BSEP-97-0100, Submits Suppl Request for License Amend Applicability & SRs Re Rev of TSs 3.0 & 4.0, & Respective Bases for These Sections to Incorporate Guidance Contained in GL 87-09

Submits Suppl Request for License Amend Applicability & SRs Re Rev of TSs 3.0 & 4.0, & Respective Bases for These Sections to Incorporate Guidance Contained in GL 87-09

ML20137N056
Person / Time
Site:	Brunswick
Issue date:	03/31/1997
From:	Campbell W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137N060	List: BSEP-97-0100, Submits Suppl Request for License Amend Applicability & SRs Re Rev of TSs 3.0 & 4.0, & Respective Bases for These Sections to Incorporate Guidance Contained in GL 87-09 ML20137N101
References
BSEP-97-0100, BSEP-97-100, GL-87-09, GL-87-9, NUDOCS 9704080235
Download: ML20137N056 (6)

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CP&L Carolina Power & !ight Company William R. Campbell PO Box 10429 Vice President Southport NC 28461 Brunswick Nuclear Plant MAR 31 1997 SERIAL BSEP 97-0100 10 CFR 50.90 TSC 87TSB16 U. S. Nuclear Regulatory Commission .

ATTN: Document Control Desk I Washington, DC 20555 i

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 [

DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS ,

APPLICABILITY AND SURVEILLANCE REQUIREMENTS Gentlemen:  ;

By letter dated April 4,1996 (Serial: BSEP 96-0126), and as supplemented by letter dated  :

January 24,1997 (Serial: BSEP 97-0024), Carolina Power & Light (CP&L) Company requested a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These proposed license amendments will revise Technical Specifications 3.0 and 4.0, and respective Bases for these sections to incorporate guidance contained in Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) On The Applicability of Limiting Conditions for Operation and Surveillance Requirements," and ,

NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision 1, April 1995.

The purpose of this submittalis to revise proposed Technical Specification 4.0.1 to include a stipulation that failure to meet a Surveillance Requirement constitutes a failure to meet the j Limiting Condition for Operation. This requirement is currently included in Technical Specification 4.0.3; however, this requirement was inadvertently not transferred to proposed Tech *.at Specification 4.0.1 as part of the license amendment request. This requirement is being added to Technical Specification 4.0.1, along with associated Bases discussion. Enclosure 1 provides further discussion of this revision. Updated page change instructions are provided in Enclosure 2. Updated typed Technical Specification pages for BSEP Unit No.1 and BSEP Unit ,

No. 2 are provided in Enclosures 3 and 4, respectively.

\ i CP&L is providing, in accordance with 10 CFR 50.91(b), Mr. Mel Fry of the State of North Carolina with a copy of this submittal.

h00 080066 9704080235 970331 i PDR ADOCK 05000324  ;

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e, Docurnent Control Desk BSEP 97-0100 / Page 2 Please refer any questions regarding this submittal to Mr. Keith R. Jury, Manager - Regulatory l Affairs at (910) 457-2783. [

i Sincerely, f William R. Campbell  !

WRM/wrm l

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Enclosures:

1. Discussion of Revision to License Amendment Request  !

2. Page Change Instructions

3. Typed Technical Specification Pages - Unit 1

4. Typed Technical Specification Pages - Unit 2 ,

Wiliam R. Campbell, 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, and agents of Carolina Power & Ught Company, h c6. Whw Notary (Seal) L My commission expires: u_S k '2,I y l%  !

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Document Control Desk i

. BSEP 97-0100 / Page 3 j 1

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pc (with enclosures): j

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U. S. Nuclear Regulatory Commission  ;

ATTN.: Mr. Luis A. Reyes, Regional Administrator l 101 Marietta Street, N.W., Suite 2900 i Atlanta, GA 30323-0199 j U. S. Nuclear Regulatory Cummission I ATTN.: Mr. C. A. Patterson, NRC Senior Resident inspector  :

8470 River Road '

Southport, NC 28461 U. S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) l 11555 Rockville Pike l Rockville, MD 20852-2738 l i

The Honorable J. A. Sanford l Chairman - North Carolina Utilities Commission j P.O. Box 29510 Raleigh, NC 27626-0510 l r

Mr. Mel Fry Acting Directer- Division of Radiation Protection i North Carolina Department of Environment, Health, and Natural Resources l 3825 Barrett Drive ,

