BSEP-97-0120, Application for Amends to Licenses DPR-71 & DPR-62,revising Definitions for ECCS Response Time,Isolation Sys Response Time & Reactor Protection Sys Response Time

Application for Amends to Licenses DPR-71 & DPR-62,revising Definitions for ECCS Response Time,Isolation Sys Response Time & Reactor Protection Sys Response Time

ML20137K877
Person / Time
Site:	Brunswick
Issue date:	03/24/1997
From:	Campbell W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137K882	List: BSEP-97-0120, Application for Amends to Licenses DPR-71 & DPR-62,revising Definitions for ECCS Response Time,Isolation Sys Response Time & Reactor Protection Sys Response Time ML20137K902
References
BSEP-97-0120, BSEP-97-120, NUDOCS 9704070117
Download: ML20137K877 (12)

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L 9' f CP&L Corolmo Power & Light Company William R. Campbell

PO Box 10429 Vice President Southport NC 28461 Brunswick Nuclear Plant SERIAL: BSEP 97-0120 10 CFR 50.90 TSC 97TSB05 March 24,1997 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 EMERGENCY / EXIGENT LICENSE AMENDMENTS INSTRUMENTATION RESPONSE TIME TESTING Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, F 150.90 and 2.101, Carolina Power & Light (CP&L) Company is requesting a revision to the lechnical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These proposed amendments revise the definitions for EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME, ISOLATION SYSTEM RESPONSE TIME, and REACTOR PROTECTION SYSTEM (RPS)

RESPONSE TIME. These definitions are located in Section 1.0 of the BSEP Technical Specifications. A discussion of the proposed changes, the bases for CP&L's determination that the proposed changes do not involve a significant hazards consideration, and an environmental evaluation are enclosed.

On March 21,1997., CP&L submitted a request for enforcement discretion (BSEP 97-0117) in anticipation that regulatory relief would be required for response time testing of ECCS, RPS, and Isolation System instrumentation. Subsequently, CP&L verbally requested enforcement discretion. BSEP Unit Nos.1 and 2 entered shutdown ACTON statements at 2116 and 2115, Eastern Standard Time (EST), respectively. On March 21,1997, at 2136 EST, the NRC staff verbally granted the request. A revised request for enforcement discretion was se'omitted, via facsimile, on March 22,1997 (BSEP 97-0119). CP&L determined that this revised request was inadvertently dated as March 21,1997, versus March 22,1997, when the revised request was prepared and submitted. The date was corrected in the copy of letter BSEP 97-0119 which has been sent to the Document Control Desk. In accordance with NRC insr'sction Manual, Part 9900, this license amendment request is being submitted within 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> following the March 22,1997, wntten request for enforcement discretion.

This license amendment request meets the requirements of 10 CFR 50.91 for both emergency /

and exigent processing because failure to act before the discretionary enforcement expires

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Document Control Desk BSEP 97-0120 / Page 2 i would result in an unnecessary shutdown of BSEP Unit Nos.1 and 2. Additionally, the proposed amendments do not involve a significant hazards consideration. Therefore, CP&L requests emergency or exigent processing of this license amendment request. A more cornplete discussion of the bases for emergency / exigency is provided in Enclosure 1.

Carolina Power & Light Company is providing, in accordance with 10 CFR 50.91(b), Mr. Mel Fry of the State of North Carolina with a copy of the proposed license amendments. ,

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

Sincerely, h 9n -

William R. Campbell WRM/wrm

Enclosures:

1. Bases for Change Request

2. 10 CFR 50.92 Evaluation

3. Environmental Considerations

4. Page Change Instructions  :

5. Marked-up Technical Specification Pages - Unit 1

6. Marked-up Technical Specification Pages - Unit 2

7. Typed Technical Specification Pages - Unit 1

8. Typed Technical Specification Pages - Unit 2 William 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 & Light Company.

. IAm- 7 Notary (Seat)

My commission expires: b i3, Goo [

Document Control Desk BSEP 97-0120 / Page 3 pc (with enclosures):

U. S. Nuclear Regulatory Commission ATTN.: Mr. Luis A. Reyes, Regional Administrator 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323-0199 U. S. Nuclear Regulatory Commission 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) 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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ENCLOSURE 1 ,

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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 EMERGENCY / EXIGENT LICENSE AMENDMENTS {

4 INSTRUMENTATION RESPONSE TIME TESTING SASES FOR CHANGES  ;

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) Summarv ,

This license amendment request is associated with a request for enforcement discretion for the {

' Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2, submitted on March 22,1997  !

