BSEP-92-0024, Forwards Request for Temporary Waiver of Compliance from TS 3.3.3, ECCS Actuation Instrumentation When in Operational Condition 4, to Permit One Channel from Each of Two Trip Sys to Be Inoperable Simultaneously for Up to 12 H
| ML20115A930 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/07/1992 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| BSEP-92-0024, BSEP-92-24, NUDOCS 9210150181 | |
| Download: ML20115A930 (11) | |
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{{#Wiki_filter:- g CD&L Carolina Power & Ught Company Brunswick steam Electric Plant P O Box 10429
- Southport. N C 28461 OCT 0 71992 R. B. RICHEY SERIAL: BSEP-924024 vce President Brunswick Nudear Progoct United States Nuclear Regulatory Comi11ssion, Region 11 Attentlen: Mr. S. D. Ebneter 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30301 BRUNSWlCK STEAM ELECTRIC PLANT, UNo r406. AND 2 DOCKET NOS. 50-325 & 50424/UCENSE NOS. DPR-71 & DPR-62 REQUEST FOR TEMPORARY WAIVER OF COMPUANCE ECCS ACTUATION AND INJECTION PERMISSIVE INSTRUMENTATION Gctitlemen; The purpose of this letter is to request a temporary Walver of Compliance for the Brunsw!ck Steam Electric Plant, Unit 1 and Unit 2. 4 The proposed walver vdll exempt the requirements of Technical Specification 3.0.3 for Technical Specificron 3.3.3, Emergency Core Cooling System Actuation instrumentation, v. hen in OPERATIONAL CONDITIG4 4 (COLD SHUTDOWN). The proposed waiver will also be used to allcw one channel from ) each of two trip systems of the reactor vessel water level - low level 3 ECCS actuation Instrumentation, while in OPERATIONAL CONDITION 4 (COLD SHUTDOWN), to be inoperable simultaneously due to the surveillance of excess flow check valves, for up to twelve hours before requiring the verification of at - leart one LPCI subsystem operable. The proposed walver will also allow fewer than the minimum number of channels in a reactor steam dome pressure -low trip system and allow one channel to be placed in the inoperablo status for ep to seven days, provided the other channel in the same trip system is operable, that both channels in the other trip system are operable, that the inoperable channel is placed in the condition that wou'd satisfy the logic for allowing injection by the ECCS with the reactor steam dome pressure below 410 psig 215 psig, and that actions are taken to ensure that the reactor stearn domo pressure will not e; a,410 psig 15 psig. This is needed to perform modifications to upgr:.Je the selsmic 4 erlification of Ir "mment ncks. The detalled basis for the proposed walver is provided in Enclosure 1. Carolina Power & Ught Company is requesting this waiver for four (4) separate 12 hour periods for each Brunswick unit to accommodate the excess flow check valve surveillance testing and two (2) separate 7 day penods for each Brunswick unit to accommodate seismic urmrade modifications of two instrument racks. The Company will notify the NRC Resident inspector within 24 l'ours prior to starting work associated with each waiver period. The Plant Nuclear Safety Comnnee has reviewed and recommended approval of this request. The Company requests approval of tN3 proposed walver by Octnber 21,1992 to support the required surveillance and modification schedule. 130085 92101 g k h h 24 DR PDR pg W
4 Please refer any questions regarding this submittal to Mr. R. C. Godley at (919) 457-2412. Yours very truly, -kdlb1falvf\\r / R. B. Richey Vice President Brunswick Nuclear Project WRM/wrm (oceswalv005) Enclosure cc: NRC Document Control Desk Mr. R. H. Lo Mr. R. L Prevatte i l: 1 o t. I
s- -r 4 ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50 324 OPERATING UCENSE NOS. DPR 71 & DPR-62 REQUEST FOR TEMPORARY WAIVER OF COMPLIANCE EXCESS FLOW CHECK VALVE SURVEILI.ANCE' -_ EQUIREMENTS FOR WHICH A WAIVER ($ REQUESTED: R The Brunswick Plant design has an Emergency Core Cooling System (ECCS) comprised of the cora spray system and the low pressure coolant injection mode of the residual heat removal system. Both the core spray system and the resdual heat removal system consist of two sub systems. Actuation of these low pressure subsystems occurs upon either drywell pressure - high coincident with low reactor pressure, or reactor vessel water level - low level 3. Elther of these actations would indicate conditions that may require injection of additional coolant to maintain reactor vessel Inventory, Fctiowing actuation, each of these systems is designed to I,yect when the pressure vessel reaches the reactor