ML20065R695
| ML20065R695 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/05/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20065R654 | List: |
| References | |
| NUDOCS 9012190140 | |
| Download: ML20065R695 (9) | |
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UNITED STATES Mr i
NUCLE AR REGULATORY COMMISSION W
WA$HING TON, D. C. 20556 t.gw g
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SAFETY EBLVATION BY_THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING __ AMENDMENT N0_.149 TO FACILITY OPERATING LICENSE _ N0_._ DPR-71 AND AMENDMENT NO.17_9 T0_ FACILITY OPER_AT1HG_ LICENSE _ NO._ DPR_-62 CAR 0_ LINA POWER &_ LIGHT _ COMPANY, et_al.
BRUNSWICK STEAM ELECTRIC PLANT, UNITS _1_ AND 2 DOCKET NOS. 50-325 AND 50-324
1.0 INTRODUCTION
By letter dated February 29, 1988, Carolina Power & Light Company (CP&L orthe-licensee),requestedTechnicalSpecification(TS)changesforthe Brunswick. Steam Electric Plant, Units 1 and 2.
The February 29, 1988 letter _was superseded by applic6 tion dated September 20, 1989.
Additional information was also provided by letters dated December 5, 1989 February 15, 1990, August 9, and October 24, 1990.
The August 9,.and October 24,
.1990, submittals provided clarifying information that did not change the proposed no significant hazards consideration published in the Federal begister. The proposed changes revise TS 3/4.3.2 to modity InstiuiIent Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2-1.
Instrument Table 3.3.2-1
. addressed isolation actuation instrumentation minimum channel operability, whereas Table 3.3.2-2 contains the isolation actuation instrumentation setpoints. Table 3.3.2-3 provides for isolation system instrumentation response. times, ano Table 4.3.2-1 addresses. isolation actuation instrumentation surveillance requirements.
The licensee also requests that the actual identification of containment isolation valves and secondary containment. isolation dampers be removed from the TS and be located in a licensee control document that would only be changed pursuant to 10 CFR 50.59.
The-licensee grouped.the changes into five categories. The following staff evaluation is also formatted by the same categories. Category 1 would delete-valve group 7 in Table 3.3.2-1.
Category 2 would add new items and' revise current items in. Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2-1, Categor (1). provide consistency, (2) y 3 changes revise the tables to:
correct administrative errors, and (3) provide clarification without boacting operation of the system. Category 4 changes revise the respons times and associated footnotes in Table 3.3.2-3 to provide a more accurate description of the instrumentation.
Category 5 changes relocate the primary containment isolation valve list, currently provided as Table 3.6.3-1, and the secondary containment automatic isolation damper list, currently provided as Table 3.6.5.2-1, to Plant Procedure RCI-02.6.
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- , 2.0'3 VALUATION Catecory-1 Changes Category 1 changes would delete valve group 7 in Table 3.3.2-1.
Valve.
group 7 currently includes the following items:
Primary Containment Isolation / Reactor Vessel Water Level-Low, Level 1; Secondary Containment Isolation /Drywell Pressure High; Reactor Water Cleanup (RWCU) System Isolation /Drywell Pressure High; Shutdown Cooling System Isolation / Reactor Vessel Water Level-Low, Level 1;-Shutdown Cooling System Isolation / Reactor Steam Dome Pressure High.
The trip signal identified in the items would isolate certain valves in the systems identified.
For example, a high reactor steam dome pressure would isolate certain valves of the shutdown cooling system.
The valves, by groups, are identified in TS Table 3.6.3-1 entitled " Primary Containment Isolation Valves," and TS Table 3.6.3-2 entitied " Secondary Containment Automatic Isolation Dampers." The licensee states that Table 3.6.3-1 does not identify any valves as group 7-valves.
Therefore, since there are no group 7 valves currently identified in the TS, the licensee reasons that the above named items identifying group-7 valves should be deleted.
In addition, the licensee provided l
various reasons why valve group.7 should not be identified in Table 3.3.2-1.