(Serial: BSEP 97-0119). The enforcement discretion was requested in order to permit 4

continued operation without completion of instrumentation response time testing, as currently l l defined in the Technical Specifications, for the Reactor Protection System (RPS), Emergency i t

i Core Cooling System (ECCS), and Isolation System actuation instrumentation. Carolina Power 1- & Light (CP&L) Company determined that these instruments were inoperable because response time surveillance testing, required by Technical Specifications 4.3.1.3,4.3.2.3,

l and 4.3.3.3, has not been performed in accordance with the instrumentation response time testing definitions contained in Section 1.0 of the BSEP Technical Specifications. Enforcement i

} discretion was verbally granted by the NRC staff at 2136 Eastern Standard Time (EST) on l March 21,1997, in a telephone conference with the NRC. .

Current Reouirement 4

Technical Specification Section 1.0 includes the following defined terms:  !

EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME j The EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME shall be that i time interval from when the monitored parameter exceeds its ECCS acttation setpnint at the channel sensor until the ECCS equipment is capable of performing its tafety function I (i.e., the valves travel to their required positions, pump discharge pressures aach their required values, etc.). Times shall include diesel generator starting and sequt.nce loading delays where applicable.

l ISOLATION SYSTEM RESPONSE TIME l

, The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when tha 1 monitored parameter exceeds its isolation actuation setpoint at the channel sensor unic' the isolation valves travel to their required positions. Times shallinclude diesel generat'

• l starting and sequence loading delays where applicable.

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. 1 REACTOR PROTECTION SYSTEM RESPONSE TIME The REACTOR PROTECTION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids.

Instrumentation response time testing is conducted within the required surveillance frequencies for the instrument functions listed in BSEP Technical Specification Tables 3.3.1-1,3.3.2-1, and 3.3.3-1. Technical Specification 4.0.3 states that performance of a Surveillance Requirement within the specified time interval constitutes compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated ACTION statements unless otherwise required by the specification. If Surveillance Requirements have not been performed, the licensee must comply with the appropriate ACTION statements.

Technical Specification 4.3.1.3 states the following:

The REACTOR PROTECTION SYSTEM RESPONSE TIME of each reactor trip function" shall be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function.  !

' Neutron detectors are exempt from response time testing.

Technical Specification 4.3.2.3 states the following:

. The ISOLATION SYSTEM RESPONSE TIME of each isolation function

• shall be demonstrated to be within its limit at least once per 18 months. Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific isolation function.

" Radiation monitors are exempt from response time testing.

Technical Spec 9ation 4.3.3.3 states the following:

The ECCS RESPONSE TIME of each ECCS function shall be demonstrated to be within the limit at least once per 18 months. Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months, where N is the l total number of redundant channels in a specific ECCS function.

Proposed Chanae The definition for EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME would be revised as follows:

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The EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS actuation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shallinclude diesel generator starting and sequence j loading delays where applicable. In lieu of the methodology defined above, the ECCS >

RESPONSE TIME may also be determined using an alternate methodology that has l been reviewed and approved by the NRC. l The definition for ILOLATION SYSTEM RESPONSE TIME would be revised as follows:

1 The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation actuation setpoint at the channel sensor until the isolation valves travel to their required positions. Times shall include diesel generator starting and sequence loading delays where applicable. In lieu of the methodology defined above, the ISOLATION SYSTEM RESPONSE TIME may also be determined using an alternate methodology that has been reviewed and approved by the NRC.

The definition for REACTOR PROTECTION SYSTEM RESPONSE TIME would be revised as follows:

The REACTOR PROTECTION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. In lieu of the rnethodology defined above, the REACTOR PROTECTION SYSTEM RESPONSE TIME may also be determined using an alternate methodology that has been reviewed and approved by the NRC.

Bases For Proposed Chance in a letter dated April 14,1994 (Serial: BSEP 94-0139), as supplemented by letter dated May 16,1994 (Serial: BSEP 94-0181), CP&L submitted a license amendment request to the BSEP Technical Specifications to relocate the Technical Specification instrument response tables to the Updated Final Safety Analysis Report (UFSAR)in accordance with NRC Generic Letter 93-08. The license amendment request was approved on May 31,1994 as Amendment Nos.171 and 202 to Facility Operating Licenses DPR-71 and DPR-62, respectively.

