BSEP-97-0012, Application for Amends to Licenses DPR-71 & DPR-62 to Incorporate New TS Which Applies to Condenser Vacuum Pump Isolation Instrumentation

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Application for Amends to Licenses DPR-71 & DPR-62 to Incorporate New TS Which Applies to Condenser Vacuum Pump Isolation Instrumentation
ML20136E776
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 03/05/1997
From: Campbell W
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20136E783 List:
References
BSEP-97-0012, BSEP-97-12, NUDOCS 9703130325
Download: ML20136E776 (11)
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% w .o CP&L Carolina Poww & Light Company William R. Campbell PO Box 10429 Vice President Southport NC 28461 Brunswick Nuclear Plant March 5,1997 SERIAL: BSEP 97-0012 10 CFR 50.90 TSC 96TSB12 U. S. Nuclear Regulatory Commission ATTN.: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENT CONDENSER VACUUM PUMP ISOLATION Gentlemen:

1 In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light (CP&L) Company hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. The proposed amendment i incorporates a new Technical Specification which applies to the condenser vacuum pump I isolation instrumentation. The proposed specification covers the use of the main steam line radiation monitor signals for a trip of the condenser vacuum pumps. In a letter dated February l 15,1997, CP&L committed to submit this amendment request by February 28,1997. In a telephone conversation with Mr. David Trimble of your staff on February 28,1997, it was agreed that the original committed date for this license amendment request would be changed to March 5,1997.

CP&L is providing, in accordance with 10 CFR 5').91(b), Mr. Mel Fry of the State of North Carolina with a copy of the proposed license a,nendments.

In order to allow time for procedure revision, orderly incorporation into copies of the Technical Srocifications, CP&L requests that the proposed amendment, once approved by the NRC, be is ad with an effective date of no later than 30 days from the date of issuance of the amendment. The associated main steam line radiation monitor m to the next reactor startup requiring operation of the condenser vacuum pumps. CP&L anticipates naving the modification prepared for installation by March 14,1997.

Please refer any questions regarding this submittal to Mr. Keith Jury, Manager - Regulatory Affairs, at (910) 457-2783.

bjf Sincerely, hY William R. Campbell 9703130325 970305 PDR ADOCK 05000324 P PDR u

  • < ,-y j Document Control Desk  !

BSEP 97-0012 / Page 2 MAT / mat

Enclosures:

1. Basis for Change Request
2. 10 CFR 50.92 Evaluation 3 Environmental Considerations
4. Page Change Instructions l
5. Typed Technical Specification and Bases Pages - Unit 1 '
6. Typed Technical Specification and Bases Pages - Unit 2
7. Control Room And Offsite Doses Due to a Rod Drop Accident William R. Campbell, having been first duly sworn, did depose and say that the information i 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 & Light l Company.

S.Yba' Notary (Seal)

My commission expires:k I 'J f 8001 pc: _ U. S. Nuclear Regulatory Commission ATTN.: Mr. Luis A. Reyes, Regional Administrator 4 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323-0199 Mr. C. A. Patterson NRC Senior Resident inspector - Brunswick Steam Electric Plant Units 1 and 2:

U.S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738 The Honorable J. A. Sanford Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Mel Fry Acting Director- Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

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u 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 REQUEST FOR LICENSE AMENDMENT CONDENSER VACUUM PUMP ISOLATION BASIS FOR CHANGES Backaround Carolina Power & Light (CP&L) Company requested a license amendment to eliminate the main steam line radiation monitor scram and line isolation functions on September 30,1994, as supplemented on March 24,1995. License amendments were issued on March 31,1995, for Brunswick Steam Electric Plant Units 1 (Amendment 176) and Unit 2 (Amendment 207). In part, these amendments eliminated the condenser vacuum pump trips and line isolation function of the main steam line radiation - high signal.

