ML20081B622

Application to Amend Licenses DPR-71 & DPR-62,revising Tech Specs Re Accident Monitoring Instrumentation Per NUREG-0737 & Generic Ltr 83-36

ML20081B622
Person / Time
Site:	Brunswick
Issue date:	03/02/1984
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20081B626	List: ML20081B622 ML20081B642
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.4, TASK-TM GL-83-36, NLS-84-074, NLS-84-74, NUDOCS 8403090252
Download: ML20081B622 (7)

Text

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e t CP&L Carolina Power & Light Company SERIAL: NLS-84-074 MAR 02 1984 Director of Nuclear Reactor Regulation Attention: Mr. D. B. Vassallo, Chief Operatica Reactors Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT NUREG-0737 TECHNICAL SPECIFICATIONS

SUMMARY

In accordance with the Code of Federal Regulations, Title 10, Part 50.90 and Part 2.101, Carolina Power & Light Company (CP&L) hereby requests revisions to the Technical Specifications for the Brunswick Steam Electric Plant, Unit Nos. I and 2. These revisions incorporate Technical Specifications for those NUREG-0737 items discussed in Enclosure 1 of Generic Letter No. 83-36.

DISCUSSION Generic Letter No. 83-36 dated November 1, 1983 requested all boiling water reactor licensees to submit proposed Technical Specifications for the NUREG-0737 items listed in Enclosure 1 of the letter. Carolina Power & Light Company has received the guidance information for these NUREG-0737 items and has identified those items for which a specification is needed. Enclosure 1, provided herein, discusses each NUREG-0737 item referenced in Generic Letter 83-36, including the CP&L action needed to resolve the item. Enclosure 2 provides a discussion of the major differences between the proposed Accident Monitoring Technical Specifications and the model specifications provided in Generic Letter 83-36. Enclosure 3 provides CP&L's proposed Technical Specifications based on the model specifications provided in Generic Letter 83-36.

SIGNIFICANT HAZARDS ANALYSIS Carolina Power & Light Company has reviewed this request and determined that the proposed revisions involve no significant hazard consideration because the proposed changes constitute additional limitations and restrictions not presently included in the Technical Specifications. The Commission has provided guidance concerning the application of its standards set forth in 10 CFR 50.92 for no significant hazard considerations by providing certain examples published in the Federal Register on April 6, 1983 (48 FR 14864).

One of the exemples of an amendment which will likely be found to involve no significant hazard considerations is a change that constitutes an additional RQ gh .. = ; . . , :: ~ w.x x x u w m m a m , m m . . ... ,_ m . c , .... . . m ~. . . m . . m

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D. B. Vassallo limitation, restriction, or control not presently included in the Technical Specifications. The proposed changes enclosed are an example of such an amendment and, therefore, CP&L believes the proposed changes fall within the Commission's. example (ii) of an action not likely to involve a significant hazard consideration.

ADMINISTRATIVE INFORMATION Enclosed are revised Technical Specification pages for Brunswick-1 and

~ Brunswick-2 with the changes indicated by vertical lines in the right-hand margins. We have reviewed this request in accordance with the provisions of 10 CFR 170.22 and have determined that the request involves a Class III license amendment fee for Brunswick-1 and a Class I license amendment fee for Brunswick-2. Accordingly, you will find enclosed a check for $4,400.00 in payment of these license amendment fees.

- Should you have any questions concerning this submittal, please contact our Licensing Staff.

Yours very truly, C.L).

P. W. Howe Vice President Brunswick Nuclear Project WRM/pgp (9521WRM)

Enclosures cc: Mr..D.- O. Myers (NRC-BSEP)

Mr. J. P. O'Reilly (NRC-RII)

Mr. M. Grotenhuis (NRC)

Mr.fD. H. Brown, Chief Radiation Protection Branch Division of' Facility Services Department of Human Resources 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.

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O ENCLOSURE 1 TO NLS-84-074 ITEM 1: REACTOR COOLANT SYSTEM VENTS (NUREG-0737, Item II.B.1)

The Brunswick Plant does not have isolation condensers; therefore, no changes in the Technical Specifications are being required by the NRC staff, i' ITEM 2: POST-ACCIDENT SAMFLING (NUREG-0737, Item II.B.3)

By letter dated December 29, 1983, CP&L submitted to the NRC staff proposed revisions to Section 6, Administrative Controls of the Technical Specifications for Brunswick-1 and Brunswick-2. This submittal incorporated proposed Technical Specifications (refer to proposed TS 6.8.3.c) addressing NUREG-0737, Item II.B.3. Those proposed Technical Specifications follow the model Standard Technical Specifications provided in Enclosure 3 of Generic Letter 83-36.

