.

==SUMMARY==
OF THE SAFETY EVALUATION:
The cutting and capping of the Reactor Recirculation System Pump A Suction Header Drain       ,
Line will not af fect the normal operation or safe shutdown capabilities of BSEP Unit 2.
During normal operation of the Reactor Recirculation System, these valves are closed.
Therefore cutting and capping the line downstream of these valves has no effect on the ability of the Reactor Recirculation System to perform as designed. These valves and line are only used to drain the A Recirculation line for maintenance of the A Recirculation pump or for other purposes such as chemical decontamination when the reactor is shutdown for refueling and/or maintenance. The design safety margins for the Reactor Recirculation System are maintained with this line cut and capped.                                         ,
The configuration of the piping remains unchanged for structural design purposes, the        -
material downstream of the valves up to and including the cap was upgraded with material     t suitable for reactor coolant system temperature and pressure, the function of the valves to  ,
isolate the reactor coolant pressure boundary remains unchanged.
r b
i i
i 18                                               l
                                                                                                )
I

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:         EER 92-0048, Unit 1 - Use of Fire Protection Water for Battery Testing BRIEF DESCRIPTION:
EER 92-0048 evaluates the feasibility of temporarily asing the fire protection system to supply cooling water to the Hi-Rate Discharge (HRD) test used for capacity testing of plant battery / chargers.

==SUMMARY==
OF THE SAFETY EVALUATION:
EER 92-0048 reviewed the flow rates needed under worst case conditions to cool the HRD tester, minimum flow rates and pressure required for fire protection system operability, the amount of water required during each capacity test, and the volume of water available in the fire protection storage tank. Based on this review, it was concluded that the use of the teniporary fire protection connection will not adversely affect previous FSAR evaluations, nor willit result in adverse operating conditions for the fire protection system i since Technical Specification water levels are maintained and the hose station used for the temporary connection remains operable. The use of fire protection water at the hose station does not prevent use of the station for fire fighting efforts. Consequently, this     l change: (1) does not increase the probability or consequences of an accident previously       .
evaluated in the FSAR, (2) does not create the possibility of a new or different type of accident than previously evaluated in the FSAR, and (3) does not reduce the margin of         !
safety as defined in the basis of any Technical Specification.                                l O
i 5
l l
19 i

i l
CHANGE TO FACILITY AS DESCRIBED IN THE FSAR                                 ,
i TITLE:       EER 92-065, Unit 1 and Unit 2 - Suppression Pool Oxygen increase During RCIC Operation                                                                      >
BRIEF DESCRIPTION:
This EER evaluates temporarily enabling the vacuum pump and closing the E51-F002 valve to prevent addition of oxygen into the suppression pool. This change was implemented in order to satisfy the actions requested by NRC Generic Letter 84-09. It also evaluates temporarily enabling the RCIC Vacuum Pump to improve RCIC reliability, using the installed vent line on the Barometric Condenser Vacuum Tank to meet the vendor recommendation intended to minimize subsequent corrosion of the control system linkage assembly.

==SUMMARY==
OF THE SAFETY EVALUATION:
This EER allows continued RCIC operation with the vacuum pump enabled following transient responses and pressure control using the previously installed vent line. The GE design does not take credit for the gland exhaust systems, thus spurious actuation of the steak leak detection equipment will not occur due to the increased steam leakage associated with no vacuum pump operation. The vent line installation will help maintain operability of the control valves and meet the intent of the vendor recommendation for           ,
drain lines from the control valves to be connected to less than or equal to atrnospheric pressure.
i RCIC inadvertent injection is an analyzed event; enabling the vacuum pump and routing its        +
discharge to the -17 f t. level will have no potential for increasing the probability of this   o event. Enabling the RCIC Vacuum Pump willimprove RCIC reliability. This temporary -                ,
change will assure compliance with vendor recommendations for control valve leakoff                l provisions as needed to avoid corrosion of the control system linkage assembly.                   J Consequently, RCIC will be available as assumed to mitigate the consequences of an event and perform its Technical Specification function.
l 20

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TIT _LE:      EER 92-0076, Unit 1 and Unit 2 - Raising Discharge Temperature Switch Setpoints for Joy Compressors BRIEF DESCRIPTION:
This change raises the setpoints of the Joy compressor discharge temperature switches,           -
both alarm and tnp. The change is necessary to prevent unnecessary trips while the               -
compressors are operating at or near full load.

