ML19325D615

Application for Amends to Licenses DPR-71 & DPR-62,to Adjust Main Steam Line Radiation Monitors Trip Setpoint to Compensate for Increased Background Radiation Levels While Hydrogen Water Chemistry Sys in Svc

ML19325D615
Person / Time
Site:	Brunswick
Issue date:	10/19/1989
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19325D616	List: ML19325D615 ML19325D618
References
NLS-89-217, NUDOCS 8910250146
Download: ML19325D615 (9)

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• Cerebne PMmer & M Congeny s ,

P.O. Sou 1651

• Raiogh. 744.27802 (itj OCT 191989

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d BCUTTER SERIAL: NLS-89+217

. Vice Preem '

10CFR50.90 x Nuclear Servloos Department

. 33 or A '

United States Nucienr Regulatory Commission

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ATTENTION: Document Control' Desk

( Washington, DC 20555

' BRUNSWICK'3 TEAM ELECTRIC'PIANT, UNIT IKi. 1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NUS. DPR-71'& DPR-62 j N KEQUEST NR LICENSE AMENDMENT

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MAIN STEAM LINE RADIATION MONITOR SETPOINT CHANGE l

. HYDROGEN' WATF.R CHEMISTRY -

y Gentlement.

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,3 .In,accordance with the Code of Federal Regulations, Title 10, Parts 50.90

'and'2.101,-Carolina Power & Light Company-(CP&L) hereby requests a revision to 3: S , 'the Technical Specifications for the Brunswick Steam Electric Plant (BSEP),

1 3, Units 1 and 2.

'The proposed change adds a footnote to Tables 2.2.1-1 and 3.3.2 2 for the adjustment of the Main Steam Liro Radiation Moniters trip setpoints t'.,

&' compensate for the increased background radiation' levels: while the Hydrogen

. Water.Chemietry-System is in' service.

En'c1'osure 1 provides a detailed description of the proposed changes and the y

basis for the changes.

.. Enclotura 2 details the basis for the Company's determination that the R: proposed changes do not involve a significant hazards consideration, u  ;

Encloaure 3 prcevides instructions for incorporation of the proposed changes into the Technical Specifications for each unit.

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• Enclosure.4 providen a summary of the proposed Technical Specification changes far each unit on a page by page aasis.

,y ' F.nclosure 5 provides the proposed Technical Specification pages for Unit 1.

[ Enclosure 6 provides the proposed Technir.a1 Specification pages for Unit 2.  !

py l The use of the .9ydrogen Water Chemietry System during power operation is  !

. # highly, desirable as it'is known to mitigate intergronular stress corrosion p", -cracking of stainless steel piping. Brunswick-2 '.3 currently shutdown for recirculation piping r: placement and scheduled for restart in mid-Fcbruary

, 1990. Brunswick-1 will start a similar outage in 1990. "'he effective use of g

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the Hydrogen Vater Chemistry System is dependent upon the issuance of this

[ request., The Company therefore requests that this amendment be issued by g, February 1, 1990.

Please refer any. questions regarding this submittal to Mr. M. R.' Oates at (919) 546-6063.

Yours.very trul ,

A. B.. Cutt ABC/ MAT Enclosures

1. Basis for Charge Request-

2. 10 CFR 50.91 Ev61uation ,

1: 3. 3astructions for Incorporation

.4. Summary List of Revisions

5. Technical Specification Pages - Unit 1

6. Technical Specification Pages - Unit 2 cc: 'Mr. Dayne H. Brown Mr. S.'D. Ebneter Mr. W. H. Ruland Mr. E. G. Tourigny A.'B. Cutter, having b6en first duly sworn, did depose and say that the infor:mation contained herein is true ano cor ect to the best of his information, knowledge and belief; and the sources of'his information are officers, employees, contreev ra, and agents of Carolina Power & Light Company.

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ENCLOSURE 1  !

