ML20042A295

Application for Amend to Licenses DPR-62 & DPR-71 to Incorporate Requirements for Time Delay Relay Mod Into Steam Line Break Detection Circuitry of HPCI & Reactor Core Isolation Cooling Sys,Per NUREG-0737,Item II.K.3.15

ML20042A295
Person / Time
Site:	Brunswick
Issue date:	03/16/1982
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20042A296	List: ML20042A295 ML20042A299
References
RTR-NUREG-0737, TASK-2.K.3.15, TASK-TM NUDOCS 8203230303
Download: ML20042A295 (5)

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Carolina Power & Light Company di MAR 161982

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9 "Q~EIS82rG Office of Nuclear Reactor Regulation k*d5\ps ATTN: Mr. D. B. Vassallo, Chief b -

Operating Reactors Branch No. 2 9 United States Nuclear Regulatory Commission Washington, D.C. 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 -

NUREC-0737 ITEM II.K.3.15

SUMMARY

In accordance with the Code of Federal Regulations, Title 10, Part 50.90 and Part 2.101, Carolina Power & Light Company (CP&L) hereby '

requests revisions to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Uni'. Nos. 1 and 2. The revisions incorporate require-ments for a time delay relay (TDR) modification to be incorporated in the steam line break detection circuitry of the High Press g Coolant Injection (IIPCI) and Reactor Core Isolation Cooling (RCIC) Systems in reference to Item II.K.3.15 of NUREG-0737.

DISCUSSION In response to Mr. T. A. Ippolito's letter of October 16, 1981, CP&L submits the enclosed information on the TDR modification for the HPCI and RCIC Systems (Enclosure 1). Our submittal dated December 31, 1980 to Mr. D. G. Eisenhut on post-TMI requirements provides additional background information on NUREG-0737 Item II.K.3.15 which, in conjunction with the information in Enclosure 1, provides the technical basis for the proposed Technical Specifications changes (Enclosure 3).

In addition to the proposed Technical Specifications changes referenced above, we have noted an incorrect and redundant instrument number on one Technical Specifications page for each unit which is affected by the HPCI/RCIC System TDR modification. We have made this administrative correction, and the basis is provided in Enclosure 2.

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4 ADMINISTRATIVE INFORMATION i

i Enclosed you will find the revised Technical Specifications pages with the changes indicated by vertical lines in the right-hand margins. In i accordance with the criteria in 10CFR170.22, we have determined that these changes are administrative in nature; therefore, a Class II and a Class I

) license amendment fee are required. Our check for $1,600.00 is enclosed.

Yours very truly, h.(J.).

j P. W. Howe f Vice President l Technical Services

, WRM/Imr (6819)

Enclosures cc: Mr. J. P. O' Reilly (NRC-RII) l i P. W. Howe, having been first July sworn, did depose and say that the information contained herein is true and correct to his own personal

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knowledge or based upon it. formation and belief.

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ENCLOSURE 1 ADDITIONAL INFORMATION NUREG-0737 ITEM II.K.3.15 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 The purpose of the time delay relay (TDR) modification is to pro-vide a three-second delay in the isolation of the turbine steam supply lines of the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems anytime a greater than 300 percent steam flow is detected. Such a modification provides prevention of flow spike trips during HPCI/RCIC system startup, as well as provide some level of protection in the event of large flow spikes resulting from transient swings in HPCI/RCIC system operation. The design basis of the modification is to eliminate trips resulting from spurious flow spikes during system startup.

Prior to the TDR modification, Brunswick had not experienced any problem with steam flow spikes causing isolation of the HPCI or RCIC systems during system startup. A review of Startup Test Reports on Brunswick shows that the steam line flow setpoint for isolation was set well above the peak transient flow condition measured.

The following data provides information from Brunswick-1 startup tests that were conducted prior to initial operation of the unit (series 14 and 15); this demonstrates how the data relates to the current steam line flow isolation setpoint. The maximum peak flow data is derived from the relation that flow change is proportional to the square root of the change in differential pressure.

Measured Peak Transient Flow Current Setpoint Maximum Peak Di f ferential (in H 20) (=300% Flow (% of System Instrument Pressure (in H2O) design flow) design flow)

RCIC E51-dPIS-N017 130 387 175%

E51-dPIS-N018 110 387 160%

HPCI E51-dPIS-N004 55 207 155%

E51-dPIS-N005 65 207 168%

The above values are from Brunswick-1 Startup Test Reports as referenced above and are typical for Brunswick-2.

Based on Brunswick's operational history and startup data and General Electric's evaluation that a three-second delay of steam line isolation actuation would cover the time period in which a typical startup spike might exceed the isolation setpoint (reference NEDE-24953, Section 4.3), CP&L does not believe any additional testing is necessary for Brunswick.

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A 13-second time delay is the design basis for isolation of HPCI or RCIC system steam line breaks and is being included in the anclysis for establishing environmental conditions for equipment quali-fication as part of NRC Inspection and Enforcement Bulletin 79-01B. The three-second time delay used for the TDR modification is enveloped by this previously established 13-second delay design basis assumption.

The proposed Technical Specifications changes covering the added time delay relays (two for the HPCI system and two for the RCIC systemi are provided as Enclosure 3. The " allowable value" has been selected to be less than or equal to 12 seconds. An allowable value as low as zero to preclude having to declare either the HPCI or RCIC systems inoperable is justified considering that Brunswick has not experienced a problem with spurious system startup isolation. The allowable value of 12-seconds was selected as one-second less than the specified 13-second maximum isolation circuitry response time, with the one-second difference being time allotted for the logic circuitry without the relay. The frequency of functional testing and calibration has been selected to be the same as the pressure switches.

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ENCLOSURE 2 DISCUSSION OF ADMINISTRATIVE CORRECTION TO TECHNICAL SPECIFICATIONS BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 An administrative correction is being made to the existing Techni-cal Specifications (TS) Tabic 3.3.2-2, item 4.a.7, HPCI Steam Line Area A Temperature - High. Two instrument numbers are listed under this item:

51-dTS-N604C,D is incorrect and redundant and has been deleted in our submittal; E51-dTS-N604C,D is correct and remains in the TS. This change will provide consistent reference to this instrument in TS Table 3.3.2-2 when compared to TS Tables 3.3.2-1 and 3.3.2-3.

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