==SUMMARY==
OF THE SAFETY EVALUATION:
This change increases the reliability of the Joy standby service / instrument air compressors.
Prior to this charige, if the compressors were operating at or near full load, the discharge temperature could reach the trip setpoint without any associated malfunction as the cause.       i if the baseload "D" compressor was out of service, a trip of one or more Joy compressors         i could cause a loss of pressure in the instrument air system, thus causing a scram.
This change increases the reliability of the plant compressed air supply system.
Consequently, this change has no negative effect on plant safety. The change is temporary and will be made permanent via plant modification in the future.                       ;
l
                                                                                                   ?
21

I CHANGE TO FACILITY AS DESCRIBED IN THE FSAR                             1 i
I TITLE:       EER 92-0090, Unit 1 and Unit 2 - Turbine Building Power Roof Ventilator Temporary Blank-Off                                                              !
BRIEF DESCRIPTION:                                                                           ,
EER 92-0090 evaluated the feasibility of temporarily installing blank-offs on the Unit 1 and ,
Unit 2 turbine building power roof ventilators (PRVs).

==SUMMARY==
OF THE SAFETY EVALUATION:
The turbine building HVAC system is a non-safety system. The turbine building PRVs           1 were originally part of a summer ventilation mode for the turbine building which operated automatically for cooling purposes. When the turbine building ventilation was changed frorn a once-through system to the current recirculation system, the purpose of the PRVs became heat and smoke removalin the event of a fire. Sealing the PRVs eliminates a potentially unmonitored release path and assists the HVAC system in developing the           >
required building negative pressure. No credit for the PRVs is taken in the Fire Protection  ,
Plan. Consequently, this change: (1) does not increase the probability or consequences of an accident previously evaluated in the FSAR, (2) does not create the possibility of a new or different type of accident than previously evaluated in the FSAR, and (3) does not .      ,
reduce the margin of safety as defined in the basis of any Technical Specification.
b i
l l
l 22

                    ' CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 92-0186, Unit 1 and Unit 2 - Permanent Repair of Turbine Building Cooling Tower BRIEF DESCRIPTION:
This engineering evaluation evaluates repair of the turbine building HVAC cooling tower structural problems which were discovered during maintenance of the tower.
This change involves substitution of alternate tower truss attachment components (tie down straps) for corroded anchor attachments on the Turbine Building HVAC Cooling Towers, and installation of an additional treated wooden member to provide for complete embedment of the torque tube to tower attachment bolts for the purpose of structural integrity.

==SUMMARY==
OF THE SAFETY EVALUATION:
The cooling towers only support cooling for the turbine building chillers which are non-safety-related. The cooling towers are located in the North yard and are non-seismic, non-EO, and non-fire protection qualified. The repair does not create a new accident initiator.
No credit is taken for turbine building cooling as an accident mitigator. The cooling tower is not safety-related equipment and is not located near safety-related equipment. No credit is taken for turbine building cooling as a safety-related equipment operability parameter.
Since secondary structures have been evaluated for accident scenarios, this design does not create a new accident type. The towers are not included as part of the margin of safety of the Technical Specifications.
23

r-CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE;       EER 92-0261, Unit 1 and Unit 2 - Standby Gas Treatment System Heat Detection Circuit Fuse Assessment BRIEF DESCRIPTION:
This EER was written to determine the size, type, and manuf acturer for the fuses to be used in the SBGTS Heat Detection circuits for all four trains. There are two fuses in each train, one in the positive leg and one in the negative leg of the 125 VDC power source.