steam dome pressure low (irsction permissive) pressure. Technical Specificot!on 3.5.3.2 requires two independent low pressure coolant inject (LPCI) subsystems of the residual heat removal system shall be OPERABLE. ACTION b states in part that *., with one or more LPCI subsystems inope 3ble take the ACTION required by Specification 3.5.3.1." Technical Specification 3.5.3.1 requires two independent core spray system (CSS) subsystems to be OPERABLE. ' ACTION b.2 states in pan that with both CSS subsystems inoperable /..s:Jspend all operations that have a potential for dmining the reactor vessel and verify that at least one low pressure coolant injection subsystem is OPERABLE within 4 hours " Technical Specification 3.3.3, ACTION c states that "The provisions of Specification 3.0.3 are not applicable in OPERATIONAL CONDITION 5." The proposed waiver to Technical SpecNication 3.3.3 would allow the requirements of Specification 3.0.3 not to be applicable in OPERATIONAL' CONDITION 4 for the periods of time indicated below. The proposed walver to Technical Specification 3.5.3.1 win allow in OPERATIONAL CONDITION 4 (OOLD L SHUTDOWN): i i
- 1) with both core spray and both low pressure cootant injection ECCS subsystems inoperable duo to functional surveillance of an exec:a flow check valve, suspend all operations that have a puential for draining the reactor vessel and verify that at least one low pressure coolant injection subsystem is operable within 12 hours.
- 2) with coth core spray and both low pressure coolant injection ECCS subsystems noperable due to the Inoperable status of a steato dom) reactor pressure -low, (injection permissh/e) channel pressure transmitter (for *he purpose of instrument rack modification), suspend all operations that have a potential for draining the reactor vessel and verify that at least one low pressure coolant injection subsystem is operable within seven days and a) verify the other channel in the same trip system is OPERABLE, b) verify bcth channels in the other trip system are OPERABLE, E1-1 1
H 4 4. l i c) place the Inoperable channel in the condition that would satisfy the logic for allowing l injection by the ECCS when the reactor steam dome pressure is below the Technical Specification required injection permissive setpoint of 410 psig 215 psig. and d) take actions to ensure the reactor pressure vessel pressure will not exceed the Technical Specification injection permissive setpoint of 410 psig 15 psig by maintaining the reactor head vent in the open position. DISCUSSION OF CIRCUMSTANCES LEADING TO THE REQUEST: Technict; opecrfication 4.3.6.4 requires that each primary containment isolation valve be demonstrated to be operable at least once each 18 months by cycling each valve through at least one complete cycle of full travel. This requirement applies to four excess f'ow check valves (821-F042A, B21 F042B, B21-F044A, and 821-F044B) that are associated with the two channels in each of the two ECCS actuation :nrtrumentation systems which actuate the core spray and lov, pressure coolant injection ystems when : aactor vessel water level - low level 3 is reached. Table 1 identifies the instrument lines and itstrumentation associated with these four excess flow check valves. Two of these four excess flow-check valves are also associated with the reactor steam dome pressure - low (injection permissive) ECCS aciuation instrumentation systems of care spray and low pressure cwlant injection systems. Isolation and testing of wt: of the four excess flow check valves requca that one channel in each of the two low pressure ECCS actuation trip systems be taken out of service and, for two of these excess flow check valves, that one channel in one trip system of the injection pressure permissive function of the low pressure ECCS be taken out of service. In addition, two of four instrument racks (instrument rack nos. P009 and P010) containing one each of the four reactor steam dome pressure low pressure transmitters require modific.tlon to satisfy upgraded seismic qualification requirements. The instrument rack modifications will require that the associated pressure transmitter (B21-PT-N021C for instrument rack P009; B21-PT-N021D for instrument ra P010) be taken out of aervice for a period of time longer than the 4 hour period for restoring at least one OPERABLE low pressure coolant injection subsystem as required by Technical Specification 3.S.3.1, ACTION b.2. The pressure transmitters located on these instrument racks are the two that