BSEP-95-0112, Forwards Supplemental Info Re 931028 Request for License Amends to Increase Instrument Surveillance Test Intervals & Allowable out-of-svc Times Addressed in TS 3/4.3,as Result of Discussions W/Nrc During 950208 Meeting & 950216 Telcon
| ML20081H537 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/22/1995 |
| From: | Cowan J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20081H541 | List: |
| References | |
| BSEP-95-0112, BSEP-95-112, NUDOCS 9503240279 | |
| Download: ML20081H537 (5) | |
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CP&L l
& Light Company John Paul Cowan l
PO Box 10429 Director - Site Operations l
Southport NC 28461 Brunswick Nuclear Plant
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910 457-2496 MAR 221995 SERIAL: BSEP 95-0112 10 CFR 50.90 l
TSC 94TSB04 i
U. S. Nuclear Regulatory Commission l
ATTN: Document Control Desk I
(
Washington, DC 20555 l
l BRUNSWICK NUCLEAR PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENTS j
INCREASED INSTRUMENT SURVEILLANCE TEST INTERVALS AND ALLOWABLE OUT OF-SERVICE TIMES - SUPPLEMENTAL INFORMATION
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l Gentlemen:
r On October 28,1994, Carolina Power & Light Company (CP&L) submitted license amendment requests for CP&L's Brunswick Steam Electric Plant, Units 1 and 2. The i
proposed amendments would increase the surveillance test intervals and allowable out of I
service times for selected instrumentation addressed in Section 3/4.3 of the Technical Specifications.
1 On February 8,1995, CP&L, General Electric Company, and members of the NRC staff l
met to discuss the proposed amendment request. On February 16,1995, a telecon was held to further discuss certain items addressed at the February 8 meeting. Enclosure 1 documents supplementalinformation provided to the NRC staff as a result of those discussions. Enclosure 2 provides the typed pages for Brunswick Unit 1. Enclosure 3 provides the typed pages for Brunswick Unit 2. Editorial corrections have been made to several pages (i.e., insertion of missing words such as "of" or "the") being changed as a l
result of this amendment request. Neither the editorial changes nor the supplemental l
information provided herein affect the conclusions of the significant hazards consideration
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provided in the October 28,1994 letter.
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Please refer any questions regarding this submittal to Mr. R. P. Lopriore at (910) 457-2212.
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Sincerely, 0-
- 2 John Paul Cowan l
KAH/
l Enclosures j
i 24008.3 9503240279 950322
- g, PDR ADOCK 0500 4
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Document Control Desk BSEP 95-0112 / Page 2 l
John Paul Cowan, 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 &
l Light Company.
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Ob/k 0
r Notary (Seal)
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My commission expires-
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Mt Eqnmission bpires August 21,,1993 i
cc:
Mr. D. H. Brown, State of North Carolina i
Mr. S. D. Ebneter, Regional Administrator, Region 11 Mr. C. A. Patterson, Brunswick NRC Senior Resident inspector.
Mr. D. C. Trimble,.Jr., Acting NRR Project Manager - Brunswick Units 1 and 2 l
The Honorable H. Wells, Chairman - North Carolina Utilities Commission L
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 AND 2 NRC DOCKETS 50-325 & 50-324 i
OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENTS.
INCREASED INSTRUMENT SURVEILLANCE TEST INTERVALS AND ALLOWABLE OUT-OF-SERVICE TIMES' SUPPLEMENTAL INFORMATION Backaround On October 28,1994, Carolina Power & Light Company (CP&L) submitted license amendment requests for CP&L's Brunswick Steam Electric Plant, Units 1 and 2. The proposed amendments would increase the surveillance test intervals and allowable out of service times for selected instrumentation addressed in Section 3/4.3 of the Technical i
Specifications.
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On February 8,1995, CP&L, General Electric Company, and members of the NRC staff met to discuss the proposed license amendment request. On February 16,1995, a telecon
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was held to further discuss certain items addressed at the February 8 meeting. The i
specific items addressed herein are:
1)
With respect to calculated drift for the instrumentation that may result from the proposed amendment request: 1) provide the percentage of data point
" outliers," 2) provide the criteria for determining outlyers,3) provide the source document for the criteria used in determining the outlyers. Also provide justification for acceptability of the outlyers.
2)
For item 18 of Enclosure 1 to the October 28,1994 submittal, identify which
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specific functions were revised to include a check for loss of function.
This enclosure documents the supplementalinformation provided to the NRC staff in i
response to the above items. This supplementalinformation does not affect the conclusions of the significant hazards consideration provided in the October 28,1994 letter.
