ML20085L065
| ML20085L065 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/17/1983 |
| From: | Howe P CAROLINA POWER & LIGHT CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20085L068 | List: |
| References | |
| LAP-83-456, NUDOCS 8310210264 | |
| Download: ML20085L065 (15) | |
Text
h Cp&L m
A, Carolina Power & Light Company SERIAL: LAP-83-456 j.
OCT 171983 t
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Director of Nuclear Reactor Regulation Attention:
Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 f
Division of Licensing United States Fuclear Regulatory Commission Washington, DC 20555 BRUNSk'ICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324
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LICENSE NOS. DPR-71 AND DPR-62 l
SUPPLEMENTAL REOUEST FOR LICENSE AMENDMENT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS
Dear Mr. Vassallo:
SUMMARY
In.accordance with the Code of Federal Regulations, Title 10, Part 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests revisions to the Technical Specifications (TS) for the Brunswick Steam Electric Plant, Unit Nos. I and 2.
These revisions supersede the proposed TS pages provided in our December 13,'1982 request concerning Radiological Effluent Technical Specifications (RETS).
Discussion By letter dated May 31, 1979, CP&L submitted proposed TS revisions to incorporate RETS into the Appendix "A" Technical Specifications for the Brunswick Plant.
Subsequently, by-letter dated December 13, 1982, CP&L submitted supplemental proposed TS revisions that superseded those TS provided in the May 31, 1979 request.
-Since submittal of our December 13, 1982 request, CP&L has continued
.to review the. proposed RETS while initiating efforts for the identification,
- development, and implementation of new or revised plant procedures needed to support RETS implementation. This review effort has identified several editorial and technical revisions that are needed to our December 13, 1982 submittal. Justifications ' for the major technical changes which are included in this submittal are provided in Enclosure 1.
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D. B. Vassallo Due to the size and complexity of the proposed RETS document, CP&L has chosen to resubmit the entire RETS document (less the Administrative Controls section as discussed below). However, to assist your staff in reviewing the revised document and determining where revisions have been made, a list is provided (Enclosure 2) which summarizes the status of each proposed RETS page.
Our December 13, 1982 submittal referenced a number of CP&L license
' amendment requests that were under NRC review at the time and which were incorporated in the proposed RETS. Due to the length of time that the RETS have been under. Staff review, several license amendments have been issued and are therefore reflected in the enclosed RETS document.
- By letter dated December 10, 1982, CP&L submitted proposed revisions concerning the Administrative Controls section of the Brunswick TS.
These proposed TS formed the basis on which the RETS Administrative Controls requirements were developed and submitted. The Administrative Controls TS revisions submitted by our December 10, 1982 request are still under review by 4
your staff. CP&L plans to-submit a revised Administrative Controls TS package for ~ the Brunswick Plant in the near future; however, it is not clear whether l
your-staff will be prepared to review, approve, and issue those TS revisions in time to support issuance of the proposed RETS (including the RETS-related i
Administrative Controls section). Due to these circumstances, CP&L has not J
included RETS-related Administrative Controls requirements in the enclosed
. revised RETS document and instead plans to submit RETS-related Administrative Controls TS revisions in the upcoming Administrative Controls submittal.
i ADMINISTRATIVE INFORMATION The. revised Brunswick-1 RETS are provided in Enclosure 3, and the revised Brunswick-2 RETS are provided in Enclosure-4. The'pages with the RETS-related revisions have the changes indicated by vertical lines in the right-hand margins.
Since this request is a supplement to our December 13, 1982 and May 31, 1979 submittals, CP&L has determined that no license amendment application fee is required.
IMPLEMENTATION SCHEDULE Since the submittal of our December 13, 1982 request, CP&L has been proceeding with the preparation of new procedures and the revision of existing procedures necessary to support implementation of the RETS. The scope of this implementation effort has included such items as the resolution of over 180 procedures and action items, computerization of the Offsite Dose Calculation Manual (CDCM), at least 3 man-years of procedure development (not including e
typing, administrative review, or training time), and extensive personnel training.
f
D. B. Vassallo In our December 13, 1982 RETS submittal, CP&L requested that the NRC promptly review, approve, and issue the RETS in order to support CP&L's scheduled implementation of the RETS by January 1, 1984. The January 1, 1984 date represents the most feasible date for implementing the RETS, and our efforts continue to be towards achieving this goal. Because the approval, issuance, and implementation of the RETS are viewed by CP&L as an important part of our continuing efforts to improve the quality of operations at the Brunswick Plant, we request that the NRC make every effort to assure that the RETS are issued in a timely manner in order to support the scheduled January 1,1984 implementation date.