are not required to be taken out of service when the excess flow check valves identified above are taken out of service. The isolation and testing of the excess flow check valves and the modifications to the two !nstrument racks will require more than four hour period for restoring one OPERABLE low prassure coolant injection subsystem. Were ischtion and testing of the excess flow check valves to occur during OPERATIONAL CONDITIONS 1, 2, ( d 4, the required actions of Table 3.3.3-1 (ACTION 30) would be appi; cab'e. Sin.;c each of the four wess flow check valves of Interest serves t'ne of two channels in each of the two ECCS actuation trip systems, isolating each excess flow check valve would require declaring the assocktod ECCS Inoparable. Thus, both trains of both the core spray system and low pressure ccolant injecu.,o system would therefore be required to be declared inoperable and the actions of Technical Specifications 3.5.3.1 and 3.5.3.2 would be followed. Also, for the two excess flow check valves which would require associated rcactor steam dome pressure -low pressure transmitters to be taken out of service (l.c, excess flow check valves B21-FG42A and B21.F044A), the requirements of Table 3.3.3-1 (ACTION U) would require that the associated ECCS be declared inoperable. Since each of the four - pressure permissive pressure transmitters are associated with each of the two trairu of both core spray and low pressure coolant injection, the actions of Technical Specifications 3.S.3.1 and 3.5.3.2 are
- required, For the reasons described above, the isoiation and testing of the E21-F042A, F042B, F044A, and F0448 excess finw check valves has historically oc urred when the operabil:ty of the low pressure coolant E1-2
m Injection and coro spray systems were not requirod: The requirements of Technical Spectcations 3.5.3.1 and 3.5.3.2 are not applicablo in OPERATIONAL CONDITION 5 with the reactor - vossol head romoved, the refueling cavity f!ooded, and the spent fuel gatos removed.- Modification of two instrument racks in each Brunswick Plant unit will require soveral days to complete. If the modifications were pntformoa during OPERATIONAL CONDITIONS 1,2,3, cr J, the actions of Tablo 3 3.31 (ACTION 31) would be applicable and the associated ECCS wculd be required to be declaiod inoperable, As noted above, with both trains of botn the core spray system and low pressure coolant Injoction systems declared inoperable, the actions of Technical Specifications 3.5.3.1 and 3.5.3.2 would be requirod. Both Brunswick units are currently In mid cycle outages. The outagos were entered when concoms aroso that solsmic design tsquirements woro not satisfied. Work that must be,lompleted prior to resumption of the current cyc!os has boon ident!ied and modifications are being made to upgrado the seismiu qurillfication of soveral structure and components. For each unit, each of two instrument acks identified for modification contain one of the pressure transmitters that providr4 input to the reactor c'e?m - domo pressuro low ECCS inloction permissivo trip systems. The cunont cycle of Unit 1 began in February 1991; the current cycle of Unit 2 began in January 1992. As (dont;!k,J above, ths isolation and testing of the four scoss flow check valvos has historically occurred during OPERATIONAL CONDITION 5 (REFUELING) with the vessol head removed, the cavity flooded, and the spent fuel pool gates removed. The surveillance of the excess flow check valves is regulrod to be performed once ovory 10 months. The next surveillance for Unit 1 is due September 1992, and for Unit 2 the surveillanco is duo July 1993. Beforo the current mid. cycle outagos, the next refueling outage for Unit 1 was scheduled to begin in September 1992. Unit 1 is now currently schedul9d to bogia its next refueling on March 4,1993. Also, before the current mid cycle outago, the next refueling outage for Unit 2 was scheduled to begin in March 1993. Unit 2 is now currently schodolod to begin its next refueling outage on September 9.1993. l The Cornpany currently plans to upgrado the solsmic quahfication of the two instrument racks contalning l the B21 PT N021C and 821-PT-N021D toactor steam dome pressure - low pressure transmitters prior to ohher Brunsw'ck Plant unit resuming operation. As identilled above, those Instrument rack modifications will requito that the associatcd pressure transmitter bo taken out of servico for a porlod o time. r CAFETY SIGNIF'CANCE AND POTENTIAL CONSEQUENCES: Corolina Powoi & Ught Company