BRUNSWICK STEAM ELECTRIC. PIANT, UNITS 1 AND 2  ;

NRC DOCKETS 50-325 & 50-324 ,

OPERATING LICENSES DPR-71 & DPR 62 ,

REQUEST FOR' LICENSE AMENDMENT

.. MAIN S'IEAM LINE RADIATTON MONITOR'SETPOINT CHANGE HYDROCEN WATEP. CHEMISTRY BASIS FOR CHANGE REQUEST Prorosed Channe

> 1 The proposed amendment adds a footnote to Table 2.2.1-1 Item 6 and Table 3.3.2-2. Item 1.c.1 to allow adjusting of the Main Steam Line Radiation Monitor (MSLa.) trip-setpoints value to con.pensate for the increased radiation l

.'[ 1evels encountered while the Hydrogen Water Chemistry (HWC) system is in ,

operation.

AI.Lia y A hydrogen injection ~ test was perforied during January 1987. Amendment 131 7 l for Brunswick-2 was issued on December 10, 1986 in support of the hydrogen  !

injection. test. Based.on the evaluation of the test data, CP&L has decided to pursue HWC on a permanent basis. Installation of the HWC system for Brunswick-2 is complete'and in process for Brunswick-1. The purpose of HWC is P , to mitigate IUSCC of susceptible reactor piping material by introducing-p gaseous hydrogen into the reactor coolant which combines with oxygen to form

• water. During use of ~ hydrogen chemistry, ~ N-16 becomes volatile and.. as a  !

result, radiation levels in the main steam will increase. This amendment will ,

l permit increasing the MSLRM trip setpoint values to compensate for the "

expected higher background radiation levels that result from operation with l, the HWC system in service.  !

1. ,

The design and installation of the permanent hydrogen water chemistry facility I

at Brunswick was reviewed by the NRC during a site visit on August 23 and 24, 1988. As a result of this review, the Staff concluded that the hydrogen and oxygen supply facilities, hydrogen and oxygen injection systems, -

instrumentat;.on and controls, and safety considerations meet the recommendations of EPRI NP 5283-SR A - September 1987. This conclusion is documented.in a memoran6m from Frank J. Witt, Chemical Engineer, Chemical  ;

Engineering Branch tt Conrad E. McCracken, Chief, Chemical Engineering Branch, '

' dated September 6, 1988.

L The hydrogen injection test involved introduction of hydrogen into the secondary condensate booster pamps at increasing injection rates ranging from 0 to 34 sefm. While the injection was in progress, extensive radiological monitoring was conducted and the electrochemico potential (ECP) of the recirculation piping was measured. In additior startup testing of the hydrogen injection system was performed with hyo:c gen injection rates ranging 4

from 0 to 15 scfm. Based on the results of these tests, CP&L believes that a a El-1 1 a

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x hydrogen injection rate of less than 20 scfm will be necessary to achieve an .

ECP. reading of -230 mV (SHE), thereby inhibiting ICSCC.

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The MSLRN setpoint is specified in TS Tables 2.2.1-1 and 3.3.2-2 as 3.0 times

• t the full power background radiation level. Without hydrogen water chemistry, the normal full power background radiation level for the MSLRMs is -

approximately 115 meen/hr. Based on observations during the hydrogen injection test and startup testing of the system, it is expected that the background radiation level will increase to approximately 350 mrom/hr at an l injection' rate of 20 scfm. Since the normal full power MSLRM setpoint is established at 300 mres/hr, a license amendment is necessary to allow the MSLRM setpoint to be increased during operation of the HWC system.

The proposed change specifies when the HWC system can be operated and identifies restrictions associated with changing the HSLRM setpoints. First, the HWC system cannot be placed in service until reactor power reaches 20% of l Rated Thermal Power. This restriction is based on the Control Rod Drop .

Accident which is only of concern at power levels below 20% of Rated Thermal Power. After reaching 20% of Rated Thermal Powar the MSLRM setpoint can be increased since no other FSAR Chapter 15 accident scenarios take credit for the operation of the HSLRM scram and isolation setpoint. With_a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after decreasing below 20% of Rated Thermal Power or after the HWC system has been shutoff, the background level and associated setpoint shall be returned 7 to the' normal full power values.- If a power reduction event occurs so that

! the reactor power is below 20% of Rated Thermal Power for longer than 24 hovrb without the required setpoint change, control rod motion shall'be suspended (except for scram or other emergency action) until the necessary adjustments are made.