The condenser vacuum pumps are used only when the reactor is at low power (less than 5 percent) and there is insufficient steam flow to operate the steam jet air ejectors. Radioactivity transported to the condenser by the steam flow as a result of a control rod drop accident could be transported to the main stack by the condenser vacuum pumps. As part of the original justification for the elimination of the condenser vacuum pump trips and line isolation function of the main steam line radiation - high signal, CP&L contracted NUS to calculate (NUS Calculation 8T12-M-02) the potential dose received in the main control room assuming operator action to trip the condenser vacuum pumps and isolate the mechanical vacuum pump line is not taken until 10 minutes after a control rod drop accident. This calculation determined that the dose in the main control room, as a result of this accident, would be 27.2 rem thyroid and 0.18 rem whole body, which is less that the General Design Criterion (GDC) 19 / Standard Review Plan (SRP)

Section 6.4 limits of 30 rem thyroid and 5 rem whole body, in addition, the modification which eliminated the main steam line radiation monitor scram and isolation functions also provided a non-safety related, automatic trip of the condenser vacuum pumps and isolation of the vacuum pump line using the main stack radiation monitor.

On December 19,1996, CP&L determined that the calculation performed to support that change was in error. The calculation improperly assumed that the dose in the control room ended prior to completion of control room air filtration following a control rod drop accident. The calculation

- error involved only the control room dose calculation and is not a factor in the off-site dose calculation (NUS Calculation 8T12-M-01). In order to support resolution of this discrepancy, the condenser vacuum pump trip and isolation of the vacuum pump line functions of the main steam line radiation monitor - high radiation signal will be installed. This is consistent with the original Brunswick Steam Electric Plant design for condenser vacuum pump isolation. These modifications are expected to be prepared for installation by March 14,1997. CP&L willinstall E1-1

these modifications prior to the next reactor startup requiring operation of the condenser vacuum pumps for either unit.

Current Reauirement None.

Proposed Changa The proposed amendment incorporates a new Technical Specification 3/4.3.8, " Condenser Vacuum Pump Isolation Instrumentation." This specification will require that four channels of the  ;

main steam line radiation - high isolation function be capable of tripping the condenser vacuum l pumps and closing the associated isolation valve. This function will be required to be operable when the unit is in OPERATIONAL CONDITION 1 or 2 with any condenser vacuum pump in operation.

Basis for Prooosed Chang 2 The condenser vacuum pump isolation instrumentation willinitiate a trip of the two condenser vacuum pumps and closure of the associated line isolation valve following events in which the main steam line radiation monitors exceed a predetermined value. This function willinitiate an isolation of the condenser vacuum pump to limit main control room doses resulting from fuel cladding failure in the event of a control rod drop accident (CRDA), to less than those in the plant's licensing and design bases.

The condenser vacuum pump isolation function is required to be operable in OPERATIONAL CONDITIONS 1 and 2 when a condenser vacuum pump is in servY.e. A condenser vacuum pump is used only when the reactor is at low power (less than 5 percent) and there is insufficient steam flow to operate the steam jet air ejectors. As such, a condenser vacuum pump is normally in service for a very limited period of time. Additionally, a highly improbable combination of events is required for a control rod drop accident to occur. These events include the erroneous selection and withdrawal of an out of sequence rod by an operator, failure of the rod worth minimizer to block withdrawal of this out of sequence rod, and failure of the rod-to-drive coupling.

The rod worth minimizer forces adherence to established control rod patterns which ensure peak fuel enthalpies being less than the control rod drop accident design limit of 280 calories / gram.

A probabilistic safety analysis has been performed which determined that the probability of a design basis control rod drop event at the Brunswick Steam Electric Plant is less than 1 E-6 per reactor over a 40 year operating period. When a condenser vacuum pump is not in operation in OPERATIONAL CONDITIONS 1 or 2, fission product releases via this pathway would not occur due to lack of a motive force in this pathway, in OPERATIONAL CONDITIONS 3,4, or 5, the potential for and consequences of a control rod drop are insignificant and are not expected to result in any fuel damage or fission product releases.

Should a control rod drop accident occur when a condenser vacuum pump is operating, fission products transported to the condenser by the steam flow could be transported to the main stack via the pump and subsequently released to the environment. The condenser vacuum pump trip assures conformance with the radiological evaluation of the control rod drop accident at less than 5% power. The safety-related main steam line radiation monitors provide a highly reliable means to detect radioactivity resulting from a control rod drop accident and will provide an automatic trip E1-2

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l of the respective condenser vacuum pump and closure of the associated isolation valve. The l main steam line radiation - high logic for condenser vacuum pump trip and line isolation will l consist of two independent trip systems, each with two channels. Each trip system will be a one- l out-of-two logic fur this function. Thus, either channel will trip a trip system. The outputs of the l channels will be arranged in a logic so that both trip systems must trip to result in an isolation i signal. Use of the main steam line radiation monitors for this application is consistent with the i original plant design for a condenser vacuum pump trip and line isolation.  !