has ovaluated the safo*y significanco ane' patential consequences of the proposed waiver of compliance ano detremined there is no adverso irn ect associated with tho' 3 prooosed request. ..The proposed walvor would exempt the requirements of Technical Specification 3.0Nfor Technical Specification 3.3.3, Emergency Core Coollt.g System Actuation Instrumentation, when in OPERATIONAL CONDITION 4 (COLD SHUTDOWN). The proposod walver would alto be used to ailow one channel from each of two trip systems of the reactor vossol water level -low lovel 3 ECCS actuation instrumentation, while in OPERATIONAL CONDITION 4 (COLD SHUTDOWN), to be inoperable - simultaneously due to the survoillance of excess flow chock valves, for up to twelvo hours before requiring the verification of at least one LPCI subsystem operablo. The proposed walvor will also allow fewer than the minirnum number of channels in a reactor steam dorne pressure low trip system and allow one channel to be placed in the inoperable status for up to seven c:ays, provided the othnr channel in the same trip system is operable, that both channels in the uthor trip system are operable, that the E13
Inoperable channel is placed in the ccrdition that would satisfy the logic for allowing injection by the ECCS with the reactor steam domo pressuro below 410 psig i 15 psig, arx1 that actions are taken to ensure that the reactor steam dom 9 pressure will not excood 410 psig 15 psig-The design basis LOCA is In'tlated by a rocirculation suction lino break with the reactor operating at full power. Loss of coolant inventory occurs due to rapid de-pressurization and blowdcru of steam and water into containment. Automatic initiation of ;ho low pressure ECCS systems (coro spray and low pressure coohnt injection) providcs lar00 volumes of mako-up coolant irrventory ard limits the peak clad fuel t mporaturo roached during tho accident. Actuation of the low pressuro ECCS systems occurs on either high drywell possuro + low reactor pressure or roactor vossel water levol - low lovel 3. The roactor steam demo pressuro. Iow Injection pormissivo must be satisfied in order to allow the Injoction valvos to open. Automatic initiation of the low pressuro ECCS systems ensures those systams are able to inject coolant as soon as possibfo relativo to tho timo it 'akos the roac'nr pressuro vo%ol to depressurtze tc the low procsuro injection permissivo for tho design basis accident corxiltions. Opening of the injection valvoa prior tc ioasol prascro falling below the low pressure permissivo has the potential for add!!!onal loss of vosso: coolant inventory through the ECCS piping. When tho vossol pressuro is below the injection permissivo Technical Specification pressuro limit of 410 psig 2 15 psig, placing one channel of one of the two Roactor Steam Domo Pressuro Low trip systems in the condition that would satisfy the logic fur allowing injec lon by the ECCS will enablo tho trip systems to function propody in the event the coro spray and low pressure coolant injection ECCS subsystems aro required. When the vossol pressuro is greator than the low pressuro injection permissivo, placing one channel in the condition that would allow injection could make the single failuro of a pressuro transmitter in the other trip system (thoroby completing the logic for opening the injection valves) causo additicnal loss of vessol Inventory during a loss of coctant accident. To ensure that the potential for roaching reactor conditions (vossol pressuro greator than the injection permissivo pressure of 410 psig i 15 psig) which could enable a single failure to havo an adverso impact on the capability of the ECCS to supply coolant loventory during a loss of coolant accident, actions to ensura the vossol pressuto will not oxcoed 410 psig i 15 psig, will be put into place. Specifically, the roactor head vont will be maintainod in the opon position. By placing the Inoperablo channot in the condition that satisfies the logic for Injoction, and by regulr;ng tho actions to ensure the voss91 prossure will not excood 410 psig i 15 psig, the proposed walvor will not reduce plant safoty to an unacceptablo lovel. At prosont, both Brunswick Plant units have been in cold shutdowr for more than 4 months. Thoroforo, a pipo break under cuiront cor.ditions would result in a peak clad temporaturo that is signifienntly loss than that resultir.g trom a design tN nis accident becaua significantly loss decay hoat oxists than that assumed in the design basis acc!dont. In addition, the