ML20058J079

Responds to NRC Station Blackout Safety Evaluation. Implementation of Required Hardware Mods & Related Procedure Changes Will Be Completed by 921017 for Both Units

ML20058J079
Person / Time
Site:	Brunswick
Issue date:	11/15/1990
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-90-231, TAC-68520, TAC-68521, NUDOCS 9011270213
Download: ML20058J079 (4)

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1 Carolina Power & Light Company  !

P.O. Box 1551 e Raioigh. N.C. 27002 1 l

SERIAL: NLS-90 231 NOV 151990 10 CFR 50.63  !

O. E. VAUOHN Wee President Nuclear Serv 6cae Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk .I Washington, DC 20555

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i- 3 BRUNSWICK STEAM ELECTRIC PIANT, UNIT NOS.1 AND 2 - }'

DOCKET NOS. 50 325 & 50 374/ LICENSE NOS DPR 716 DPR-62 RESPONSE TO NRC STATION BLACK 0UT SAFETY EVALUATION  !

(NRC TAC NOS. 68520 ANDL68S21) l t

References:

1. CP&L Letter from M. A. M*Duffic to the Document Control Desk of the U, S. Nuclear kegulatory Commission, dated March 3, 1989. 4 Y

2. CP&L Letter from A. B Cutter to the Document Control Desk of s the U. S. Nuclear Regulatory Commission, dated October 10, 1989.

3. CP&L Letter from A. B Cutter to the Document Control Dask of the U. S. Nuclear Regulatory Commission, dated March 30,-

1990. ,

Centlemen:

U In a letter dated October 4,;1990, the NRC provided the Safety Evaluation (SE)- i regarding the Station' Blackout (SBO) Rule (10 CFR 50.63) as applicable to the i

, Brunswick Steam Electric Plant, and the associated Technical Evaluation Report

 !(TER) performed by SAIC. The NRC-letter also contained five (5)  !

, recommendations and requested confirmation that the Staff recommendations would.be implemented.

s CP&L concurs with those recommendations with minor i excepti_ons noted in Enclosure 1, which provides JP&L's responses to each of  !

the: Staff's recommendations.

~As a result of our preliminary review,' some inaccuracies were identified in  !

the:SAIC evaluation. Certain values from CP&L's evaluation were incorrectly used-in the SAIC ovaluation. In addition, some assumptions used by SAIC were (

beyond SBO, criteria. The Company will identify those discrepancies in the SB0 supporting'ocumentation..

d Our preliminary determination is that these .l discrepancies would not alter the conclusions of the SAIC evaluation and the

• Staff!s Safety Evaluation. (

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-The Company plans to complete the required SB0 modifications during the t Brunswick-1 Reload 8 outage, currently scheduled to begin in April 1992 and during the Brunswick-2 Reload 9 outage, currently scheduled to begin in September 1991. The NRC SE on Station Blackout for the Brunswick Plant was 3

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received by;CP&L on October. 17,-1990._. Therefore, in accordance *.th- _

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, '10 CFR 50.63(c)(4)~,11mplementation of required hardware modificottons and the Tcg -

Lrelated procedure changes will be completed by Catober 17,:1992 for both sp units! l a :, i , ; .

Plen'se refer'any questions regarding this submittal to Mr. M. R. Oates at- y l(919):c546 6063, s .;

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Yours very truly,-

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Enclosuro:

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I FNCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50 325 6 50 324 OPERATING LICENSES DPR-71 6 DPR-62 RESPONSE TO NRC STATION BLACKOUT SAFETY EVALUATION (NRC TAC NOS. 68520 AND 68521) j 1

Staff Recommendation 1

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A test of the operability of the 4kV and 480 V cross tie circuits under SB0 l conditions should be performed to ensure that the AAC source meets the I guidelines of NUMARC 87-00, Appendix B, Item B.12.

j CP&L Resoonse

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CP6L will demonstrate the operability of the AAC cross tie circuits to ensure compliance with Appenoix B, Item B.12 of NUMARC 87-00 by perform!ng an operability test of the breaker modifications as they are installed on each unit and performing a timod test of the SB0 Cross Connection Procedures under ,j simulated SB0 conditions. This is consistent with CP&L's original commitment; -i y and is as described in the Technical Evaluation Report prepared by SAIC.

Staff Recommendation 2 i

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The licensee should verify that the assumptions in the loss of coolant accident (LOCA) analysis are consistent with those of the SB0 scenario for j ~

containment areas. If the licensee's verification shows that additional

. procedure changes or hardware modifications are necessary to ensure equipment-operability in the above areas, then the licensee should implement the j

required procedure changes and/or modifications as necessary to ensure a equipment operability. In addition, the licensee should (1) establish i procedural controls to monitor the control room and switchgear room- j

. temperatures and to open the cabinet doors in the control room and the 'I switchgear room within 30 minutes from the onset of SB0 to provide-adequate l air mixing to maintain cabinet temperatures within equipment operable limits j or (2) assess the equipment in the switchgear' rooms to determine its j operability for th. temperatures expected in these rooms. This verification 1

-and:any'resulting modifications should be included in the documentation "

supporting the SB0 submittals that is to be maintained by the licensee. l l CP&L Resnonse The Company will verify that the assumptions-in the LOCA analysis are consistent with those of the SB0 scenario and take appropriate actions.

CP&L does not intend to establish procedural controls to monitor the control room and :switchgear room temperatures. This is not identified in NUMARC 87 00 as a recommended action and would add unnecessarily to operator actions. In '

the- event llVAC,is not available to the control room complex, action will be taken by procedure to open the SB0 related cabinet doors in that complex 1

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, within 30 minutes of the loss of !!VAC per guidance provided in NUHARC 87 00 Supplemental Questions / Answers.

The Staff recommendation provides two options for resolution of the EDC switchgear room loss of HVAC concerns. CP&L will use the second option by assessing reasonable assurance of the operability of SB0 response equipment using the methodology contained in Appendix F of NUKARC 87 00. The results of this assessment will be included 8.n the SB0 supporting documentation.

Staf f Recoset ndation 3 The licensee should verify that the rise in suppression pool level (see TER) "

will riot affect the operation of the itPCI and RCIC syste.ac an' include this verification in the documentation supporting the SB0 submittals that is 'o be maintained by the licensee.

GI&t Responig s' The Company will perform the requested verification and include the result in the SB0 supporting documentation.

Staff Recommendation f The licensee should include a full description, including the nature and objectives, of the required modifications identified above (see page 8 of the NRC Safety Evaluation for SB0 dated October 4,1990, Section 2.5, Proposed Modifications) in the documentation supportin6 the SB0 submittals that is to be maintained by the licensee.

CP&L Response The recommended description will be maintained with the applicable modification package and the existing design control process will ensure I continued compliance with the 10 CPR 50.63.

Slaff Recommendation 5 The licensee should provide confirmation and include in the documentation supporting the SB0 submittals that is to be maintained by the licensee that such a program (i.e., EDG Reliability Program) meeting the guidance of RG 1.155, Position 1.2, is in place or will be implemented.

CP&L Respeggg CP&L will establish an EDG Reliability Program which meets the guidance of Regulatory cuide 1.155, Position 1.2 in accordance with Appendix D of NUMARC 87 00.

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