1 As stated above, an extensiva radiological monitoring program was conducted l during perforcance of the hydrogen injection test. Radiation surveys were L taken during each incremental increase in hydrogen injection at various points inside and outside the plant. Based on these surveys,-the Company has determined that: 7

1. At the projected injection rate, no additional plant shielding is necessary nor are revised access control mearures warranted. Worker doses.will be mainta'.ned ALARA at all times.

2. The overall turbine building shine increases slightly within che protected area, however, at the anticipated normal injection rate, the increase-can be considered negligible since the radiation levels will be well below the 10 CFR 20.101 restricted ares dose standards of 1.25 rem / quarter whole body.

'e 3. Outside the site boundary, thero are no measurable increased in radiation levels and, therefore, the 10 CFR 20.105, 10 CFR 100.11, and 40 CFR 190 site boundary doses are not affected.

Therefore, CP&L concludes that, since there are no appreciable affects on either onsite or offsite doses, the general public is not impacted by the El-2

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. operation of the NWC system. CPfiL intends to follow the latest available EPRI l

.. > Guidelines-for BWR Hydrogen Water Chemistry. ,

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I ENCLOSURE 2 l J

l BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 ]

. NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 J 3

REQUEST FOR LICENSE AMENDMENT MAIN STEAM LINE, RADIATION MONITOR SETPOINT CHANGE HYDROGEN WATER CHEMISTRY ,

1 10 CPR 50.92 EVALUATION l n

The Commissien has provided standards in 10 CFR 50.92(c) 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

• y - consequences'of an' accident previously evaluated (2) create the possibility '

, ' of a new or diffcrent kind of accident from any accident previously avaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power & Light Company has reviewed thic proposed license amendment request and determined that its adoption would not involve a significant hasards consideration. The bases for this detcraination are as follows: ,

t Pronosed Channe The' proposed amenda.r.c adds a footnote to Table 2.2.1-1, Item 6 and Teble 3.3.2-2, Item 1.c.1 to allow adjusting of the Main Steam Line Radiation i

Monitor (MS1RM) trip setpoints value to compensate for the increased radiatica  !

L levels encountered while the Hydrogen Water Chemistry (HWC) system is in '

operation.'

Basis The change does not involve a'significant hazards consideration for the following reasons:  ;

l.  ;

l' 1. The proposed amendment does not involve a significant increase in the

' probability or consequences of an accident previously evaluated.

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l h The only accident scenario which takes credit for the USLKM high "

[, radiation scram and isolation setpoint is the Contro Rod Drop Accidant l (CRDA) as described in the Brunswick FSAR Chapter li. Specifically, the Main Steam-Isolation Valves (MSIVs) are assumed to receive an automatic closure signal at 0.5 seconds after detection of high radiation in the -

main steam lines and to be fully closed at 5 seccnds from the receipt of the closure signal. The MSLRMs are provided to detect a gross failure of the fuel cladding. When high radiati'.n is detected, a trip is L initiated to reduce the continued failure of fuel cladding. At the same time, the MSIVs are closed to limit the ralease of fission products.

The trip setting is high enough above background radiation levels to lL

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l;ll m prevent spurious-trips yet low enough to promptly detect gross failures 4

in;the fuel risdding.

NEDO-10527, Supplement 1 " General Electric lod Drop Accident Analysis For Large Boiling Water Reactors," dated July 1972, concluded that the L

consequences of the CRDA are most severe under Hot Standby conditions.

Furthermore, the consequences of the CRDA are increasingly less severe above.10. percent power due to a faster Doppler response and a lower rodworth. Finally and mast importantly, this report concluded that above 20% of Rated Thersal Power the consequences of the CRDA are la minimal. Therefore, the proposed change specifies when the HWC system

,, can be operated and identifies restrictions associated with changing the MSLRN setpoints. First, the NWC system cannot be placed in service unti1 reactor power' reaches 20% of Rated Thermal Power. This

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restriction is based on the Control Rod Drop ac.cident which is only of l'

j concern at power levels below 20% of' Rated Thermal Power. After reaching'20% of Rated Thermal Power the MSLRM setpoint can be increased L since-no other FSAR Chapter 15 accident scenarios take credit for the