rato of coolant inventory loss is significantly ;oss than that assumed in the design bash loss of coolant accident due to the reduced pressure differenco betwoon tM prcmoro vossol and containment. This reduced rate of Inventory loss provides greater opportunity for the operator to klonuly and monttnr the loss of pressuto vossol coolant inventory and to manually actuato the low pressuro ECCS systems, if required. Any delay in a required low pressuto ECCS actuation on vossol water lovel would be duo to a combination of the following threefaw probability events: Loss of coolant ncident with the reactor vessel depressurized. Falluro of una of the two oporablo channols for low Lovel 3 (those channels are functionally tested monthly and have hlstorically had a very low faliuro rato). E1-4
~, C N Failure of the operators to r anually init'ato the required systoms after the level drops below the plant sotpoint of 45 inchos and before it roachos the Technical Specification limat of 2.5 inchos. Due to the insignificant probabNty of this combinatioq occutting during the short lotstval of timo speciflod, the proposed walvor to allow isolation and testing of the Unit 1 anc 2 ouess flow choci' valves will not reduco plant safety to an unacceptable level.~ . DISCUSSION OF _ JUSTIFICATION FOR DURATION: Survolllanco Testina: The isolation and testing of each Unit 1 and 2 excess flow chuck vaivo is expected to require fewer than 12 hours. Nthough a real!stic estimato is that isolation and footing can be completed in approximately four hours, a 12 hour duration for the waNor of complianco for roaulrenonts in Technical Specification 3.ft.3.1 for tho verification of at least ono LPCI subsystem oporable is being requested to allow for unforosoon problorns that may occur durin0 the procoes. M Instrument Rack ModificallDD: The modification of the incrum9nt racks containing pressure transmitters D21-PT N021C and 821.PT. 71D is expected to require fower than sovon days. Although a realistic ost!mato is that the ne dification can be completed in approximatoiy three days, a seven day duration for the walvor of -{ complir.nco for requiromont in Technical Spocification 3.5.3.1 for verification of at least ono LPCI subsyrtom operablo as a result of roactor stoam domo prossur9 -low lostrumentation inoperability is i being request 6d to allow for m.urosoon problems that may occur during the process. 4 D16.CUS$1QN OF COMPENSATORY ACTIONS: The compensatory actions described below will be taken to ent.aro the plant configuration remains capable of responding to conditions requiring the actuation of the low pressuro ECCS systems during functional survolllance of the excess flow check valvos and the mod!!! cation of the instrumet.t racks. Technical Specif' cations 3.5.3.1, ACTION b.2 allow operation to continuo provided at least one low pressure coolant inJoction subsystem is verified OPERABLE within 4 hours. During the survoillanco - testing of the B21-F042A and F042B oxcess flow chock valvos to _bo performod under the proposed walvor, one chant'ol in each of the two ECCb actuation qstmmentatien trip systems will be inoperable. - During the survoillance testing, at least ona channo8 in cach trip systam will be requirod to be operable. The modifications to the instrument racks will require taking two of four injection permisske pressure transmitters out of sea /m at separato times. As discuscod above, the injection permissivo is designed to ensure that tho m.t v9ssel pressure is nfficiently low enough to ensure that the low pressure - ECCS systems wili tra solo to inject into the vossol during a loss of coolant accident. In OPERATIONAL CONDITION 4 the reactor vossol is essentially unpressurtzod. At very low roactor vossol pressures, the ? ij ti it the .dov_ loped pump head of the low pressure systems is more than adequate to ensure n ec on n o reactor vessel in the ovont of a loss of coolant accident. With the vessel unpressurized, placing the Inoperable pressurc permissivo channel in :he condition that satisfies tho_ logic for allowing injection and requiring both channels of the other inp system to be OPERABLE will onsure that the injection permissive will be satbiled should the low pressuro coolant Injoction' systems be neocodi Satisfying the logic to allow injection would not be appropriato should the - reactor vessel pressure excoed the injection permissive.' To ensure that the reactor vessel does not El-5 m