==SUMMARY==
OF THE SAFETY EVALUATION:
This EER analyzed the characteristics of the SBGT heat detecuon circuit and determined that the existing Bussmann NON-10 fuse has adequate voltage and interrupting ratings for the DC system supplying the control power and has acceptable amperage rating and time current characteristics to ensure that the fuse will not spuriously open during normal operation of the circuit.
1 24

E CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 92-0300, Unit 1 - Control of Reactor Building Static Pressure                 ;
EER 92-0228, Unit 2 - Lontrol of Reactor Building Static Pressure                 ,
BRIEF DESCRIPTION:
This EER evaluates disconnection of the differential pressure controller (PDC) output from the exhaust vortex damper operators and reconnection of the PDC to the supply fan vortex damper operators to throttle the supply air to create the air flow differential necessary to   '
develop Unit 1 and Unit 2 Reactor Building negative pressure.

==SUMMARY==
OF THE SAFETY EVALUATION:
The FSAR states that airflow patterns are designed to confine potential airborne contamination to their source and from which they will be rernoved by exhaust ductwork.
In general, the ventilation design ensures air movement from clean areas to areas with progressively greater contamination potential.
The negative pressure control will be removed from the exhaust fan vortex dampers and applied to the supply fan vortex dampers. This will ensure that the supply air volume will be maintained less than that of exhaunt, thus minimizing the potential of the building going positive. Maintaining the building negative will also ensure that releases to the atmosphere ,
are monitored. Altering the building pressure control to the supply side of the system will not increase the probability of occurrence of a previously evaluated _ accident. By maintaining effective control of the building negative pressure, the activity does not       i increase the consequences of an accident previously evaluated. The proposed activity helps decrease the probability of occurrence of a malfunction of equipment important to        ,
safety by helping maintain ambient temperature conditions for plant equipment.
Effectively maintaining the reactor building at negative pressure does not increase the consequence of a malfunction of equipment important to safety. As the system is designed to maintain a building negative pressure, altering the control to the supply side   '
still maintains a negative condition which does not create a different type of accident or create the possibility of equipment malfunction different than that previously evaluated.    .
The proposed change does not alter components that would reduce the margin of safety.
4 4
25

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:      EER 92-0305, Unit 2 - RHR "B" Temporary Flow / Pressure Instruments BRIEF DESCRIPTION:                                                                          l 1
The Unit 2 Instrument Rack upr,rade project replaces Instrument Racks PO21 on the .-17' Elevation of the Reactor BuilcCng. This EER evaluates a temporary change which provides for temporary instrumentation to be in place prior to the removal from service of the instruments on the rack. This temporary instrumentation will give flow indication in the   ,
control room and a local pressure gauge for reading the combined RHR "B" Pumps discharge pressure.

==SUMMARY==
OF THE SAFETY EVALUATION:
The temporary flow indication loops will not provide any control but will be used by the operators in performing other control functions. The RHR pumps are used to maintain cold shutdown and the flow indication is necessary to the operator in maintaining normal operating limits for the RHR System. The local pressure gauge provides additional          .
information regarding the performance of the RHR pumps and for maintaining RHR-SW pressure greater than the RHR pressure to limit the consequences of a heat exchanger tube leak.
The mounting of the transducers and the temporary power supply have been reviewed and evaluated as adequate. The RHR loop shall be used for the Shut Down Cooling (SDC)          '
mode only, while the temporary instruments are installed. This will cause the LPCI to be inoperable and therefore there are no seismic constraints on the system. Consistent with current plant philosophy, an alternate mode of decay heat removal shall be maintained, and the plant operators will ensure this as a part of routine operation.
The ultrasonic flowmeter is a state of the art system that is designed for permanent duty service. The +/- 5% accuracy is adequate for this short term service to ensure the system operates within normal operational limits.                                          ,
1 I
26                                           l