The reasons can be grouped as:
(1) custom to standard technical specification' conversion,- (2) logi_c design changes, and (3) license amendments that.were issued over ten years ago to support these efforts.
The staff reviewed Table 3.6.3-1 which contains an identification of the containment isolation valves for each unit.
No group 7 valves are identified.
The staff also reviewed the Updated Final Safety Analysis
- (UFSAR) Table 6.2.4-2 entitled " Automatic Primary Containment Isolation Valves." UFSAR Table 6.2.4-2 lists only one set of valves associated with group 7:
high pressure coolant injection (HPCI) turbile exhaust vacuum breaker isolation.
These two valves are addressed in the licensee's category 2 proposed -changes.where a new valve group 7 is proposed.
Based upon the above evaluation, the staff concluded that valve group 7 in Table 3.3.2-1 should have.been removed years ago and there are no group 7 valves'except for the'HPCI turbine exhaust vacuum breaker isolation valves which.will be addressed in the following evaluation.
The staff finds the change to delete valve group 7 in Table 3.3.2-1 acceptable.
Category 2 Changes Category 2 changes add new items and ' revise current items in Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2-1.
The licensee proposes to add the following new items:
1h (Reactor Buliding-Exhaust Radiation-High), 3f (Delta Flow-High - Time Delay Relay), 4.a.10 (Drywell Pressure-High), 4.b.11 (RCIC Steam Line Tunnel Temperature - High Time Delay Relay), 4.b.12
-(Drywell Pressure-High) and Footnotes (1), (j),. (k), and (1) for Table 3.3.2-1 only.
e s -
r The. licensee p(Main Steam Line Pressure-Low) g items for Table 3.3 roposes to revise the followin only:
- 1. c. 2
,1.c.3(MainSteamLine Flow.High),1.c.4 (Main Steam Line Flow-High-Unit 2 only),1.d (Main Steam Line Tunnel Temperature-High), le (Condenser Vacuum Low),1.f. (Turbine Building Area Temperature - High), 4.b.2 (HPCI Steam Line Flow-High Time Deiny Relay), 4.b.3 (RCIC Steam Supply Pressure-Low), and 5.b (Reactor SteamDomePressure-High). The details of these proposed changes follow.
The licensee proposes to add reactor building exhaust radiation-high trip function to the TS tables under PRIVARY CONTAINMENT ISOLATION.
The licensee states that this signal causes the group 6 isolation valves to close during a loss-of-coolant accident.
The licensee proposes the same i
applicable operational condition and act.on statement as the other group 6 valves under Item 1.
The staff reviewed UCaR Table 7.3-3 entitled
" Isolation Signals and Setpoints."
Reactor Building Exhaust High i
Radiation is listed as a signal for primary containment isolation,
-l group 6.
The staff agrees that this signal should be added to the TS and agrees that the operability and surveillance requirements are appropriate.
l The licensee proposes to add the differential (delta) flow-high time delay relay trip function to the TS tables under REACTOR WATER CLEANUP SYSTEM ISOLATION.
The licensee stated that current TS do not specifically reference operability surveillance requirements for the existing RWCU Delta Flow-High time delay relay.
These relays do not initiate any isolation signal. However, they are an important part of the instrumen-Lation.
RWCU isolation under high flow conditions is already included in the Table 3.3.2-1 as Item 3.a. Delta Flow-High. The licensee proposes similar-operability requirements to those already contained in Item 3.a.,
Delta Flow-High.
The staff reviewed UFSAR Table 7.3.1-3 entitled "
1 Isolation Signals and Setpoints."
The RWCV high Delta Flow time delay is listed as a signal for primary containment isolation group 3.
The staff agrees that the signal should be added to the TS and agrees that the operability and surveillance requirements are appropriate.
The licensee proposes to add drywell pressure-hich trip function to the TS tables under HPCI System Isolation. This signai, when combined with existing signal, HPCI Steam Supply Pressure-Low, will close HPCI turbine exhaust vacuum breaker valves, which are identified by a new valve group 7.
