BSEP-97-0135, Application for Amends to Licenses DPR-71 & DPR-62,revising Requirements for Instrumentation Response Time Testing Associated W/Rps,Isolation Actuation Sys & ECCS
| ML20137Y679 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/11/1997 |
| From: | Campbell W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137Y682 | List: |
| References | |
| BSEP-97-0135, BSEP-97-135, NUDOCS 9704230179 | |
| Download: ML20137Y679 (14) | |
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i CP&L Carolino Power & Light Company William R. Campbell PO Box 10429 Vice President Southport NC 284 % 0429 Brunswick Nuclear Plant i
SERIAL: BSEP 97-0135 10 CFR 50.90 3
i TSC 97TSB05 i
1 APR 111997 3
I U. S. Nuclear Regulatory Commission ATTN: Document Control Desk
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Washington, DC 20555 l
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 I
DOCKET NOS. 50 'G AND S0-324/ LICENSE NOS. DPR-71 AND DPR-62 SUPPLFh.F.NT TC Rr.OUEST FOR EMERGENCY / EXIGENT LICENSE AMENDMENTS l
INSTRt3 HNTATOh GESPONSE TIME TESTING i
Or % men a
By letter dated March 24,1997 (Serial: BSEP 97-0120), as superseded by letter dated March 27,1997 (Serial: BSEP 97-0125), Carolina Power & Light (CP&L) Company requested a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These license amendments proposed revisions to the requirements for j
instrumentation response time testing associated with the Reactor Protection System (RPS),
Isolation Actuation System, and Emergency Core Cooling System (ECCS).
i Based on further telephone conversations wi+h members of the NRC staff, CP&L is proposing additional revisions to the Technical Specifications for isolation actuation instrumentation and d
the Bases changes for ECCS response testing of the High Pressure Coolant injection (HPCI) i System, Core Spray System, and Low Pressure Coolant injection (LPCI) System. These proposed revisions will more clearly define the specific instrument functions which no longer require response time testing as supported by the Boiling Water Reactor Owners' Group (BWROG) Licensing Topical Report NEDO-32291-A, " System Analyses For The Elimination of Selected Response Time Testing Requirements." A discussion of the additional Technical Specification changes is provided in Enclosure 1.
A new set of instructions for inserting and removing the affected Technical Specification pages pol is provided in Enclosure 2 For the convenience of the staff, new sets of typed Technical 3
Specification pages for both BSEP Unit No.1 cad BSEP Unit No. 2 are ocvided in Enclosures 3 and 4, respectively. The enclosed Technical Specification pages supersede 1{
those provided in our request dated March 27,1997. CP&L has reviewed the 10 CFR 50.92 evaluation provided in our March 27,1997, submittal and determined that the proposed license j
amendments do not involve a significant hazards consideration.
This license amendment request continues to meet the requirements of 10 CFR 50.91 for both i
emergency and exigent processing be causa failure to act before the discretionary enforcement 9704230179 970411 PDR ADOCK 05000324 lll]l]l]ljllljl[jll p
PDR rel 910 457 2496 Fox 910 457 2803 4VUUG
i Document Control Desk BSEP 97-0135 / Page 2 expires 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 continues to request emergency or exigent processing of this license amendment request.
I Carolina Power & Light Company is providing, in accordance with 10 CFR 50.01(b), Mr. Mel Fry of the State of North Carolina with a copy of this supplement to the proposed license amendments.
Please refer any questions regarding this submittal to Mr. Keith Jury, Manager-Regulatory Affairs, at (910) 457-2783.
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Sincerely, i
n' h
William R. Campbell i
i' WRM/wrm
Enclosures:
1.
Discussion of Additional Technical Specification Revision 2.
Page Change Instructions 3.
Typed Technical Specification Pages - Unit 1 4.
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 intermation, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power & Light Company.
Notary (Seal)
My commission expires:
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h Document Control Desk BSEP 97-0135 / Page 3 pc (with enclosures):
s U. S. Nuclear Regulatory Commission i
. 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 4
U. S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852-2738
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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 i
3825 Barrett Drive Raleigh, NC. 27609-7221 1
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i ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 I
NRC DOCKET NOS. 50-325 AND 50-324 j
OPERATING LICENSE NOS. DPR 71 AND DPR-62 i
SUPPLEMENT TO REQUEST FOR EMERGENCY / EXIGENT LICENSE AMENDMENTS I
INSTRUMENTATION RESPONSE TIME TESTING DISCUSSION OF REVISIONS TO TECHNICAL SPECIFICATION CHANGE REQUEST j
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SUMMARY
4 This submittal is associated with a license amendment request submitted on March 27,1997 (Serial: BSEP 97-0125), for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. The license amendment request revises instrumentation response time testing surveillance requirements for the Rer.ctor Protection System (RPS), Emergency Core Cooling System (ECCS), and Isolation System actuation instrumentation.