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 92 0370 and EER 92-0371, Unit 1 RHR "A" & Unit 1 RHR "B" Temporary Flow / Pressure Instruments BRIEF DESCRIPTION:
The Unit 1 instrument Rack upgrade project is intending to replace Instrument Racks PO21 and PO18 on the -17' Elevation of the Reactor Building. Prior to removing the instruments from service, Operations requested that temporary instrumentation be in place giving Flow indication in the control room and local pressure gauge for reading the combined RHR "B"      -
and RHR "A" Pumps discharge pressure.

==SUMMARY==
OF THE SAFETY EVALUATIONi The temporary flow indication loops will not provide any control but will be used by the operators in performing other control functions. The RHR pumps are used to maintain cold shutdown and the flow indication is necessary to the operator in maintaining norrnal operating limits for the RHR System. The local pressure gauges provide additional information regarding the performance of the RHR pumps and for maintaining RHR-SW pressure greater than the RHR pressure to limit the consequences of a heat exchanger tube leak.-
The mounting of the transducers and the temporary power supplies have been reviewed and evaluated as quite adequate. The RHR loops should be used for the Shut Down Cooling (SDC) mode only while the temporary instruments are installed, this will cause the LPCI to be inoperable and therefore there are no seismic constraints on the system.
Consistent with current plant philosophy an alternate mode of decay heat removal should       {
be maintained, and the plant operators will ensure this as a part of routine operation.        :
J I
The ultrasonic flowmeters are state of the art systems that are designed for permanent duty service. The + /- 5% accuracy is considered adequate for this short term service to ensure the systems operate within normal operational limits.
I i
i 27

CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:      EER 92-0387, Unit 1 and Unit 2 - Radwaste HVAC Abnormal Fan Lineups BRIEF DESCRIPTION:
The purpose of the plant HVAC systems is to maintain areas of the plant at temperature conditions which provide optimum operation of equipment and comfort and safety of personnel, and to limit the spread of contamination during power operation and shutdown operation of the plant.

==SUMMARY==
OF THE SAFETY EVALUATION:
The abnormal f an lineups described will not affect the performance of plant safety systems and will maintain a building negative static pressure; which will ensure that potentially contaminated air is filtered and monitored before being released to atmosphere, and provide for partial heat removal from the building. Therefore, operating two exhaust f ans and one supply fan is an acceptable lineup for continuous operation and operating one exhaust f an and no sup,'ly tan is acceptable provided pump areas are monitored for temperature.
28

I i
CHANGE TO FACILITY AS DESCRIBED IN THE FSAR                                i TITLE:       EER 92-0392, Unit 1 - Temporary Alternate Reactor Level Alarm installed Due to Work on PM 89-001 BRIEF DESCRIPTION:
This EER evaluates a temporary modification to convert the 9-10 contacts of E51-K52 to         ,
normally closed in order to make the A21-4 annunciator useful to Operations personnel in avoiding an undesirable low level transient. Additionally, the window for A21-4 was replaced with one reading RX WTG LVL BELOW 200".                                               l

==SUMMARY==
OF THE SAFETY EVALUATION:
This temporary modification provides for a temporary alternate alarm to help prevent undesirable level transients during removal from service of Unit 1 feedwater control per-Plant Modification 89-001, Feedwater Level Control Modification. The condition was temporary with the Unit 1 vessel in cold shutdown. The normal minimum vessel water level of 200" provides a margin above the level where the LL1 instrumentation would actuate, approximately 166". With the changed configuration resulting from this temporary modification, the annunciator would alarm at 195" and reset at 196" With the revised window, this will assist Operations personnel in avoiding an unwanted low level transient. This condition is temporary and the normal configuration will be restored prior to needing the normal function of the affected equipment.                                      .
This EER only affects RCIC while it is in a condition where it is not required to be operable or where it cannot mitigate an event. RCIC will be restored to normal configuration prior       ,
to the plant being in a conditior; where RCIC is required. This EER will not affect any         ,
assumed initial conditions with regard to evaluated malfunctions of equipment. Changing         ,
the function of this annunciator has no potential for causing any condition that would        ''
initiate an event.
i l
1 29