In a letter dated December 28,1994, the NRC documented its review and acceptance of the BWR Owners' Group Licensing Topical Report NEDO-32291-A, " System Analyses For The Elimination of Selected Response Time Testing Requirements." This report justifies the elimination of selected response time testing requirements. The report identifies the specific response time testing requirements that were approved for elimination. Subsequent to relocation of the affected instrument response time tables to the UFSAR, CP&L implemented the NEDO-32291-A testing methodology via the 10 CFR 50.59 review process.

On March 21,1997, the NRC notified CP&L of an issue documented in a letter sent to Washington Nuclear Power Unit 2 (WNP-2) on March 20,1997, regarding compliance with the Technical Specification definition for instrumentation response time testing. The Technical Specifications define response time as the time interval from when the monitored parameter E1-3

I exceeds its isolation actuation setpoint at the channel sensor until the required safety function has occurred. As such, verbatim compliance with the Technical Specification definition of  ;

response time for the affected instrumentation includes the sensor. However, response time l testing of some sensors, components, and systems was eliminated through implementation of ]

the NEDO-32291-A repM. CP&L reviewed this issue and determined that it is applicable to l BSEP Unit Nos.1 and 2. The equipment in question are sensors associated with the RPS, Isolation System, and ECCS actuation instrumentation. {

This situation does not present a safety concern because qualitative response time testing of  !

the RPS, Isolation System, and ECCS actuation instrumentation has been completed in l accordance with NEDO-32291-A, approved by the NRC in a letter dated December 28,1994. l This provides assurance of equipment operability. These components are also subject to - 1 periodic functional testing by channel functional testing and logic system functional testing. No  ;

failure mechanism has been identified that results in response time degradation for these j components that can be detected by response time testing that cannot also be detected by the other Technical Specification required testing. Determination of response times in accordance .

with the alternate methodology in NEDO 32291-A ensures that the RPS, Isolation System, and  ;

ECCS actuation instrumentation are capable of performing their intended functions within j designed response times.  ;

The proposed amendments revise the o'efinitions of ECCS, RPS, and Isolation System )

response times to allow the determination of response times using an alternate methodology j that has been previously reviewed and approved by the NRC (e.g., NEDO-32291-A, " System Analyses For The Elimination of Selected Response Time Testing Requirements"). l, The proposed amendments also revise the Bases for Technical Specifications 3/4.3.1 Reactor f Protection System instrumentation 3/4.3.2 Isolation Actuation instrumentation, and 3/4.3.3 l Emergency Core Cooling Actuation Instrumentation. These Bases changas indicate that l NEDO-32291-A is an NRC approved methodology for elimination of response time testing {

requirements at BSEP. .

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Bases For Emercenev/Exiaency CP&L could not reasonably have taken action to avoid this situation. On March 21,1997, the {

, NRC formally notified CP&L of the potential for a Technical Specification compliance issue as j documented in a letter sent to Washington Nuclear Power Unit 2 (WNP-2) on March 20,1997. ]

CP&L reviewed this issue and determined that it was also applicable to response time testing of ECCS, RPS, and Isolation System instrumentation for BSEP Unit Nos.1 and 2. Failure to satisfy the response time testing specified in Technical Specifications 4.3.1.3,4.3.2.3, and 4.3.3.3 requires that the applicable systems be declared inoperable. On March 21,1997, CP&L submitted a request for enforcement discretion (BSEP 97-0117)in anticipation that regulatory relief would be required for response time testing of ECCS, RPS, and Isolation System instrumentation. Subsequently, CP&L verbally requested enforcement discretion and on March 21,1997, at 2136 EST, the NRC staff verbally granted the request. A revised request for enforcement db::retion was submitted on March 22,1997 (BSEP 97-0119).

This license amendment request meets the requirements of 10 CFR 50.91 for both emergency and exigent processing because failure to act before the discretionary enforcement expires would result in an unnecessary shutdown of BSEP Unit Nos.1 and 2. Additionally, the l E1-4

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proposed amendments do not involve a significant hazards consideration. Therefore, CP&L f requests emergency or exigent processing of this license amendment request. l

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1. BWR Owners' Group Licensing Topical Report NEDO-32291-A," System Analyses For i The Elimination of Selected Response Time Testing Requirements." l

2. Amendment Nos.171 and 202 to Facility Operating Licenses DPR-71 and DPR-62, l May 31,1994, i

3. NRC Generic Letter 93-08, " Relocation of Technical Specification Tables of Instrument  !

Response Time Limits." December 29,1993. -);

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s ENCLOSURE 2 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 EMERGENCY / EXIGENT LICENSE AMENDMENTS INSTRUMENTATION RESPONSE TIME TESTING 10 CFR 50.92 EVALUATION The 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 of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant '

reduction in a margin of safety. CP&L has reviewed these proposed license amendment requests and concluded that their adoption does not involve a significant hazards consideration. i The bases for this determination follows.