Carolina Power & Light (CP&L) Company has previously determined that these instruments were inoperable because response time surveillance testing, required by Technical Specifications 4.3.1.3,4.3.2.3, 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 discretion was verbally granted by the NRC staff at 2136 Eastern Standard Time (EST) on March 21,1997, in a telephone conference with the NRC.
A_DDITIONAL TECHNICAL SPECIFICATION REVISIONS Technical Specification 4.3.2.3 (Isolation Actuation Instrumentation) i On September 27,1993, the NRC issued Generic Letter 93-05, "Line-Item Technical Specification Improvements To Reduce Surveillance Requirements for Testing During Power Operation." Generic letter 93-05 provided guidance on incorporating a number of line-item improvements to the Technical Specifications, including the elimination of response time testing for isolation actuation functions with response times that corresponded to the diesel generator
. start time. The basis for this change was sufficient margin exists in the diesel start time when compared to the typical instrument responce time to assure adequate response without a specific measurement test.
Subsequently, on December 29,1993, the NRC issued Generic Letter 93-08, " Relocation of Technical Specification Tables of Instrument Response Time Limits." This generic letter provided guidance for requesting a license amendment to relocate tables of instrument response time limits from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR).
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l On April 14,1994, CP&L submitted a license amendment request to relocate the instrument response time limit tables from the Technical Specifications to the UFSAR using the guidance of NRC Generic Letter 93-08. The NRC approved this request on May 31,1994 as Amendments 171 and 202 to the Facility Operating Licenses for BSEP Unit No.1 and BSEP j
Unit No. 2, respectively.
Subsequently, in a letter dated December 28,1994, the NRC issued its Safety Evaluation i
Report and approval for licensees to use the BWR Owners' Group Licensing Topical Report NEDO-32291-A," System Analyses for Elimination of Selected Response Time Testing i
Requirements." Table 1 of NEDO-32291-A indicates the instruments and components for which respense testing can be eliminated. Table 2 of NEDO-32291-A indicates that response
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time testir,g of sensors only can be eliminated for the following RPS actuations:
I Reactor Vessel Steam Dome Pressure - High Reactor Vessel Water Level - Low, Level 3 Reactor Vessel Water Level - High, Level 8 l
Table 2 of NEDO-32291 also indicates that response time testing of sensors only can ba eliminated for the following main steam line isolation valve (MSIV) closure actuations:
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Reactor Water Level 1 or 2 Main Steam Line Radiation High Main Steam Line Low Pressure 1
Table 2 of NEDO-32291-A indicates that response time testing of ECCS actuation instrument loops for the following systems can be eliminated:
1 Low Pressure Core Spray Low Pressure Coolant injection High Pressure Core injection / Spray j
Finally, Table 2 of NEDO-32291-A indicates that response time testing can be eliminated for the following isolation system actuation instrument loops:
Reactor core isolation cooling (RCIC) system High pressure coolant injection (HPCI) system Core spray system Reactor water cles n-up (RWCU) system Frimary Ocntainmerd Seconcery containment RHR snutdown cooling / head spray Following relocation of the instrument response time limit tables to the UFSAF< CP&l incorporated, under 10 CFR 50.59, the instrument response time limit changes described in NRC Generic Letter 93-05 pertaining to diesel generator start times. The instrument response times listed in the relocated instrument response time table (e.g., UFSAR Table 7.3.3-1) for certain functions were changed to "NA" (i.e., not applicable) in accordance with the guidance of Generia Letter 93-05. While Generic Letter 93-05 indicates that these isolation actuation instrument functions no longer require response time testing (e.g., since their response times E1-2
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4 are listed as "NA"in UFSAR Table 7.3.3-1), NEDO-32291-A also eliminates the requirement for response time testing of these functions. These instrument functions are as follows:
Item 1.a.1, " Reactor Vessel Water Level - Low, Level 1" item 1.b, "Drywell Pressure" Item 1.d, " Main Steam Line Tunnel Temperature - High" item 1.e, " Condenser Vacuum - Low" Item 2.a, " Reactor Building Exhaust Radiation - High" Item 2.b, "Drywell Pressure - High" Item 2.c, " Reactor Vessel Water level - Low, Level 2" Item 3.e, " Reactor Vessel Water Level - Low, Level 2" item 4.a.1, "HPCI Steam Line Flow - High" Item 4.a.3, "HPCI Steam Supply Pressure - Low" Item 4.b.1, "RCIC Steam Line Flow - High"
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Because both NEDO-32291-A and NRC Generic Letter 93-05 support elimination of response time testing of the isolation actuation instrument functions listed above, CP&L proposes to add a new note (g) to Technical Specification Table 4.3.2-1 for each of these functions to indicate that response time testing of the function is not required.