The HPCI steam supply pressure-low (4.a.3) will *:ontinue to close the group 4 valves. The HPCI system has vacuum breater valves on a vacuum relief line for the HPCI turbine exhaust. These lines help prevent the creation of a water column in the exhaust line.
Preventing filling of this' column reduces the piping loads which could exist if the turbine is restarted. -The valves isolate on coincident HPCI steam line pressure-low and drywell pressure-high.
Proposed footnote k reflects this logic makeup.- The licensee is proposing an operability requirement similar to other HPCI isolation signals. The staff reviewed UFSAR Table 7.3.1-3 entitled " Isolation Signals and Setpoints." Drywell pressure-high is an isolation signal with HPCI steam supply low pressure for primary
v
-4 containment isolation group 7.
In addition, UFSAR Table 6.2.4-2 entitled
" Automatic Primary Containment Isolation Valves" identifies these valves as group 7 valves which close on low steam supply pressure coincident with high drywell pressure. The-staff agrees that the signal should be added to the TS and that the operability and surveillance requirements are appropriate.
The licensee proposes to add the RCIC steam line tunnel temperature-high time delay relay trip function to the TS Table 3.3.2-3 under Reactor Core Isolation Cooling (RCIC) System Isolation. The licensee states that the current TS do not specifically reference operability and surveillance requirements for the existing RCIC steam line tunnel high temperature time delay relay.
These relays do not initiate any isolation signal; however, they are an..important part of the instrumentation.
RCIC isolation under high steam line temperature conditions is already included in the table as item 4.b.7, RCIC steam line ambient temperature high.
The licensee q
proposes the same operability requirements as already contained for item
.4 b.7.
The staff reviewed UFSAR Table 7.3.1-3 entitled " Isolation Signals and Setpoints." The RCIC steam line tunnel temperature high time delay is listed as a signal for primary containment isolation, group 5.
The staff
.egrees that.the signal should be added to the TS and operability and surveillance requirements are appropriate The licensee proposes to add the drywell pressure-high trip function to the TS Table 3.3.2-3 under Reactor Core Isolation Cooling System
. Isolation. This request is the same as the tiPCI above. The staff performed a similar review of the licensee's request and reviewed the J
UFSAR. A new valve group 9 will be used for the RCIC turbine exhaust j
vacuum breaker. isolation valves. Group 5 valves will continue to close-under RCIC low steam pressure (4.b.3).
The staff agrees that the signal should be added to the TS and agrees that the operability and surveillance requiremen.ts'are appropriate.
In TS Table 3.3.2-1, footnote (i) is proposed to be added for valve group.8 for-shutdown cooling system isolation under high reactor steam dome pressure conditions (Item 5 b.).
Footnote'(1) states "does not-isolate'E11-F015A, B."
This fact is not reflected in the TS, according to the licensee. The staff reviewed UFSAR Table 6.2.4-2 entitled " Automatic Primary Containment Isolation Valves." This table states in footnote (d) that for.these valves "does not isolate on high reactor pressure.
Isolates on low' level only in shutdown cooling mode." The staff agrees to the addition of footnote (1).
. In TS 3.3.2-1, footnote (j) is proposed to be added for valve group 1 for
~
states "Res not Iso.c.4 (BSEP-2 only),1.d. I.e, and 1.f.
Footnote (j)
I tem 1. c.2, 1. c.3 1 late B22-F019 or B32-F20." This fact is not reflected in-the T3, according to the licensee.
The' staff reviewed UFSAR Table 6.2.4-2 entitled " Automatic Primary Containment Isolation Valves." This table states in footnote (b) that these valves only isolate on reactor low water level and main steam line high radiation. Thus, the valves would f
not isolate for the signals associated with the above items. The staff agrees to the addition of footnote (j) as discussed above.