If you have any questions concerning this submittal, please contact our staff.
Yours very truly, b,
P. W. Howe Vice President Brunswick Nuclear Project WRM/ccc (8041WRM)
Enclosures cc:
Mr. Dayne H. Brown Radiation Protection Branch Division of Facility Services Department of Human Resources Mr. D. O. Myers (NRC-BSEP)
Mr. J. P. O'Reilly (NRC-RII)
Mr. S. D. MacKay (NRC)
P. W. Howe, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.
Mttt ak-L Notary (Seal)
My commission expires: 1 - 3 3 5T a
ENCLOSURE 1 JUSTIFICATIONS FOR PROPOSED RETS CHANGES BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2
't ATTACHMENT 1
SUBJECT:
Radioactive Gaseous Effluent Monitoring Instrumentation APPLICABILITY: Brunswick-1 and Brunswick-2
REFERENCE:
TS Table 4.3.5.9-1, Item 5.(a)
PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE: Revise the frequency for a Source Check of the main condenser off-gas treatment system monitor (downstream of the augmented of f-gas ( AOC) treatment system) from "P" (prior to each release) to "M" (at least once per 31 days).
JUSTIFICATION FOR PROPOSED CHANGE: The AOC treatment system is a charcoal absorber delay system and not a waste gas decay tank system. Releases will be made from the A0G system continuously. Therefore, a monthly source check frequency is more logical and consistent than a frequency of prior to each release.
ATTACHMENT 2
SUBJECT:
Redioactive Liquid and Gaseous Effluent Monitoring Instrumentation Surveillance Requirements APPLICABILITY: Brunswick-1 and Brunswick-2
REFERENCE:
TS Table 4.3.5.8-1, footnote (b)
TS Table 4.3.5.9-1, footnote (b)
PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE: Add the statement "Previously established calibration procedures may be substituted for this requirement (refer to Bases 3/4.3.5.x)." to footnote (b) and add an explanatory paragraph to the Bases for TS Sections 3/4.3.5.8 and 3/4.3.5.9.
JUSTIFICATION FOR PROPOSED CHANGE: The above statement is taken from the guidance for this footnote as given in NUREG-0473. This statement was not included in CP&L's original Brunswick RETS submittal (December 13, 1982) due to an oversight. A new paragraph is being added to the Basea to clarify the intent of this footnote for the Brunswick plant staff.
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ATTACHMENT 3
SUBJECT:
Radioactive Gaseous Effluent Monitoring Instrumentation APPLICABILITY: Brunswick-1 and Brunswick-2
REFERENCE:
TS Table 4.3.5.9-1, footnote (c)
PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE: The footnote should have the following statement added:
"The CHANNEL FUNCTIONAL TEST of the channel up to but not including operation of the isolation valve for this pathway shall be performed within the specified surveillance interval. Testing of the isolation valve for this pathway to demonstrate operability shall be performed during the CHANNEL CALIBRATION."
JUSTIFICATION FOR PROPOSED CHANGE: Footnote (c) applies to the quarterly freauency for the channel functional test of the main condenser air ejector radioactivity monitor. This footnote, as written, would require that "the CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway... occurs..." on a quarterly basis. The actual stroking of the valve and isolation of the gaseous effluent pathway can cause a plant transient. Operating experience at Brunswick has demonstrated that transients of this nature trip the turbine and subsequently cause a reactor scram.
A high reading on the radiation monitor starts a 15 minute timer. At the end of tue 15 minutes, if the situation has not been corrected, the isolation valve shuts and effluent flow is diverted to the augmented off gas (ADG) system. It is not likely that the A0G system will accept the diverted flow fast enough to prevent condenser back pressure from causing a turbine trip with subsequent reactor scram. To lessen the severity of the transient, power would have to be significantly reduced during this test resulting in reduced plant capacity. The requirements of footnote (c) as written could unnecessarily stress the reactor system and reduce the plant's overall safety and reliability.
