BSEP-95-0660, Provides Status for CP&L Reassessment of Labeling Position Per RG 1.97 Re Instrumentation Labeling

Provides Status for CP&L Reassessment of Labeling Position Per RG 1.97 Re Instrumentation Labeling

ML20101E849
Person / Time
Site:	Brunswick
Issue date:	03/19/1996
From:	Hicks G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 BSEP-95-0660, BSEP-95-660, NUDOCS 9603250239
Download: ML20101E849 (5)

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i CP&L Carolina Power & Light Company PO Box 10429 Southport NC 28461-0429 MAR 191996 SERIAL: BSEP 95-0660 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS DPR-71 & DPR-62 REGULATORY GUIDE 1.97 INSTRUMENTATION LABELING Gentlemen:

The purpose of this letter is to provide a status for Carolina Power & Light Company's (CP&L) reassessment of our labeling position per Regulatory Guide 1.97 " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." In letters dated September 30,1983 (Serial: LAP 408) and February 1,1984 (Serial: NLS-84-025), CP&L documented a position on RG 1.97 labeling for the Brunswick Steam Electric Plant, Units 1 and 2. The NRC Safety Evaluation was issued on May 14,1985, however it did not specifically discuss or acknowledge the exception taken to the labeling convention. CP&L has reassessed our RG 1.97 labeling position and has labeled the more limited set of non-RG 1.97 qualified instruments associated with RG 1.97 parameters. Enclosure 1 provides the details on CP&L position to label the non-RG 1.97 instruments. Enclosure 2 provides a list of regulatory commitments.

Please refer any questions regarding this letter to Mr. G. Honma at (910) 457-2741.

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s G. D. Hicks 250097 Manager - Regulatory Affairs Brunswick Nuclear Plant GMT/

Enclosures:

1. Position on RG 1.97 labeling

2. List of Regulatory Commitments 9603250239 960319 PDR ADOCK 05000324 1 I P PDR [.

l Document Control Desk BSEP 95-0660 / Page 2 cc: Mr. S. D. Ebneter, NRC Regional Administrator, Region ll Mr. D. C. Trimble, Jr., NRR Project Manager - Brunswick Plant Mr. C. A. Patterson, NRC Senior Resident inspector - Brunswick Plant The Honorable H. Wells, Chairman - North C rolina Utilities Commission I

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l ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 l

NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REGULATORY GUIDE 1.97 INSTRUMENTATION LABELING In letters dated September 30,1983 (Serial: LAP-83-408), and February 1,1984 (Serial:

NLS-84-025), Carolina Power & Light Company (CP&L) documented a position on RG 1.97 labeling for the Brunswick Steam Electric Plant, Units 1 and 2. The NRC Safety Evaluation was issued May 14,1985, however it did not specifically discuss or acknowledge the exception taken to the labeling convention. In August of 1995, the Resident inspector noted that RG 1.97 instruments in the control room were not specifically identified on the control panels. This is documented in NRC Inspection Report Nos. 50-325/95-19 and 50-324/95-19, dated September 25,1995, as Unresolved item 325,324/95-19-01.

A review of RG 1.97 parameters was conducted which documented the limited cases l

where qualified and non-qualified instruments monitor the same RG 1.97 parameter. The '

review determined that in the conirol room there were 38 RG 1.97 qualified instruments verses 12 non-RG 1.97 instruments that also monitor RG 1.97 parameters. Therefore to minimize cluttering the control panels, CP&L chose to label the non-RG 1.97 instruments that monitor RG 1.97 parameters. The following provides the list of non-RG 1.97 instruments which are being labeled:

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l Parameter Instrument # Ranae '

l Reactor Prassure Vessel Pressure C32-PR-R609 800-1100 PSIG l C32-LPR-R608 0-1500 PSIG Reaator Pressure Vessel Level C32-LI-R606 A,B,C 150 to 210 " I l C32-LPR-R608 150 to 210 "

C32-PR-R609 0-210 "

FW-LIC-3269 150-210" Suppression Pool Water Level CAC-LI-4177 -18 to -43" Drywell Pressure CAC-PI-2685 0 to 2 PSIG CAC-Pi-1230 0 to 75 PSIG l Stack Radiation Mos: tor D12-RR-R6008 10E + 1 to 10E + 13 CU/sec CP&L is implementing the following position regarding the identification of RG 1.97 instrumentation:

, For those cases where the only indications available to the operator for a specific i parameter are qualified as RG 1.97 instruments, no specialidentification of the

! instrument will be provided.

in those cases where the indication is provided by instr';ments which are both j RG 1.97 qualified and non-RG 1.97 qualified, the indiceter which is not RG 1.97 l qualified will be specifically identified.

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4 O Operators will receive training regarding the significance of using non-qualified Post Accident Monitoring (RG 1.97) instruments.

During the last License Operator Retraining (LOR) cycle, that started in January of 1996, training on RG 1.97 was provided. To support this training and to validate the labeling '

approach the 12 non-qualified instruments in the site's simulator were labeled. This was followed on February 23,1996 by installing the labels in the control room.

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! ENCLOSURE 2 L

i BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 l

REGULATORY GUIDE 1.97 lNSTRUMENTATION LABELING 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 the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager-Regulatory Affairs at the Brunswick Nuclear Plant of any questions regarding this document or any associated regulatory commitments.

Committed Commitment date or outage

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