Prior to elimination of the condenser vacuum pump trips and line isolation function of the main i steam line radiation - high signal, the design for this function included redundant safety-related I initiation logic up to the actuating relay for the condenser vacuum pump trip and associated isolation valve. The original design was not single failure proof nor safety-related downstream of the initiation logic. Section 15.3.1, Table 15-3, of the NRC Safety Evaluation of the Brunswick Steam Electric Station Units 1 and 2, dated November 1973, assumed, for the control rod drop accident, that the condenser vacuum pump stopped on a high radiation signal. In the evaluation, the assumptions used recognized that isolation valves closed within 5 seconds of the main steam radiation - high signal. This assumption refers to the main steam isolation valves which l were required by Technical Specifications to close within 5 seconds. The methodology used in the analysis to support original plant design, as well as the attached analysis, does not credit main steam isolation valve closure. The design of the Brunswick Steam Electric Plant condenser vacuum pumps is such that the pumps stop in less than 5 seconds following a trip signal, thus terminating the release. Successful pump tripping within this time frame will ensure that doses remain below regulatory and licensing limits.

In addition to the mechanical vacuum pump trip, an isolation signal will be provided to the ,

condenser vacuum pump suction valve. This signal, coupled with the pump trip signal, will restore the line isolation function to a configuration consistent with original plant design. Isolation of this valve is not credited for control rod drop accident mitigation in the Final Safety Analysis Report or the Updated Final Safety Analysis Report accident analyses; however, valve isolation does provide additional assurance that this flow path will be isolated.

CP&L contracted Scientech-NUS to recalculate the main control room operator doses resulting from a control rod drop accident, assuming the main steam line radiation monitors isolate the condenser vacuum pumps, based on the assumptions given for control rod drop accidents in Section 15.4.9 of the Standard Review Plan (this calculation is included as Enclosure 7). The calculation conservatively assumes no credit for fission product inventory decay from the time of shutdown until the time of the accident (i.e., the fission product activity during start-up is equivalent to that for prolonged operation at 100 percent of power). The main control room operator doses from a postulated CRDA are 23.2 rem thyroid and 0.05 rem whole body, which are less than the GDC-19 / SRP Section 6.4 limits of 30 rem thyroid and 5 rem whole body. The exclusion area boundary 2-hour doses were calculated to be 0.16 rem thyroid and 0.015 rem whole body. The low population zone (LPZ) doses were estimated to be approximately 1 rem thyroid. Therefore, the offsite dosca are well below the acceptance criteria contained in the SRP and 10 CFR Part 100.

The logic change being implemented by the main steam line radiation monitor isolation will impose an automatic trip of the condenser vacuum pumps upon receipt of a main steam line radiation - high signal. CP&L has completed a calculation of the trip setpoint and allowable value for this function based on our instrument setpoint methodology. The instrument setpoint methodology is based on the guidance of ISA Recommended Practice ISA-S67.04 Parts I and 11,

" Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation,"

September 1994. The allowable value was established for this function by combining the errors E1-3

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associated with channel / instrument calibration (e.g., device accuracy, setting tolerance, and drift) with the calculated nominal trip setpoint. The allowable value determinations were made using ,

vendor documented performance specifications.

l The setpoint for this function was established by accounting for the applicable instrument accuracy, calibration and drift uncertainties, environmental effects, power supply fluctuations, as well as uncertainties related to process and primary element measurement accuracy as defined in the our setpoint methodology. Plant calibration procedures will ensure that the assumptions regarding calibration accuracy, measurement and test equipment accuracy, and setting tolerance l are maintained. The trip setpoint for this function is considered to be an operational detail not I directly related to the operability of the instrumentation; therefore, the setpoint is not being included in the proposed specification. The allowable value is considered the required limitation for this function; therefore, this value has been incorporated into the proposed specification. Use of our setpoint methodology for determining the allowable value and instrument setpoir.t and analyzing channel / instrument performance ensures that GDC-19 limits for control room operator dose will not be exceeded for the design basis control rod drop accident.