             . - . . .   .                  -           ~-     --
l CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:         EER 92-0406, Ermrgency Substation Tie Breaker Undervoltage Trip Device Removal BRIEF DESCRIPTION:                                                                                    1 l
The BSEP Emergency Substation ITE type K1600 tie breakers were being refurbished by                  l BBC when it was discovered that they were equipped with DC control power undervoltage                 i trip devices. Replacing the existing DC undervoltage trip devices would have delayed delivery of the refurbished breakers unless CP&L approved removal of the existing devices            ,
from the tie breakers.                                                                               :

==SUMMARY==
OF THE SAFETY EVALUATION:                                                                    .
Specification 9527-01-145-3, Revision 4 gives no indication that the DC control power                l undervoltage trip devices were specified for the BSEP Emergency Substation electrically operated breakers, even though it was an option available on K-Line breakers. In the case           1 of Emergency Substation t';e breakers, it is not desirable to maintain this feature because          ,
during a Station Blackout scenario, when these breakers would be used to " cross-tie" Emergency Substations, it would defeat the one remaining source of AC power to                       ;
equipment needed to maintain the plant in a safe shutdown condition.
                                                                                                    ?
b i
                                                                                                    +
                                                                                                     ?
i b
t 30                                                     !

l l
l l
i CHANGE TO FACILITY AS DESCRIBED IN THE FSAR                                 )
TITLE:        EER 92-0534, Unit 1 - Temporary Modification for Equalization of                   )
1-SA-PDIS-4489                                                                    ;
BRIEF DESCRIPTION:
This temporary modification will disable the alarm for pressure switch 1-SA-PDIS-4489 in order to clear a nuisance annunciator in the Control Room. This switch monitors pressure        ;
across the Service Air Dryer. Other alarms for monitoring / alarm initiation will not be affected.

==SUMMARY==
OF THE SAFETY EVALUATION:
Differential pressure switch 1-SA-PDIS-4489 has a setpoint of 2 psid, but with normal flow through the Service Air Dryer, the switch sees a differential pressure of about 3.4 psid. Although this valve had been valved out per shift supervisor clearance for about a two year period, lif ting of such clearance created a condition whereby the exposure of the switch to the relatively constant DP of 3.4 resulted in the switch remaining in the alarm state af ter the clearance was lifted.
Other Control Room indication will be used to alert the operators of possible service air dryer or system problems (such as temperature and level monitoring / annunciation for the dryer, Joy air compressor auto start, low service air pressure alarm, or low instrument air pressure alarm) while this temporary modification is in place. This temporary modification will not contribute to the reduced reliability of the service and instrument air systems for    >
the plant, or impact accident likelihood. Service and instrument air systems are not safety-related, they are not addressed by the Technical Specifications, and no credit for their operation is assumed during evaluated accidents. Loss of instrument and service air are bounded by existing safety analyses. Eliminating alarm initiation based on service air dryer DP will not reduce the previously analyzed safety margin.
i j
31
                                                                                                )

I CHANGE TO FACILITY AS DESCRIBED IN THE FSAR TITLE:       EER 92-0566, installation of Temporary Potable Water Supply                          i BRIEF DESCRIPTION:
This EER evaluates installation of a temporary jumper to provide a method of temporarily          !
maintaining the potable water supply to the Brunswick Nuclear Plant by connecting a tank          ;
truck and portable pump to the station water supply.
                                                                                                  ~
i