N
,e _ Category 3_ Changes Category 3 changes revise the tables to:
(1) provide consistency. (2) correct administrative errors, and (3) provide clarification without impacting operation of the system. The licensee further subdivided this category into six subchanges.
The staff's evaluation is formatted accordingly.
The licensee proposes to specify individualized valve groups on separate lines in Table 3.3.?-1 to show that their operability requirements are different(SubchangeA).
An in depth analysis of this change was provided
.in the licensee's December 5, 1989 submittal as follows.
Currently, valve groups actuated by an isolation signal are specified under the trip function regardless of whether the actuated valve groups ere associated with that isolation function.
As an example,. valve groups 2, 6, and 8 are listed under both trip funct'ons 1.a.1, Primary Containment Isolation, and 5.a,- Shutdown Cooling System Isolation, even though valve groups 2 and 6 are associated with primary containment isolation and valve group 8 with shutdown cooling system isolation. As a result, the Technical Specifications are not consistent in specifying the. correct action if the operability requirements are not met.
In the above case, Item 1.a.1 requires Action 20 for valve groups 2, 6, and 8 whereas Item 5.a. specifies Action 27 for these groups. Action 20, as specified by Item 1.a.1, is appropriate for valve groups 2 and 6 because both are associated with primary containment. Action 27, specified in Item 5.a. is appropriate for valve group 8 since it is associated with shutdown cooling system isolation.
The nature of the action speified by Action 27 would not compensate for the inoperability of the~ valve group 2 and 6 instrumentation and, as such, is inappropriate for that' condition.
Similar changes are necessary for Items 2.a. 2.b, and 2.c.- These items address the operability: requirements for the secondary containment isolation system-instrumentation, however the secondary containment isolation dampers are not identified as a valve group operated by the items. This change adds footnote (1) which references the secondary containment isolation dampers.
The specified Action 23 is correct for the secondary containment isolation dampers, however, it is not for valve groups 2, 3, and f which are related to secondary containment. The correct actions for these valve groups are specified by the primary containment isolation section for valve groups 2 and 6 and the reactor water cleanup system isolation system section for valve group-3. These sections are specifica1ly provided for these isolation functions and contain the appropriate actions.
The proposed changes do not reflect a change in the design or operation of the instrumentation. The staff agrees with the licensee's rationale and the proposed changes are acceptable because they clarify the valve groupings and their respective functions.
The licensee proposes to revise titles of the items in Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2-1 to provide consistency with other titles, correct administrative errors, and provide a more accurate description of the instrumentation (Subchange B). The licensee states that the changes
s t
do not: reflect changes in the design or operation of the instrumentation.
The corrected titles are listed on pages El-9 and El-10 of the September 20, 1989 submittal. The staff reviewed the revised titles, and the changes are acceptable.
The licensee proposes to replace Footnote
- with (f) in item 2.a in Table 4.3.2-1(SubchangeC)onpage3/43-28.
The footnote wording itself does not change. This is administrative in nature and is acceptable.
The licensee proposes to delete the word "or" from the end of Item a.2 under the " Primary Containment Integrity" definition on page 1-5 t
(SubchangcD). According to the licensee, the conjunction is out of place and should be deleted.
The licensee states that there is no technical besis for the current wording, nor does the conjunction represent any logic.
The staff agrees that the "or" makes no sense in Item a.2 on page 1-5, and the change is acceptable.
The licensee p(roposes to delete Footnote
- under Specification 4.6.3.3 (BSEP-1 only)
SubchangeE),
Footnote
- was added to the TS via Amendment No. 72 to provide a one-time extension of the 18 month survoiliace interval for four reactor instrumentation system isolation valves.
- n r.
licensee stated that the surveillance has been completed and the foots.vte is no longer applicable.
Based on the licensee's statements that the surveillance was completed and the footnote is no longer applicable, n c change is acceptable.
The' licensee proposes to delete Item 1.a.2, Reactor Vessel Water Level-tow, Level 2, from Tables =3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2-1 (SubchangeF).