1 The proposed Technical Specifications for the condenser vacuum pump isolation instrumentation  !

reflect the analyses discussed above. The proposed ACTIONS for the condenser vacuum pump )

isolation instrumentation provide a limited time (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) for restoration or tripping of inoperable  !

channels (or the associated trip system). This time period is only provided when condenser vacuum pump isolation capability is maintained. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowable out-of-service time for i the main steam line radiation - high function was shown to be acceptable in NEDC-30851P-A I Supplement 2, Technical Specifications improvement Analyses for BWR isolation Instrumentation Common to Reactor Protection System and Emergency Core Cooling System Instrumentation, dated March 1989. In addition, this allowable out-of-service time is consistent with that previously approved for the main steam line radiation - high function in Amendments 175 and 206 for Brunswick Steam Electric Plant Units 1 and 2, respectively. If the required action and associated completion time cannot be met or if condenser vacuum pump isolation capability is not maintained, ACTIONS require the respective Unit be brought to an operating  !

condition in which the Limiting Condition for Operation (LCO) does not apply. To achieve this, the unit must be placed in OPERATIONAL CONDITION 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Alternatively, the condenser vacuum pump can be removed from service since this performs the intended function of the instrumentation. An additional option is provided to isolate the main steam lines. Isolation of the main steam lines effectively provides an equivalent level of protection by precluding fission product transport to the condenser. Based on operating experience, an allowed completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable to reach OPERATIONAL CONDITION 3 from full power conditions, or to remove the condenser pump from service in an orderly mannar and without challenging plant systems. An ACTION is also provided to allow, when a channelis placed in an inoperable status for the performance of Surveillances, entry into the associated ACTIONS be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated function maintains condenser vacuum pump isolation capability.

This allowance is based on the reliability analysis in NEDC-30851P-A Supplement 2 for the main steam line radiation - high function. This analysis demonstrated that this testing allowance does not significantly reduce the probability that the condenser vacuum pumps will isolate when necessary. In addition, this allowance is consistent with that previously approved for the main steam line radiation - high function in Amendments 175 and 206 for Brunswick Steam Electric Plant Units 1 and 2, respectively.

Appropriate CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, CHANNEL CAllBRATION, and LOGIC SYSTEM FUNCTIONAL TEST requirements are being provided to ensure the condenser vacuum pump isolation instrumentatio,1 will perform the intended function. These Surveillance Requirements are consistent with the Surveillance Requirements previously provided for the E1-4

e, main steam line radiation - high function after the implementation of Amendments 175 and 206 for Brunswick Steam Electric Plant Units 1 and 2, respectively.

= CP&L believes that the proposed LCO, Action Statements, and Surveillances provide appropriate operational restrictions to maintain consistency with the control rod t.ap accident analysis. In addition, the proposed specification is consistent with specifications for the condenser vacuum

. pump instrumentation previously provided to the Nuclear Regulatory Commission (NRC) staff by the Boiling Water Reactor Owners' Group during the development of the improved Standard Technical Specifications.

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i j ENCLOSURE 2

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 l NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 i REQUEST FOR. LICENSE AMENDMENT j

! CONDENSER VACUUM PUMP ISOLATION .I I

j- 10 CFR 50.92 EVALUATION .

! = The Nuciear Regulatory Commission (NRC) has provided standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists. A proposed amendment to an

, operating license for a facility involves no significant hazards consideration if operation of the

} . facility in accordance with the proposed amendment would not: (1) involve a significant increase

in the probability or consequences of an accident previously evaluated, (2) create the possibility b of a new or different kind of accident from any accident previously evaluated, or (3) involve a

, significant reduction in a margin of safety. Carolina Power & Light (CP&L) Company has i'

reviewed these proposed license amendment requests and believes that their adoption would not involve a significant hazards consideration. The basis for this determination follows.

. 1. The proposed amendments do not involve a significant increase in the probability or l consequences of an accident previously evaluated.