This concern can be eliminated by adopting the proposed change to this l
footnote. The intent of this TS would be met by functionally testing the channel up to shutting the isolation valve on a quarterly basis and by ensuring valve operability on a less frequent basis at times when the plant is in a shutdown condition.
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ATTACHMENT 4
SUBJECT:
Radioactive Gaseous Waste Sampling Analysis Program APPLICABILITY: Brunswick-1 and Brunswick-2
REFERENCE:
TS Table 4.3.5.9-1, footnote (e)
PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE: Change item 1 of footnote (e) to read "Two volume percent hydrogen, balance nitrogen, and" instead of "One volume percent hydrogen, balance nitrogen, and."
JUSTIFICATION FOR PROPOSED CHANGE: This footnote applies to the channel calibration of the hydrogen monitors which are downstream of the off-gas recombiners. In order to protect the augmented off-gas (A0G) system from excessive hydrogen accumulation, these monitors have been designed to provide a high alarm at two percent hydrogen in addition to a high-high alarm at four percent hydrogen. Carolina Power & Light Company proposes to calibrate these monitors at hydrogen concentrations of two percent and four percent (instead of one percent and four percent) so that the channel calibration could also serve as an alarm verification.
ATTACHMENT 5
SUBJECT:
Radioactive Gaseous Waste Sampling and Analysis Program APPLICABILITY: Brunswick-1 and Brunswick-2
REFERENCE:
TS Table 4.11.2-1, footnotes (c) and (g)
PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE:
(1) Add the words " main condenser air ejector" to clarify that the noble gas monitor referred to in the footnote is the main condenser air ejector's monitor; (2) add the statement :
"This footnote does not apply to the Hot Shop environmental release point," and; (3) add a statement to the Bases clarifying the interpretation of "a factor of 3" increase for DOSE EQUIVALENT I-131 concentration in the primary coolant and noble gas activity.
JUSTIFICATION FOR PROPOSED CHANGE: Footnotes (c) and (g) of TS Table 4.11.2-1 apply to the minimum analysis f requency of grab samples, charcoal samples, and particulate samples for the environmental release points. The intent of this sampling and analysis is to ensure that no fuel degradation has occurred due to an operational transient. The proposed changes are needed to clarify the intent of this footnote.
Footnote (g) should not apply to the Hot Shop environmental release point.
The iodine-131 and particulate activity at this release point would not be affected by operational transiects. The weekly sampling frequency for this release' point required in Table 4.11.2-1 should be sufficient for this location in all situations.
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ENCLOSURE 2
SUMMARY
LIST OF RETS REVISIONS BRUNSWICK UNIT NO. 1 PAGE COMMENT Table of Contents:
I Revised to reflect issued amendments II Revised to reflect issued amendments V
Correct typographical error in section title IX Delete page from RETS request IXa Section title (TS 3/4.11.2.3) revised to add reference to I-133 X
XII Delete reference to core spray system Special Test Exception XIIA Section title (TS 3/4.11.2.3) revised to add reference to I-133 XIII XIV Will be revised in future submittal XV Will be revised in future submittal XVI Will be revised in future submittal Definitions:
1-1 1-2 1-3 1-4 Add definitions for ODYN Option A and B 1-5 1-6 1-7 1-8 1-9 1-10 LCO/ Surveillance Requirements:
3/4 3-61 3/4 3-62 3/4 3-63 3/4 3-64 3/4 3-65 Item *** revised to reflect the A0G system becoming operational 3/4 3-66 3/4 3-67 Item (b) revised (refer to Enclosure 1, Attachment 2) 3/4 3-68 Revise page note to refer to Bases 3/4.3.5.9 3/4 3-69 3/4 3-70 Item 6.b title revised from "Recombiner Train A" to "Recombiner Train B" Items (5) and (6) applicabilities revised to reflect the A0G system becoming operational 3/4 3-71 Action 121, item (a) revised to reflect the A0G system becoming operational
PAGE COMMENT 3/4 3-72 Items *** and **** revised to reflect the A0G system becoming operational 3/4 3-73 3/4 3-74 Item 5.a source check requirement revised (refer to Enclosure 1, )
Item 5.a surveillance mode requirement revised to reflect the A0G system becoming operational 3/4 3-75 Item 6 surveillance mode requirements revised to reflect the A0G system becoming operational Footnote (f) reference also deleted 3/4 3-76 Item (b) revised (refer to Enclosure 1, Attachment 2)
Item (c) revised (refer to Enclosure 1, Attachment 3) 3/4 3-77 Item (e).1 revised (refer to Enclosure 1, Attachment 4)
Item (f) deleted Items *** and **** revised to reflect the A0G system becoming operational 3/4 3-78 3/4 3-79 3/4 3-80 3/4 3-81 3/4 4-7
" CONDITION" revised to "0PERATIONAL CONDITION" to conform to the defined term 3/4 4-10
" CONDITION" revised to "0PERATIONAL CONDITION" to conform to the defined term 3/46-6
" CONDITION" revised to " OPERATIONAL CONDITION" to conform to the defined term 3/4 11-1 3/4 11-2 3/4 11-3 Item (e), LLD equation revised 3/4 11-4 Item (e), conversion factor revised 3/4 11-5 3/4 11-6 Item (e), LLD equation revised 3/4 11-7 Item (e), conversion factor revised 3/4 11-8 3/4 11-9 3/4 11-10 3/4 11-11 Add reference to I-133 3/4 11-12 Item B, delete unit references 3/4 11-13 Item (a), LLD equation and conversion factor revised 3/4 11-14 Items (c) and (g) revised (refer to Enclosure 1, Attachment 5) 3/4 11-15 3/4 11-16 Add reference to I-133 3/4 11-17 3/4 11-18 3/4 11-19 Applicability revised to reflect the A0G system becoming operational 3/4 11-20 TS 3.11.2.7, 2nd line:
Insert "or" af ter the phrase "shall be limited to less than" 3/4 11-21 3/4 11-22 3/4 11-23
PAGE COMMENT 3/4 11-24 3/4 12-1 3/4 12-2 3/4 12-3 2nd paragraph: capitalize " site boundary" to conform to the defined term 3/4 12-4 3/4 12-5 3/4 12-6 3/4 12-7 3/4 12-8 Item (h):
Insert " locations" af ter the "three (3) milking animsls" and change " animals" to " animal" 3/4 12-9 3/4 12-10 3/4 12-11 Item (b):
Revise "microcuries per unit mass or volume" to "picocuries per unit mass or volume" 3/4 12-12 3/4 12-13 2nd paragraph:
capitalize " site boundary" to conform to the defined term 3/4 12-14 3/4 12-15 Bases:
5 3/4 3-4 Bases 3/4.3.5.8 expanded (refer to Enclosure 1, Attachment 2)
B 3/4 3-5 Bases 3/4.3.5.9 expanded (refer to Enclosure 1, Attachment 2) and revised to reflect the A0G system becoming operational B 3/4 3-6 B 3/4 11-1 B 3/4 11-2 B 3/4 11-3 Bases 3/4.11.2.1 expanded (refer to Enclosure 1, Attachment 5) and several miscellaneous corrections incorporar9d Bases 3/4.11.1.4, 2nd paragraph, line 3:
Insert 'or drain" after the phrase " transfer pump (s) vent" B 3/4 11-4 B 3/4 11-5 Add references to I-133 in Bases 3/4.11.2.3 Bases 3/4.11.2.4 revised to reflect the A0G system becoming operational B 3/4 11-6 Bases 3/4.11.2.6 revised to reflect the A0G system becoming l
operational B 3/4 11-7 Delete the first title line " TOTAL DOSE (40 CFR PART 190)
(Continued)"
B 3/4 12-1 B 3/4 12-2 Design Features:
5-1 5-3a Administrative Controls:
l Will be revised in future submittal l
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SUMMARY
LIST OF RETS REVISIONS BRUNSWICK UNIT NO. 2 PAGE COMMENT Table of Contents:
I II V
Correct typographical error in section title IX Delete page from RETS request IXa Section title (TS 3/4.11.2.3) revised to add reference to I-133 X
XIIA Section title (TS 3/4.11.2.3) revised to add reference to I-133 XIII XIV Will be revised in future submittal XV Will be revised in future submittal XVI Will be revised in future submittal Definitions:
1-1 1-2 1-3 1-4 1-5 1-6 1-7 1-8 1-9 1-10 1-11 LCO/ Surveillance Requirements:
i 3/4 3-61 l
3/4 3-62 3/4 3-63 l
3/4 3-64 l
3/4 3-65 3/4 3-66 3/4 3-67 Item (b) revised (refer to Enclosure 1, Attachment 2) 3/4 3-68 3/4 3-69 3/4 3-70 Item 6.b title revised from "Recombiner Train A" to "Recombiner Train B" 3/4 3-71 3/4 3-72 3/4 3-73 3/4 3-74 Item 5.a source check requirement revised (refer to Enclosure 1, )
3/4 3-75
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PAGE COMMENT 3/4 3-76 Item (b) revised (refer to Enclosure 1, Attachment 2)
Item (c) revised (refer to Enclosure 1, Attachment 3) 3/4 3-77 Item (e).1 revised (refer to Enclosure 1, Attachment 4) 3/4 3-78 3/4 3-79 3/4 3-80 3/4 3-81 3/4 3-82 3/4 3-83 3/4 3-84 3/4 3-85 3/4 3-86 3/4 3-87 3/4 4-7
" CONDITION" revised to "0PERATIONAL CONDITION" to conform to the defined term 3/4 4-10
" CONDITION" revised to "0PERATIONAL CONDITION" to conform to the defined term 3/4 6-6
" CONDITION" revised to "0PERATIONAL CONDITION" to conform to the defined term 3/4 11-1 3/4 11-2 3/4 11-3 Item (e), LLD equation revised 3/4 11-4 Item (e), conversion factor revised 3/4 11-5 3/4 11-6 Item (e), LLD equation revised 3/4 11-7 Item (e), conversion factor revised 3/4 11-8 3/4 11-9 3/4 11-10 3/4 11-11 Add reference to I-133 3/4 11-12 Item B, delete unit references 3/4 11-13 Item (a), LLD equation and conversion f actor revised j
3/4 11-14 Items (c) and (g) revised (refer to Enclosure 1, Attachment 5) 3/4 11-15 i
3/4 11-16 Add reference to I-133 3/4 11-17 l
3/4 11-18 3/4 11-19 3/4 11-20 TS 3.11.2.7, 2nd line:
Insert "or" af ter the phrase "shall be limited to less than" 3/4 11-21 3/4 11-22 l
3/4 11-23 3/4 11-24 3/4 12-1 3/4 12-2 3/4 12-3 2nd paragraph: cpaitalize " site boundary" to conform to the l
defined term
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3/4 12-4 3/4 12-5 3/4 12-6 l
PAGE COMMENT 3/4 12-7 3/4 12-8 Item (h):
Insert " locations" af ter the phrase "three (3) milking animals" and change " animals" to " animal" 3/4 12-9 3/4 12-10 3/4 12-11 Item (b):
Revise "microcuries per unit mass or volume" to "picoeuries per unit mass or volume" 3/4 12-12 3/4 12-13 2nd paragraph: capitalize " site boundary" to conform to the defined term 3/4,12-14 3/4 12-15 Bases:
B 3/4 3-4 Base 3/4.3.5.8 expanded (refer to Enclosure 1, Attachment 2)
B 3/4 3-5 Bases 3/4.3.5.9 expanded (refer to Enclosure 1, Attachment 2)
B 3/4 3-6 B 3/4 11-1 B 3/4 11-2 B 3/4 11-3 Bases 3/4.11.2.1 expanded (refer to Enclosure 1, Attachment 5) and several miscellaneous corrections incorporated Bases 3/4.11.1.4, 2nd paragraph, line 3: Insert "or drain" after the phrase " transfer pump (s) vent" B 3/4 11-4 B 3/4 11-5 Add references to I-133 to Bases 3/4.11.2.3 B 3/4 11-6 B 3/4 11-7 Delete the first title line " TOTAL DOSE (40 CFR PART 190)
(Continued)"
B 3/4 12-1 B 3/4 12-2 i
Design Feature:
l 5-1 5-3a Administrative Controls:
I Will be revised in future submittal i
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