1. The proposed license amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated. BWR Owners' Group Licensing Topical Report NEDO-32291-A demonstrates that quantitative response time testing is redundant to other Technical Specification requirements. Qualitative tests are sufficient to identify failure modes or degradation in instrument respor'se time and ensure operation of the associated systems within acceptance limits. There art no known failure modes that can be detected by response time testing that cannot also be detected by other l Technical Specification required tests. ECCS, RPS, and Isold on System response times will continue to be determined using a methodology tha: has been reviewed and approved by the NRC. Therefore, the proposed license amendments do not involve a significant increase in the probability or consequences of an accident mviously evaluated.

2. The proposed license amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed license amendments do not affect the capability of the associated systems to perform their intended function within the acceptance limits assumed in the plant safety analyses and required for successful mitigation of an initiating event. The proposed amendments do not change the way in which any plant systems are operated. ECCS, RP,S, and Isolation System response times will continue to be determined using a methodology that has been reviewed and approved by the NRC. Therefore, the proposed amendments do not create the possibility of a new or different kind of accident.  ;

3. The proposed license amendments do not involve a significant reduction in a margin of l safety. The current Technical Specification response times are based on the maximam allowable values assumed in the plant safety analyses. These analyses conservatively E2-1 l

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establish the margin of safety. As described above, determination of response times  !

based on an alternate NRC approved methodology (i.e., provided in the NEDO-32291-A l report) will not affect the capability of the associated systems to perform their intended {

i function within the allowed response time used as the bases for the plant safety. i erialyses. Plant and system response to an initiating event will remain in compliance with  !

the assumptions of the safety analyses; therefore; the margin of safety is not affected.  ;

i Based on the above, CP&L concludes that the proposed license amendments do not involve a t significant hazards consideration. CP&L has also concluded that the proposed amendments do  ;

i not involve an unreviewed safety question based on the 10 CFR 50.59' evaluation that was j prepared for the implementation of NEDO 32291-A.  !

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l ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-37'5 AND 50-324 I

OPERATING LICENSE NOS. CPR-71 AND DPR-62 REQUEST FOR EMERGENCY / EXIGENT LICENSE AMENDMENTS INSTRUMENTATION RESPCNSE TIME TESTING  ;

ENVIRONMENTAL CONSIDERATIONS 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 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. CP&L has reviewed this request and concluded that the proposed amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental i impact statement of environmental assessment needs to ee prepared in connection with the issuance of these amendments. The bases for this determeation follows.

1. The proposed license amendments do not involve a signifiwnt hazards consideration, as shown in Enclosure 2.

2. The proposed license amendments do not result in a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite. The proposed license amendments do not introduce any new equipment nor does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The proposed license amendments do not alter the function of existing equipment and will ensure that the consequences of any previously evaluated accident do not increase. Therefore, CP&L has concluded that there will not be a significant increase in the types or amounts of any effluent that may be released  !

offsite and, as such, does not involve irreversible environmental consequences beyond those already associated with normal operation.

3. The proposed hcense amendments do not result in an increase in individual or cumulative occupational radiation exposure.

Based on the above, CP&L concludes that the proposed ameridments do not require an

• environmental assessment.

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ENCLOSURE 4 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 EMERGENCY / EXIGENT LICENSE AMENDMENTS INSTRUMENTATION RESPONSE TIME TESTING PAGE CHANGE INSTRUCTIONS UNIT 1 Removed page Inserted page 1-3 1-3 1-6 1-6 B 3/4 3 -1 B 3/4 3-1

- B 3/4 3-1a B 3/4 3-2 B 3/4 3-2 B 3/4 3-2a B 3/4 3-2a PAGE CHANGE INSTRUCTIONS UNIT 2 Removed page inserted page 1-3 1-3 1-4 1-4 1-6 1-6 B 3/4 3-1 B 3/4 3-1

- B 3/4 3-1a B 3/4 3-2 B 3/4 3-2 8 3/4 3-2a B 3/4 3-2a