! . The proposed change incorporates a new Technical Specification 3/4.3.8, " Condenser

, Vacuum Pump Isolation Instrumentation." This specification will require that the main steam line radiation - high isolation function be capable of tripping the condenser vacuum pump (s) and isolate the associated common isolation valve. Four instrumentation

channels of this function are required to be operable when the unit is in OPERATIONAL 1 CONDITION 1 or 2 with a condenser vacuum pump in operation. Adding the requirement j to trip the condenser vacuum pumps does not affect the probability of an accident 2

previously evaluated. The probability of component failure of the proposed design for L condenser vacuum pump isolation devices is the same as_ that of the originallicensing i basis.~ As a result, the capability to isolate the condenser vacuum pump will not be significantly impacted.

i' CP&L contracted Scientech-NUS to recalculate the main control room doses resulting from

, a control rod drop accident assuming main steam line radiation monitors isolate the condenser vacuum pump (s) and determined the dose to be 23.2 rem thyroid and 0.05 rem I whole body, which is less than the General Design Criterion (GDC) 19 / Standard Review i Plan (SRP) Section 6.4 limits of 30 rem thyroid and 5 rem whole body. The offsite doses l at the exclusion area boundary after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are 0.16 rem thyroid and 0.015 rem whole

body, which is less than the SRP Section 15.4.9 limits. The let, population zone (LPZ)

! dose is estimated to be about i rem thyroid, which is also wel! below regulatory limits.

l-Therefore, the proposed amendment does not increase the consequences of an accident 4 previously evaluated.

2. The proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

i ' The proposed amendment adds new requirements to ensure the capability to trip the-j- condenser _ vacuum pump (s). The proposed change does not affect the operability of equipment designed to mitigate the consequences of an accident nor does.it create a j 4

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potential to initiate a new type of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed license amendment does not involve a significant reduction in a margin of safety.

The safety-related main steam line radiation monitors provide a highly reliable means to '

detect radioactivity resulting from a control rod drop accident and will provide automatic trip of the condenser vacuum pumps and isolation of the associated isolation valve. Use of the main steam line radiation monitors for this application is consistent with the original
Brunswick Steam Electric Plant design for condenser pump and associated valve isolation.

,.. CP&L contracted Scientech-NUS to recalculate the main control room doses resulting from i a control rod drop accident assuming main steam line radiation monitors isolate the I condenser vacuum pump (s) and determined it to be 23.2 rem thyroid and 0.05 rem whole body, which is less than the GDC 19 / SRP Section 6.4 limits of 30 rem thyroid and 5 rem ,

whole body. The offsite doses at the exclusion area boundary after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are 0.16 rem '

thyroid and 0.015 rem whole body, which is less than the SRP Section 15.4.9 limits. LPZ dose is estimated to be about i rem thyroid, which is also well below regulatory limits.

' Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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4 i ENCLOSURE 3

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

NRC DOCKET NOS. 50-325 AND 50-324 i __ OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENT 2 ' CONDENSER VACUUM PUMP ISOLATION ENVIRONMENTAL CONSIDERATIONS 1

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i 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if j operation of the facility in accordance with the proposed amendment would not: (1) involve a

. significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power & Light (CP&L) j- Company has reviewed this request and believes that the proposed amendments. meet the 1 eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). In accordance with to

10 CFR 51.22(b), no environmental impact statement of environmental assessment needs to be

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. prepared in connection with the issuance of the amendment. The basis for this determination follows.

l l 1. These amendment does not involve a significant hazards consideration, as shown in y Enclosure 2.

l 2. The proposed license amendment does not result in a significant change in the types or a

, significant increase in the amounts of any effluent that may be released offsite. A condenser vacuum pump is used only when the reactor is at low power (less than l 5 percent) and there is insufficient steam flow to operate the steam jet air ejectors.

i Radioactivity transported to the condenser by the steam flow as a result of a control rod drop accident could be transported to the main stack by a condenser vacuum pump. The j safety-related main steam line radiation monitors provide a highly reliable means to detect-the release of fission products resulting from a control rod drop accident and will provide automatic trip of the condenser vacuum pumps. Offsite doses resulting from the control rod drop accident are calculated to be well below regulatory limits.

! 3. These amendments do not result in an increase in individual or cumulative occupational l radiation exposure. CP&L contracted Scientech-NUS to recalculate the main control room doses resulting from a control rod drop accident assuming main steam line radiation

monitors isolate the condenser vacuum pump (s) and determined the dose to be 23.2 rem l thyroid and 0.05 rem whole body, which is less tlan the General Design -
, Criterion (GDC) 19 / Standard Review Plan (SRP) Section 6.4 limits of 30 rem thyroid and 5 rem whole body. l

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