There are other isolation actuation instrument functions which, prior to issuance of either NRC Generic Letter 93-05 or the approval NEDO-32291-A, had no response time requirements identified (i.e., their function response times were listed as "NA") and, thus, do not require response time testing. Response time testing of these instrument functions is also no longer required based on the NEDO-32291-A report. These instrument functions include the following:
Item 1.f, " Turbine Building Area Temperature - High" l
item 1.h, " Reactor Building Exhaust Radiation - High" Item 3.a. "aFlow - High" Item 3.b, " Area Temperature - High" Item 3.c, " Area Ventilation a Temperature - High" j
ltem 3.d, "SLCS Initiation" Item 3.f, "4 Flow - High - Time Delay" Item 3.g, " Piping Outside RWCU Rooms Area Temperature - High" Item 4.a.2, "HPCI Steam Line Flow - High Time Delay Relay" Item 4.a.4, "HPCI Steam Line Tunnel Temperature - High" Item 4.a.5, " Bus Power Monitor" Item 4.a.6, "HPCI Turbine Exhaust Diaphragm Pressure - High" Item 4.a.7, "HPCI Steam Line Ambient Temperature - High" Item 4.a.8, "HPCI Steam Line Area a Temperature - High" Item 4.a.9, "HPCI Equipment Area Temperature - High" Item 4.a.10, " Drywell Pressure - High""
Item 4.b.2, "RCIC Steam Line Flow - High Time Delay Relay" Item 4.b.3, "RCIC Steam Supply Pressure - Low" Item 4.b.4, "RCIC Steam Line Tunnel Temperature - High" Item 4.b.5," Bus Power Monitor" ltem 4.b.6, "RCIC Turbine Exhaust Diaphragm Pressure - High" Item 4.b.7, "RCIC Steam Line Ambient Temperature - High" Item 4.b.8, " RCIC Steam Line Area a Temperature - High" E1-3
Item 4.b.9, "RCIC Equipment Room Ambient Temperature - High item 4.b.10, "RCIC Equipment Room a Temperature - High" Item 4.b.11, "RCIC Steam Line Tunnel Temperature - High Time Delay Relay" Item 4.b.12, "Drywell Pressure - High" item 5.a,." Reactor Vessel Water Level - Low, Level 1" Item 5.b, " Reactor Steam Dome Pressure - High" Based on further discussions with the NRC staff regarding CP&L's March 27,1997, license amendment submittal, CP&L is proposing additional revisions to Technical Specification 4.3.2.3 and Technical Specification Table 4.3.2-1 to identify the complete scope of the isolation at.tuation instrumentation functions which no longer require rosponse time testing. The Technical Specification revision 6 needed to identify the icciation actuation instrument functions for which response time testing a no longer required a 'e summarized below.
Technical Specification 4.3.2.3 states tho ionowing.
The ISOLATION SYSTEM RESPONSE TIME of each isolation function" shall be demonstrated to be within its limit at least once pe 18 months. Each test shallindede 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 'ested 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.
The BSEP Unit No.1 footnote to Technical Specification 4.3.2.3 is being revised as follows:
" Radiation monitors are exempt from response time testing. The sensor response times for the following functions may be assumed to be the design sensor response time:
Item 1.a.2, " Reactor Vessel Water Level - Low, Level 3" item 1.c.3, " Main Steam Line Flow - High" Response time testing is not required for the functions noted in Table 4.3.2-1.