V W ' become pressurized above the injection permissNo, the reactor head vont will be maintained in the open position. SIGNIFICANT lt#2ARDS ANALYSIS:- The Commission has provided stanuards in 10 CFR 50.92(c) for oetermining whethor a significant. hazards consideration exists, Carolina Power & Light Company has revkwod this propocod temporary walvor of complianco and dotormined that its adoption would not involve a significant hazards consideration. The basis for this dotorminatfori follows: 1, The proposed walvor will allow, while in OoERATICNAL CONDITION 4,12 hours to restore at least one OPERACLE low possure coohnt injection subsystem white performhg survolllance testina of excess flow check valvos 821 F042A, F0428. F044A, and F0448. Ths proposed walvor will alto allcw, while in OPERATIONAL CONDITION 4, sovon dcys to rostore at least one OPERABLE low pressure coolant Injoction subsystem while perfonnir.g modifcations to Instrument rack nos. P009 and P010 to upgrade their solsmic qualificatka No accident initiators or procurt. ors are :, hanged by the proposed waNo. NoN,t the low pressure coolant injection actuation instrumentation nor the low pressure coolant injection systoms themselves will initia.e an accident. This equipment is instead provided to mitigato the consequences of an accident. Thorofore, the proposed walvor will not significantly increase the probabihty of an accident previously evaluated. During the excess flow check yalvo survoulance testing, one channel in each of two reactor vossol water lovel Iow lovel 3 trip systems will be Inoperable at tto same time. The two remaining water lovel monitoring channels, one in oar:h of the two low prassure ECCS actuatbn trip systems, will be required to be OPERABLE. Under these conditions, a single failur9 in either of the two romalning water lovel inarument channels could provent the trip system from eosponding to an actual vossol low water lovel and thereby provent automatic actuation of tha low pressure ECCS. Automatic actuation is most important for the design basis loss of - coolant accident (LOCA) assumed to be kitiated from full power conditionsqunder full power conditions, a design basis loss of cWM accident results in rapid loss et coolant inventory from the reactor vossol. In t'le ;. ni of a loss of cnolant accident with the units in OPERATIONAL + CONDITION 4, the rato of loss of coolant loventory from the unpressurized reactor vessel would be greatly reduced. In the event that a single failuro irNoiving one of the two romaining water level !astrument channels were to occur, alarms and trips frcm other reactor vessel water leve! o instrumentatit,,, would occur and provido the operator su8ficient time to monPnr, and if. necessary, maneally Initiate the low pressure ECCS prior to uncovering the reactor core.- During the planned instrument rack modifications, one chanael of the two injection permissive trip systems will be inoperable. The planned compensatory action of placing the affected injection permissive channel !n the cond% M satisfios the logic will ensure the capability to actuato and inject low pressuro ECCS, if requiroo. In addition, the planned compensatory action of opening the reactor head vont will ensure that the reactor vessel cannot pressurize and thoroby inhibit the capability of the low pressuro ECCS to inject during a loss of coolant accident tn OPERATIONAL CONDITION 4. Based on the above discussions, the proposed walvor does not involve a significant locrease in the consequences of an accident previously evaluated. El-6 ( m e .1<
a 4 The proposed walver will allow the simultaneous (noperability of ono channel in each of two 2.: roactor vossol low water levol instrumentation trip systams. T h!s instrumentation is designed to detect low water level and to actuate tw low pressuro ECCS. Compensatory actions will be taken to ensure that the other channel in the effected trip system is OPERA 3LE and ttnt both channels in the other trip system a.v OPERABLE. The nroposed waiver will also allow one channel of the two drywell pressure - low trip systems to bc.noperablo without requ iac at least one LPCI subsystem be declared operable within 4 hours when that channot is placed in the cordition that satisfies the logic for the injectior4 - permissive for the low prus'.ur9 ECCS. In addition, noth channels in the other trip system will be - OPERABLE, and actions to prevent preswrization of tha reactor vessei will be taken. Thus, based on the fact that no now onuipment failure modes are coing introduced as a result of the proposed waiver and the compensatory actions