ITEM 3: NOBLE GAS EFFLUENT MONITORS (NUREG-0737, Item II.F.1.1)

Enclosed are proposed Technical Specifications addressing the turbine building ventilation monitor and the off-gas stack ventilation monitor. As specified in Generic Letter 83-36, these noble gas monitors will be required to be operable at all times during plant operation (i.e., the monitors will be required operable in Operational Conditions 1, 2, and 3).

The Generic Letter stated that an alternate method for monitoring the plant

. effluent should be initiated as soon as practical, but no later than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after identifying an inoperable monitor. If the monitor is not restored to operability within 7 days af ter identifying the failure, the submittal of a Special Report to the NRC within 14 days is requested. These provisions have been incorporated into the requirements of the proposed Action Statement.

Proposed Technical Specifications addressing the reactor building ventilation i exhaust monitor are not included in the enclosed request. Carolina Power &

Light Company has taken credit for the automatic diversion of reactor building ventilation exhaust to the standby gas treatment (SBGT) system which discharges to the plant stack. In your letter to Mr. J. A. Jones (CP&L) dated January 21, 1982, you stated that while this approach constitutes a deviation to the requirerents of NUREG-0737, the approach does meet the intent of NUREG-0737 and is, therefore, acceptable. The acceptance of the approach was conditioned on two items, both of which were addressed in our letter of March 31, 1982 concerning NUREG-0737 Items II.F.1.1 and II.F.1.2. Based on -

the Staff's acceptance of the ' alternative approach discussed above, proposed specifications for the reactor building ventilation exhaust monitor are not necessary.

ITEM 4: SAMPLING AND ANALYSIS OF PLANT EFFLUENTS (NUREG-0737, Item II.F.1.2)

By letter dated December 29, 1983, CP&L submitted to the NRC staff proposed i revisions to Section 6, Administrative Controls of the Technical

. Specifications for Brunswick-1 and Brunswick-2. This submittal incorporated proposed Technical Specifications (refer to proposed TS 6.8.3.c) addressing

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! NUREG-0737. Itaa'II.F.1.2. Those proposed Technical Specifications follow the I model Standard Technical Specifications provided in Enclosure 3 of Generic Letter 83-36. -

ITEM S: CONTAINMENT HIGH-RANGE RADIATION MONITOR (NUREG-0737. Item II.F.1.3) l EuclosekareproposedTechnicalSpecificationsaddressingcontainment radiation-level monitors (drywell area radiation' monitors). As specified in Generic. Letter 83-36, the radiation-level monitors will be required to be operable at all times %xcept for cold shutdown and refueling outages (i.e., l

~the monitors are required operabis in Operational Conditions 1, 2, and 3). It j

- should'be noted that-CP&L has opted to include an Applicable Operational Conditions column'in Table 3.3.5.3-1 rather than include a footnote *.n the Applicability statement of TS 3.3.5.3 in order to more specifically define this requirement. . Also, as specified in the Generic Letter, provisions are

' included in the proposed Technical Specifications requiring that a Special Report be submitted to the~ NRC within 14 days if an inoperable monitor is not returned to operable condition within 7 days after the failure.  ;

ITEM 6: CONTAINMENT PRESSURE MONITOR (NUREG-0737, Item II.F.1.4)

- The Brunswick Technical Specifications already include requirements for a minimum of two containment pressure monitors; however, enclosed are revised

' Technical Specifications that are consistent with the model specifications relative to-incorporating' requirements for Required Number of Channels, Minimum Channels Operable, and the operational conditions during which monitor operability is requ'ited.~~~ ~

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' ITEM 7: CONTAINMENT WATER LEVEL MONITOR (NUREG-0737, Item II.F.1.5)

Technical Specification changes to incorporate revised requirements for containment water level monitors have-already been reviewed and approved by

.the NRC staff as Amendment No. 63 for Brunswick-1 and Amendment No. 81 for '

Brunswick-2.

ITEM 8: CONTAIltiENT HYDROGEN MONITOR (NUREG-0737, Item II.F.1.6)

Technical Specification changes to incorporate revised requirements for containment hydrogen monitors (and containment oxygen monitors) have already been 2eviewed and approved by the NRC staff as Amendment No. 63 for Brunswick-1. Enclosed are proposed Technical Specifications addre? sing containment hydrogen and oxygen' monitors for Brunswick-2. The modifications corresponding to these proposed specifications will be installed during the.