==SUMMARY==
OF THE SAFETY EVALUATION:
* The potable water system provides and distributes water for drinking and sanitary uses;           ;
however, it is a non-safety-related system and provides no function important to safety.
The temporary jumper installation involved in this change makes no permanent modification to the existing piping system and/or flow path. The installation of the jumper provides a method of temporarily maintaining the potable water supply by connecting a             :
tank truck via an existing flanged tee for the old pH-meter downstream of Valve 2-PWT-V4         1 and using the existing piping. The tank truck is certified as to cleanliness and acceptability    j for storage of potable water. Additionally, the truck is charged with a chlorine solution,        ,
and the charge is maintained for a 24 hour period prior to use, for bacterial control. This       '
will ensure that no contaminants are introduced into the system. This tempt try                   -
arrangement is only for use during such time periods that the county water supply is out of service for repairs. The installation of the jumper is acceptable because of: (1) the non-safety-related status of the potable water system, (2) the non-modifying effect of the            j jumper installation, and (3) the protection against the introduction of contaminants into the system.
I I
32
                                                                                                  )

CHANGE TO PROCEDURE AS DESCRIBED IN THE FSAR TITLE:       0-OP-37.2, Radwaste Building Heating and Ventilation System Operating Procedure BRIEF DESCRIPTION:
A change to the procedure was performed to allow operation of different combinations of ventilation fans to maintain a negative pressure in the radwaste building. This change will not affect the performance of the plant safety systems.

==SUMMARY==
OF THE SAFETY EVALUATION:
The abnormal fan lineups resulting from this procedure change will not affect the performance of plant safety systems and will maintain a building negative static pressure, which will ensure that potentially contaminated air is filtered and monitored before being released to atmosphere, and provide for partial heat removal from the building. Therefore, operating two exhaust hans and one supply fan is an acceptable lineup for continuous operation and operating one exhaust fan and no supply fan is acceptable provided pump areas are monitored for temperature.
B i
f 33 i

CHANGE TO PROCEDURE AS DESCRIBED IN THE FSAR TITLE:        0-SP-92-003, Operations Support for OM-6 Qualification of Service Water Pumps BRIEF DESCRIPTION:                                                                             f This special procedure provides the prerequisites, precautions, limitations, and instructional [
guidance for operation of the service water system to support performance of sections of       ,
Special Procedure 0-SP-91-092, OM-6 " Qualifying of Service. Water Pumps." The purpose         i of Special Procedure 0-SP-91-092 is to acquire the necessa y data to quantify the amount of resonance vibration for the service water pumps. This w'll allow calculation of correct allowable values for vibration limits in implementing vibration monitoring of the pumps.

==SUMMARY==
OF THE SAFETY EVALUATION:
This special procedure operates the Service Water System in the same general method as Operating Procedure OP-43. The SW headers are left aligned to their normal supply source, pumps are started and stopped in the same way, and RBCCW and TBCCW flows               i are lef t at their normal flow rates. RHR-SW loops are started up to allow a convenient        ,
method of varying service water header flow rates for testing. However, the test does          !
place the system in various configurations as far as number of pumps and flowrates which       ,
are unusual. This varying system configuration is discussed in the safety analysis for         l Special Procedure 0-SP-91-092 and sufficient precautions and limitations are taken to          :
assure no safety concerns exist. Therefore, the proposed performance of this procedure         i will not place the plant in an unsafe plant position and no unreviewed safety question exists.                                                                                        ,
i 7
e s
9 h
_3 I
34

l TEST OR EXPERIMENT NOT DESCRIBED IN THE FSAR TITLE:        OSP-91-011, Testing instrument Air Dewpoint                                     ]
i i
BRIEF DESCRIPTION:                                                                            i i
J This procedure involves temporarily placing a hygrometer and chart recorder downstream of service and instrument air dryers to determine their performance over time.                 l