Sucolemental Information Reauest - ltem 1
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With respect to calculated drift for the instrumentation that may result from the proposed amendment request: 1) provide the percentage of data point "outlyers," 2) provide the' criteria for determining outlyers,3) provide the source document for the criteria used in determining the outlyers. Also provide justification for acceptability of the outlyers.
CP&L Resoonse As a result of extending the surveillance test interval of selected instrumentation, the E1-1
l calibration interval for certain analog trip units is increased from weekly or monthly to quarterly. As noted in CP&L's October 28.1994 amendment request, General Electric Company (GE) performed a study to evaluate the impact of the change in calibration frequency on instrument drift. The analysis methods were developed as part of the GE j
instrument Setpoint Methodology program, documented in GE document NEDC 31336, l
" General Electric Instrument Setpoint Methodology," October 1986. As identified in the analysis methodology, identification of outlyers is based 'on a 3 standard deviation criteria.
The drift study performed for CP&L identified a worst-case percentage of outlyers (from a j
total population of over 700 data points) of approximately 1.4 percent (10 points).
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During the February 16 telecon, the NRC staff requested that the data points determined l
to be outlyers be confirmed to not affect the results of the drift study. To address this-
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j issue, GE recalculated the expected instrument drift with the outlyers included. By letter dated February 24,1995, GE informed CP&L that the inclusion of the outlier data points in the drift calculations did not affect the results of the original drift study; therefore, i
changing channel function test intervals and, where applicable, the analog trip unit.
calibration intervals from weekly or monthly to quarterly, will not result in excessive drift relative to current setpoints.
Sucolemental information Reauest - ltem 2 l
In the October 28,1994 submittal, CP&L noted in Enclosure 1, Page E1-7, Emergency Core Cooling System Actuation Instrumentation, under item 18, that revisions were being made to Table 3.3.3-1 Actions to include, depending on degree of redundancy, a check for i
loss of function and an allowable out-of-service time (AOT) for repair of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In the February 8,1995 meeting, the NRC staff requested CP&L to expand this item to include I
the specific functions being affected. Following is a more detailed description of the changes associated with item 18 on Page El-7:
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- 18. Revise and clarify Table 3.3.3-1 Actions to include, depending on degree of i
redundancy, a check for loss-of-function and an AOT for repair of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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Specifically, Actions 30 and 36 are revised, per Inserts 1C and 2C respectively, to i
require compensatory action within one hour when a loss-of-function condition exists i
and to allow up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to repair inoperable channels provided a loss-of-function condition does not exist. Revised Actions 30 and 36 are applicabi'e to the Trip l
Functions in Table 3.3.3-1, as noted below:
l Core Spray System a.
Item 1.a, Reactor Vessel Water Level - Low, Level 3 (No change, referenced j
Action remains 30) b.
Item 1.b, Reactor Steam Dome Pressure - Low (Referenced Action is changed from 31 to 30) c.
Item 1.c, Drywell Pressure - High (No change, referenced Action remains 30)
Low Pressure Coolant injection Mode of RHR System d.
Item 2.a Drywell Pressure - High (No change, referenced Action remains 30) e.
Item 2.b, Reactor Vessel Water Level - Low, Level 3 (No change, referenced Action remains 30) f.
Iterr. 2.d.1, Reactor Steam Dome Prescure - Low, RHR Pump Start and LPCI Injection Valve Actuation (Referenced Action is changed from 31 to 30)
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Item 2.d.2, Reactor Steam Dome Pressure - Low, Recirculation Loop Pump
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Discharge Valve Actuation (Referenced Action is changed from 31 to 30)~
High Pressure Coolant injection System h.
Item 3.a. Reactor Vessel Water Level - Low, Level 2 (No change, referenced Action remains 30) i.
Item 3.b, Drywell P. essure - High (No change, referenced Action remains 30)
Automatic Depressurization System j.
Item 4.a, ADS Inhibit Switch (No change, referenced Action remains 36) k.
Item 4.b, Reactor Vessel Water Level - Low Level 3 (Referenced Action is -
changed from 30 to 36) 1.
Item 4.c, Reactor Vessel Water Level - Low Level 1 (Referenced Action is changed from 30 to 36) m.
Item 4.d, ADS Timer (Referenced Action is changed from 31 to 36) n.
itam 4.e, Core Spray Pump Discharge Pressure - High (Referenced Action is j
changed from 31 to 36):
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item 4.f, RHR (LPCI MODE) Pump Discharge Pressure.High (Referenced Action is changed from 31 to 36) l I
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