Brunswick-2 Reload 5 odtage, presently scheduled to begin March 1984.

Carolina Power & Light Company will notify the staff when the modifications are installed and'the specifications should be issued.

ITEM 9d CONTROL. ROOM HABITABILITY (NUREG-0737, Item III.D.3.4)

The Brunswick Technical Specifications already include requirements for a chlorine detection system (refer to TS 3.3.5.5); however, our review of the Brunswick requirement has identified the need to revise the chlorine detection l

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- system alarm setpoint. The existing TS 3.3.5.5 allows the chlorine concentration in the control room intake air to reach 50 ppe before the chlorine detection system alarm is required to actuate. According to Regulatory Guide 1.95, a chlorine concentration of 15 ppa is considered the toxicity limit for human beings. Although the alarm setpoint on the control room chlorine detection system at the Brunswick Plant is currently set to actuate at a chlorine concentration of 1 ppa, CP&L believes that it would be prudent to change the chlorine alarm setpoint limit to a lower, more conservative value. Therefore, CP&L proposes to lower the control room chlorine detection system alarm actuation limit from a chlorine concentration of 50 ppa to a chlorine concentration of 5 ppa. An alarm setpoint of 5 ppe for the system is consistent with the staff guidance provided in the GE/BWR-4 Standard Technical Specifications (refer to STS 3.3.7.8).

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ENCLOSURE 2 TO NLS-84-074 l

The existing Brunswick Technical Specifications list eleven items in the post-  !

accident monitoring instrumentation tables (Tables 3.3.5.3-1 land 4.3.5.3-1). l The existing specifications require these eleven items .co be operable in ]

. Operational Conditions 1 and 2. These specifications also require a minimum )

l of two operable instrument channels (except for the safety / relief valve position indication) and state that with either one or two chanaels less than the required number of operable channels, operation may continue for up to 31 days. ,

i The Standard Technical Specifications now include requirements for the required number of channels, the minim a number of channels operable, and varying action requirements for inoperable accident monitoring instrumentation (previously referenced as post-accident monitoring instrumentation). Carolina Power & Light Company has attempted to upgrade the format of the enclosed proposed specifications to that of the Standard Technical Specifications; however, the Standard Technical Specificacions include more restrictive Action Statements. In reformatting the Brunswick specifications, the Minimum Number of Operable Instrument Channels-column of the existing Brunswick Table 3.3.5.3-1 has been converted to the Required Number of Channels column in the corresponding table in the Standard Technical Specifications. The Minimum Channels Operable column of the Standard Technical Specifications has been adopted; however, since this Standard Technical Specification requirement 4 is less stringent than the existing Brunswick requirement concerning minimum number of operable channels, the existing Brunswick Action has been upgraded by using a slightly' modified version of Action Statement 82 from the Standard Technical Specifications. The existing Brunswick Action Statement allows continued operation for up to 31 days with two fewer operable channels than the minimum number of operable channels specified. The proposed Action Statement 82 will permit continued operation for up to 31 days with fewer operable channels than the specified Required Number of Channels and will permit continued operation for up to 7 days with fewer operable channels than the specified Minimum OPERABLE Channels. ,

The wording of proposed Action Statement 81, part (1) and Action Statement 82, Part (b) have been modified to more clearly define the requirement to restore

.a sufficient number of channels to operable status to meet the Minimum

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0PERABLE Channels requirements of Table 3.3.5.3-1. .In addition, the wording of proposed Action Statement 82, part (a) has been modified relative to the time period allowed for returning an inoperable channel to operable status.

The Standard' Technical. Specifications specify a 30-day time period; however, CP&L has selected a 31-day time pericd in order to be consistent with the monthly ' surveillance frequency given in Section 1,, Definitions of the Brunswick Technical Specifications and the Standard Technical Specifications. A'31-day time period is also consistent with certain other requirements in the Brunswick Tacitnical Specifications.

In addition, CP&L has opted to include in proposed Table 3.3.5.3-1 an Applicable Operational Conditions column in lieu of the Standard Technical Specifications Applicability footnote in STS 3.3.7.5. The footnote states that " Operational Condition 3 is applicable only to the it4atrumentation for

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radiation mnitoring." Carolina Power & Light Company believes that the use of an Applicable Operational Conditions column will more specifically define the applicability requirements than do the model Standard Technical Specifications.

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