being implomonted, the proposed walvor dons not creato the possibliity of a now or d2ferbnt kird of accident. The proposed walvor to allow the performanco of surveillanco testing for excess flow check 3. valves B21-F042A, F0428, F044A, ar>1 F0440 and to upgrade the seismic qualification of instrument rack nos. P009 and P010 will reduce not sigrdficantly roduce thu marg!n of safety. Although the lovel of redundancy associated with the low pressuro ECCS actuation inMrumentation will be temporarily reduced during the excess flow check valve surveillance tor:ing, at least one low pressuro ECCS actuation instrumentation channel will remain OPERABLE ir each actuation trip system and will be capable if initiating low pressure coolant injection, if nooded, in the ovent of a loss of coolant accidea. In OPERATIONAL CONDITION 4, the rate of coolant inventory loss from the unprossurized reactor vessel would be significantly less than during full power operation. Nevertheless, during the period of tirne when this surveillance testing is being parformed, other reactor vessel water level instrumentation alarms and trips would occur and provide the operator sufficient timo to manually initiats the to v pressure ECCS systems prior to the reactor coro becoming uncovered. Furthermore, during the testing, operations with the i potential to drain the reactor vessel wil not be performed. Lunng (no planned instrument rack modifications, one channel of the two injection permissive trip systems will be lonwable. The planned compensatory action of placing the affected injection permissivo cnannel in the condition that satisfies the logic will ensure the capability to actuato and inject low pressure ECCS, if required. In addition, the planned compensatory action of opening the reactor head vent will ensure that the reactor vessel cannot pressurize and thereby inhibit the capability of the low pressure ECCS to injact during a loss of coolant accident in CT"IRATIONAL CONDITION 4. I Therefore, based on the actua? capabity of tha low pressure ECCS systems to inject, if required, l a 'ho compensatory actions being taken, the proposed waiver does not involve a significant to ation in a margin of safety. i i L ENVIRONMENTAL EVALUATION: f 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions oligible for categorical exclusion from performing an environmental asaestment. Carolina Power & Light Company has revlowed this request and deformined that it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 50,91(c)(9) ano u.at this (nouest does not involve irreversible environmental E1-7 3 -- ~
consequences. Pursuant to 10 CFR St.22(b), no onvironmental Impact statomont or environmenta! ' essessmont noods to be prepared in ccenoction with granting of tho temporary walvar of compliance. The basis for this dotormination h as fo ows. As demonstrated in the above significant hazards u.1alyris, the proposed walvor does not involvo 1. a significant hazards consideration. me proposed walvor does not result in a significant change in the types or significant increase 2. in tho' amounts of any offluent that may be rt eased offsito, The proposed walvor does not introduce any nov' equipment ncr does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform. During normal plant oporation, the reactoi vowel water level - low lovel 3 and reactor steam dome pressure - low Ir.strumentation are not used as control systems nor for performance mooltoring indications althougn they are required to be operable. The prirr.ary function of this instrumentation h during upsot and accident conditions where additional reactor vessel coolant inventory is required by providing automatic actuatlon of the low piessure ECCG rnd in:11 biting the opening of the injection valves until the pressure lu the reactor vessel is sutticiently low enough to ensure coolant injection by the law pressuro ECCS. The proposed walver will not alter the function of this instrumentation and componsatory actions will ensure that the consequences of any previously evaluated accident do not inc< ease. Thoroforo, it is concluded that there will not be a significant increase the types or amounts of any emuont that may be roloased offsito and. as such, does not involve irreversible environmental consequences beyond those already assriciated with normal operation. The proposed walvor does not roso:t in a significant liicreaso in individual or cumulative 3. occupatlanal radiation exposure. I 1 E14
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