The BSEP Unit No. 2 footnote to Technical Specification 4.3.2.3 is being revised as follows:
" Radiation monitors are exempt from response time testing. The sensor response times for the following functions may be assumed to be the design sensor rasponse time:
Item 1.a.2, " Reactor Vessel Water Level - Low, Level 3" Item 1.c.3, " Main Steam Line Flow - High" Item 1.c.4, " Main Steam Line Flow - High" Response time testing is not required for the functions noted in Table 4.3.2-1.
The instrument functions listed in footnote above for BSEP Unit Nos.1 and 2 differs from the instrument functions listed in Table 2, item 4 of fJEDO-32291-A. Specifically, the BSEP footnote omits the main steam line pressure -low function. The BSEP Final Safety Analysis Report (FSAR), Section 7.3.4.7 discusses the isolation functions and settings of the primary E1-4
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e containment isolation and nuclear steam supply shutoff system listed in Table 7.3-2. Item 5 discusses the low steam pressure at turbine inlet function. This function is provided to handle a pressure regulator malfunction in which the turbine control valves or turbine bypass valves open fully. This FSAR section states that "although this isolation function is not required to satisfy any of the safety design bases for this system, this discussion is included here to make the listing of isolation functions complete." The same information can also be found in Section 7.3.1.1.6.5 of the Updated FSAR. Because the main steam line pressure -low instrument function is not needed to satisfy any safety bases for the main steam supply system, CP&L has determined that this function does not need to be included in list of MSIV isolation actuation functions which will continue to require response time testing (excluding the servor).
A new footnote (g) is being added to Technical Specification Table 4.3.2-1:
(g) Response time testing of the function is not required.
The new footnote (g) is being added to the following instrument functions listed in Technical Specification Table 4.3.2-1:
1 Item 1.a.1, " Reactor Vessel Water Level - Low, Level 1" item 1.b, "Drywell Pressure" Item 1.c.2, " Main Steam Line Pressure - Low"
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Item 1.d, " Main Steam Line Tunnel Temperature - High" j
ltem 1.e, " Condenser Vacuum - Low" l
item 1.f, " Turbine Building Area Temperature - High" Item 1.h, " Reactor Building Exhaust Radiation - High" Item 2.a, " Reactor Building Exhaust Radiation - High" Item 2.b, "Drywell Pressure - High" Item 2.c, " Reactor Vessel Water level - Low, Level 2" item 3.a, "6 Flow - High" Item 3.b, " Area Temperature - High" item 3.c, " Area Ventilation a Temperature - High" item 3.d, "SLCS Initiation" Item 3.e, " Reactor Vessel Water Level - Low, Level 2" Item 3.f, "6 Flow - High - Time Delay" item 3.g, " Piping Outside RWCU Rooms Area Temperature - High" Item 4.a.1, "HPCl Steam Line Flow - High" item 4.a.2, "HPCI Steam Line Flow - High Time Delay Relay" Item 4.a.3, "HPCI Steam Supply Possure - Low" Item 4.a.4, "HPCI Steam Line Tunnel Temperature - High" Item 4.a.5, " Bus Power Monitor" item 4.a.6, "HPCI Turbine Exhaust Diaphragm Pressure - High" Item 4.a.7, "HPCI Steam Line Ambient Temperature - High" Item 4.a.8, "HPCI Steam Line Area a Temperature - High" item 4.a.9, "HPCI Equipment A,rea Temperature - High" item 4.a.10, " Drywell Pressure - High""
ltem 4.b.1, "RCIC Steam Line Flow - High" Item 4.b.2, "RCIC Steam Line Flow - High Time Delay Relay" Item 4.b.3, "RCIC Steam Supply Pressure - Low" Item 4.b.4, "RCIC Steam Line Tunnel Temperature - High" E1-5 i
Item 4.b.5, " Bus Power Monitor" Item 4.b.6, "RCIC Turbine Exhaust Diaphragm Pressure - Hip'i" Item 4.b.7, "RCIC Steam Line Ambient Temperature - High '
Item 4.b.8, " RCIC Steam Line Area a Temperature - High" Item 4.b.9, "RCIC Equipment Room Ambient Temperature - High item 4.b.10, "RCIC Equipment Room a Temperature - High" item 4.b.11, "RCIC Steam Line Tunnel Temperature - High Time Delay Relay" Item 4.b.12, "Drywell Pressure - High" Item 5.a, " Reactor Vessel Water Level - Low, Level 1" Item 5.b, " Reactor Steam Dome Pressure - High" Bases 3/4.3.2 (Isolation Actuation Instrumentation _}
l The following addition is being made to the BSEP Unit No.1 paragraph which discusses response time testing in Bases Section 3/4.3.2:
As noted (Note #), neutron detectors are excluded from ISOLATION SYSTEM RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time. In addition, this note states that the response time of the sensors for item 1.a.2, " Reactor Vessel Water Level-Low, Level 3"; and Item 1.c.3, " Main Steam Line Flow - High" may be assumed in the ISOLATION SYSTEM RESPONSE TIME test to be the design sensor response time. This is allowed since other surveillance testing (e.g., channel calibration) and other techniques ensure detection of response time degradation before performance is significantly affected (Reference 1).