==SUMMARY==
OF THE SAFETY EVALUATION:                                                             ,
1 The proposed activity tests the instrument air system dowpoint at various places in the-
* instrument air system in order to determine the performance of the instrument and service      i air dryers. The dryers performance (dewpoint) will be plotted against time for several        ,
cycles to ensure the instrument air is being dried to an acceptable level. The presence of moisture in the instrument air system has a negative impact on reliability and maintenance    ,
of components served by the instrument air, and no quantitative method existed prior to this test method to check their performance. Simpiing alone does not give a complete picture of the dryer performance as the dewpoint varies considerably over the dryer cycle, and it is difficult to determine where in the cycle th9 dryer is at any given time point.
The proposed activity does not change the operating conditions of the plant. _ The test draws an insignificant amount of air from the instrume
* air system which will not cause an adverse effect on the operating plant. This procedt.re does not have a significant effect' ,
on the instrument air system, which is not safety related. Therefore, the consequences of an accident evaluated previously in the S fety Analysis Report has not been increased.
I i
1 i
35

f TEST OR EXPERIMENT NOT DESCRIBED IN THE FSAR TITLE:       OSP 91-092, OM-6 Service Water Pump Vibration ~ Testing BRIEF DESCRIPTION:
This procedure provides instructions and guidance in acquiring the necessary data to quantify the amount of resonance vibration being exhibited in the Unit 1 and 2 nuclear and conventional service water pump assemblies. The implementation of the testing will place the service water pumps in operational configurations which deviate from normal operation as described in FSAR Section 9.2.1.

==SUMMARY==
OF THE SAFETY EVALUATION:
The implementation and performance of this procedure will require the Unit 1 and 2 nuclear and conventional service water pumps to be operated in various configurations and alignments to record anticipated changes in pump vibration responses. Although both units' service water systems are affected, each unit's system will remain completely independent while providing flow to essential plant equipment. Although the performance of this special procedure will place the service water pumps in abnormar operating configurations, the automatic designed safety features of the system will not be defeated.
The safety evaluation determined that the probability of increase of safety-related equipment damage / failure is small relative to the uncertainties. Therefore, the proposed performance of this procedure will not place the plant in an unsafe plant condition.
l l
I i
36 1
l f
v-

l TEST OR EXPERIMENT NOT DESCRIBED IN THE FSAR TITLE:       2-SP-92-039, Unit 2 - Test of ClamTrol for Macrofouling Control in Circulating Water System BRIEF DESCRIPTION:                                                                            )
This specific procedure provides for injection and evaluation of effectiveness of Betz        l ClamTrol chemical for macrofouling control in the Circulating Water System. The               l procedure covers the following actions: placement and removal of concrete test substrates     !
in the circulating water system, injection of ClamTrol on a periodic basis, including circulating water sample during injection, and inspection of circulating water system following specified ClamTrol injections.                                                      1

==SUMMARY==
OF THE SAFETY EVALUATION:
The ClamTrol is being tested as a substitute for chlorination for macrofouling control. The   ;
chlorination process for the Unit 2 Circulating Water System will be terminated during the performance of this procedure. The product has been used by other nuclear plants in similar applications. The design and installation of ClamTrol injector assemblies and plant   i sample points were evaluated under PM 91-044 and no unreviewed safety questions were          ,
identified. Internalinspections and cleaning of the circulating water system is a normal      )
plant maintenance function, and presents no new safety concerns.
I 37

Enclosure 2 List of Regulatory Commitments The following table identifies those actions committed to by Carolina Power & Light Company in this document. Any other actions discussed in the submittal represent               ,
intended or planned actions by Carolina Power & Light Company. They are described to      .j the NRC for the NRC's information and are not regulatory commitments. Please notify the        l Manager-Regulatory Affairs at the Brunswick Nuclear Plant of any questions regarding this    l document or any associated regulatory commitments.
Committed Commitment .                                 date or       ,~
outage
: 1. NONE                                                                                ,
                                                                                             -i
: 2.                                                                                        r
: 3.
* i i
t
                           ~
3 1
l
                                                                                               )
                                                                                              }}}