. operation of the MSLRN scram and isolation setpoint. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after decreasing below 20% of Rated Thermal Power or after the HWC system has been shutoff, che background level and associated setpoint shall be returned to the normal full power values. If a power reduction event occurs so that the reactor power is below 20% of Rated Thermal Power for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without the requireo setpoint change, l control rod motion shall be suspended (except for scram or other emergency action) until the necessary adjustments are made.

i L 2. 'Tha proposed amendment does not create the possibility of a new or l L different kind of accident from any accident previously evaluated.

l-The proposed change does not affect the design of any safety related systems and as such does not affect the performance of any safety related functions. The proposed amendment allows the operation of a new system, that is the HWC system. This system has been extensively y analyzed by EPRI, approved for use by the NRC, and.in operation at a number of facilities.

1 The des'ign and installation of the permanent hydrogen water chemistry' l facility at Brunswick was review by the NRC during a site visit on August 23 and 24, 1988. As a result of this review, the Staff concluded q that the hydrogen and oxygen supply facilities, hydrogen and oxygen j injection systems, instrumentation and controls, and safety l considerations meet the recommendations of EPRI NP 5283-SR A - September i 1987. This conclusion is documented in a memorandum from Frank J. Witt, Chemical Engineer, Chemical Engineering Branch to Conrad E. McCracken,

,4 Chief Chemical Engineering Branch, datad September 6, 1988.

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3. The proposed amendment does no- 'r.< ificant reduction in the margin of safety.

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J The proposed amendment includes specific requirements regarding the )

, operation of the H90 systemt -

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- Operction of the HWC system is only permitted above 20% of Rated

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When the HWC system is in operation, tho MSLRX setpoints can be

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adjusted upward to secount for the increase in the background rain

• f steam'line radiation levels.

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- Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after decreasing reactor power to below 20% of. j o Rated Thermal Power, the setpoints must be readjusted to their- l pre HVC system operation levels.  :

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If the power level falls 1elow 20% for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I 7; without the setpoint change, control rod motion is suspended .!

(excepi for scrams or other emergency si':uations) until the setroint adjustment is made. ,

These requ?rements will assure that the EWC system is opersted safely and with sufficient margin such that spurious MSL isolations'are 'i precluded w'aile maintaining the ability to detect any gross failures in the fuel cladding..

As discussed ir Item 1, A CRDA is the only accident which takes' credit for che MSL isolation trip function. However, above 20% of Rated .

1 Thermal. Power, the consequences of the CRDA ar minimal. Therefore, the change has no significant affect on the margins of safety for this accident scenario, e The increase in background rcdiation levelo has been analyzed and it has '

been determined that neither plant personnel nor the health and safety ,

of the public are at risk when operating with the HWC system.

Pased on the above, it is concluded that the proposed amendment does not U involve a significant reduction in a margin of safety.

As demonstrated above, the proposed amendment does not involve a significant a hazards consideration. This conclusion is further substantiated when the l' . Examples of Amendments That Are Considered Not Likely To Involve Significant L Hazards (Federal Register Volume 51, Number 44 dated March 3, 1986) are revie9ed. Specifically, this change can be considered to meet Example (ii) of F the above cited FR in that the proposed change ". . . constitutes an

, ' additional limitation, restriction or control not presently included in the M,' Technical Specifications." The proposed change identifies specific '

limitations for the operation of the HWC system .md imposes control rod L restricticns during the setpoint adjustment process thereby serving to inclu!e a in the Technica) ?pecifications additional control not currently present. In addition, the design and installation of the permanent hydrogen water chemistry facility at Brunswick was reviewed by the NRC during a site visit on August 23 and 24, 1988. As a result of this review, the Staff concluded that 1:

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[l the hydrogen'and oxygen' supply facilities, hydrogen'and oxygen injection '

l systems, instrumentation and controls,.and safety <:onsiderations. meet the recommendati xs of EPRI NP.5?83-SR A - September 1987. For these reasons,

g' , , ' CP&L conclu6es that. the proposed amenhent-'satistles tne ' criteria identified p '. > for a Category 2 'tachnical Spacification change.  ;

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