Raleigh, NC 27609-7221 l

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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS APPLICABILITY AND SURVElLLANCE REQUIREMENTS DISCUSSION By letter dated April 4,1996 (Serial: BSEP 96-0126), and as supplemented by letter dated January 24,1997 (Serial: BSEP 97-0024), Carolina Power & Light (CP&L) Company requested a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These proposed license amendments would revise Technical Specifications 3.0 and 4.0, and respective Bases for these sections, to incorporate guidance contained in Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) On The Applicability of Limiting Conditions for Operation and Surveillance Requirements," and NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision 1, April 1995. ,

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Generic Letter 87-09 provides increased flexibility with regard to Technical Specificati n 3.0.4 by removing unnecessary restrictions on operational mode changes in those cases wbare conformance with an Action requirement already provides an acceptable level of sahty for continued operation in any mode for an unlimited period of time. In addition, Generic Letter 87-09 includes a change to Technidal Specification 4.0.3 to eliminate unnecessary plant shutdowns caused by this specification when surveillance intervals are inadvertently exceeded.

i The purpose of this submittal is to revise proposed Technical Specification 4.0.1 to include a J stipulation that failure to meet a Surveillance Requirement constitutes a failure to meet the i Limiting Condition for Operation. This requirement is currently included in Technical I Specification 4.0.3. In the April 4,1996, license amendment request, this requirement was inadvertently omitted instead of being relocated to the proposed Technical Specification 4.0.1.

Therefore, the stipulation that failure to meet a Surveillance Requirement constitutes a failure to meet the Limiting Condition for Operation is now being relocated and included as part of ,

1 Technical Specification 4.0.1. Thus, proposed Technical Specification 4.0.1 will read as follows:

Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation l unless otherwise stated in the Surveillance Requirement. Failure to perform a Surveillance l within the specified Frequency shall be failure to meet the Limiting Condition for Operation j except as provided in Surveillance Requirement 3.0.3. j This approach is consistent with NUREG-1433. which also includes this stipulation as part of Surveillance Requirement 4.0.1. Changes to the Bases associated with relocation of this i stipulation from Specification 4.0.3 to Specification 4.0.1 are also enclosed. l This revision provided herein to Technical Specification 4.0.1 restores a requirement that was inadvertently omitted during preparation and submittal of the April 6,1996, license amendment request. As such, these revisions are considered administrative changes which have no impact E1-1 l l

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on the bases or conclusions of the significant hazards evaluation included in our April 4,1996, submittal. Therefore, CP&L has determined that the conclusions of the significant hazards i evaluation published in the Federal Register on July 17,'1996 (61 FR 37297), remains valid. ,

i Through telephone conversations with the NRC Project Manager, CP&L has requested that the i portion of this submittal which eliminates the Technical Specification 4.0.3 requirement (i.e., shut down the unit when a surveillance interval has been inadvertently exceeded), be issued through a separate license amendment for each unit. CP&L has suggested that the remainder of the  :

proposed license amendment (i.e., the portion that allows operational mode changes in those i cases where conformance with an Action requirement permits continued operation in any mode '

l for an unlimited period of time) be separately issued when NRC review of that portion of the i

amendment request can be completed.' Therefore, based on this approach, CP&L is enclosing updated typed Technical Specification pages for BSEP Unit No.1 and BSEP Unit No. 2 which  !

address only the changes to Technical Specification 4.0.3 and its associated Bases regarding an l inadvertently missed surveillance. These typed pages do not include the revisions associated with the Technical Specification 3.0.4 changes. The page update instructions provided in Enclosure 2 have been revised to reflect issuance of only the Technical Specification 4.0.3 requirement.

l Typed Technical Specification pages for the portion of the license amendment request relating to  ;

the Technical Specification 3.0.4 changes will be provided in under separate cover in the near future.

REFERENCES

1. NRC Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) On The Applicability of Limiting Conditions for Operation and Surveillance Requirements," dated June 4,1987.

2. CP&L letter from William Levis to the NRC Document Control Desk, " Request for License Amendments - Applicability and Surveillance Requirements," dated April 4,1996 (Serial Number BSEP 96-0126).

3. CP&L letter from John S. Keenan to the NRC Document Control Desk, " Response to Request for Additional Information, Request for License Amendments, Applicability and Surveillance Requirements," dated January 24,1997 (Serial Number BSEP 97-0024).

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ENCLOSURE 2 i BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 1- OPERATING LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENTS APPLICABILITY AND SURVEILLANCE REQUIREMENTS t i

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r PAGE CHANGE INSTRUCTIONS j UNIT 1 l l

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i I i i PAGE CHANGE INSTRUCTIONS l c- i UNIT 2 i l

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