References:
1.
NEDO-32291-A," System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.
The following addition is beag made to the BSEP Unit No. 2 paragraph which discusses response time testing in Bases Section 3/4.3.2:
As noted (Note #), neutron detectors are excluded from ISOLATION SYSTEM RESPONSE TIME testing because the principles of detectc.r operation virtually ensure an instantaneous response time. In addition, this note states that the I
I response time of the sensors for Item 1.a.2, " Reactor Vessel Water Level-Low, Leve! 3"; Item 1.c.3, " Main Steam Line Flow - High"; and item 1.c.4, " Main Steam Line Flow - High" may be assumed in the ISOLATION SYSTEM RESPONSE TIME test to be the design sensor response time. This is allowed since other surveillance testing (e.g., channel calibration) and other techniques ensure detection of response time degradation before performance is significantly affected (Reference 1).
References:
1.
NEDO-32291-A," System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.
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Bases Updates CP&L is also revising the proposed paragraphs being added to Bases Sections 3/4.5.1, 3/4.3.5.3.1, and 3/4.3.5.2. These revisions are being made to more clearly reference the acceptance criteria being included in section 6.3.3.7 of the Updated FSAR.
The revised addition to Bases Section 3/4.5.1 is as follows:
Surveillance Requirement 4.5.1.c.4 ensures that the ECCS RESPONSE TIME for the HPCI system is less than or equal to the acceptance criteria included in Reference 6.
This surveillance requirement is modified by a note that allows the instrumentation portion of the response time to be assumed to be the design instrumentation response time. Therefore, the instrumentation response time is excluded from the ECCS RESPONSE TIME testing. This exception is allowed since other surveillance testing (e.g., channel calibration) and other techniques ensure detection of response time degradation before performance is significantly affected (Reference 7).
References:
6.
Updated Final Safety Analysis Report, Section 6.3.3.7.
7.
NEDO-32291-A, " System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.
l The revised addition to Bases Section 3/4.5.3.1 is as follows:
Surveillance Requirement 4.5.3.1.e ensures that the ECCS RESPONSE TIME for each core spray system subsystem is less than or equal to acceptance criteria included in Reference 1. This surveillance requirement is modified by a note that allows the instrumentation portion of the response time to be assumed to be the design instrumentation response time. Therefore, the instrumentation response time is excluded from the ECCS RESPONSE TIME testing. This exception is allowed since the ECCS instrumentat'on response time is a small part of the ECCS RESPONSE TIME (e.g., sufficient margin exists in the emergency diesp) generator start time when compared to the instrumentation response time) (Ieference 2).
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References:
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Updated Final Safety Analysis Report, Section 6.3.3.7.
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NEDO-32291-A, " System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.
The revised addition to Bases Section 3/4.5.3.2 is as fol;ows-Surveillance Requirement 4.5.3.2.d ensures that the ECCS RESPONSE TIME for each low pressure coolant injection system subsystem is less than or equal to acceptance criteria included in Reference 1. This surveillance requirement is modified by a note that allows the instrumentation portion of the response time to be assumed to be the design E1-7
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i instrumentation response time. Therefore, the instrumentation response time is excluded from the ECCS RESPONSE TIME testing. This exception is allowed since other surveillance testing (e.g., channel calibration) and other techniques ensure detection of response time degradation before performance is significantly affected 4
(Reference 2),
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References:
1 1.
Updated Final Safety Analysis Report, Section 6.3.3.7, l
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- NEDO-32291-A, " System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.
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4 ENCLOSURE 2 i
I 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 SUPPLEMENT TO REQUEST FOR EMERGENCY / EXIGENT LICENSE AMENDMENTS INSTRUMENTATION RESPONSE TIME TESTING PAGE CHANGE INSTRUCTIONS UNIT 1 4
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