Unit 1 Amendment No. 122, dated February 6, 1989 and Unit 2 Amendment No 146, dated April 18, 1989, revised the reactor vessel water level trip function for the valve group 1 isolation valves from low, level 2 to low, level 3.
This resulted in only valve group 3 being actuated by the low, level 2 trip function.
Valve group 3 isolates the reactor water cleanup system and 'is addressed specific: illy in Itern 3.3 for the low, level 2-instrumentation.- Item 1.a.2 is teing deleted because the instrumentation no longer actuates any valve groupr that need to be addressed under item 1.
This change does not represent any physical change to the design or operation of any systems.
It only more accurately describes the trip function associated with the group 3 valves. The staff agrees that there is unnecessary duplication and agrees to the change.
Category _4 Changes Category 4 changes consist of revising certain response times and u sociated footnotes in Table 3.3.2-3 to provide a more accurate cription of the instrumentation.
.o
-7 The licensee proposes to change the Erding of footnote (a) sli move the reference of this note from specific table items the (ghtly and currently Item 4.a.1 and 4.b.1) to the heading entitled " RESP 0 HSE TIME".
Cu rrently,
part of footnote (a) states " Isolation system instrumentation response time specified includes the delay for diesel generator starting assumed in the accident analysis." The licensee desires to change the words "the delay" to "any delay.
Some valves depend apen diesel generator AC power when loss of offsite power is assumed and some do not. The change is necessary when the footnote is placed at the heading " RESPONSE TIME."
Thus, footnote (a) now addresses instrumentation response time as:
(1) time for the instrument to respond, (2) any deley caused by the use of timers, and (3) any delay due the diesel generator starting. This time when added to the valve isolation time, as addressed in footnote (e), will give the.alation system response time.
The staff agrees to the change, i
The current TS specify an instrumentation response time of 1.0 second for the trip function instrumentation in Items 1.a.2, 1.c.1, 1.c.3, 2 c, and 3.e.
A reference to Footnote (d), which states " Isolation actut cion instrumentation response time only," is also provided. This footnote indicates that any time delay needed for diesel generator starting is not subject to the response time requirement since the requirement applies only to the instrumentation.
The trip functions covered by Items 1.a.2, 1.c.1, and 1.c.3 actuate both AC powered valves and the main steamline isolation valves (MSIV).
Item 2.c and 3.e cover functions that actuate only AC sowered valves.
-The MSIV are not dependant on AC power for closure. T1e response times currently specified are appropriate for the MSIV, but not for other AC powered valves actuated by this instruinentation since they are dependent upon the diesel generators. The proposed change establishes a 13-second response time' requirement for the valves other than the MSIV to accommodate the diesel generator start time. A new footnote (f) is added with the new 13-second response time which states, " Isolation system instrumentation response time for associated valves except MSIV" for those functions that actuate both the MSIVs and AC powered valves. The proposed change also revises Footnote (d), which is associated with the 1.0-second response time to state, " Isolation system instrumentation response time for MSIVs only. No diesel generator delays assumed."
The above described changes do not represent a change to the plant. The changes clarify the existing information contained in the Table and more accurately portray it. On this basis, the changes are acceptable.
The last change associated with Category 4 changes replaces the response time for isolation of RWCU under high differential flow t.ondition. The current value is less than or equal to thirteen seconds.
The value proposed is 45 seconds. The licensee stated that a 45-second time delay is provided for this instrumentation to prevent spurious isolation signals resulting from RWCU pump starts or flow path changes.
The time delay is not currently included in the TS response time.
The staff reviewed UFSAR
y
- e
,w l t:
. l Table 7.3.1 entitled " Isolation Signals and Setpoints" and confirmed.the j
use of -the-45-second timer.' The licensee also confirmed by letter dated February 15,1990, that the high eneroy line break analysis supports the "45-second time delay. Therefore, the staff finds the c'1ange acceptable.
Category 5~ Changes.
Category. 5 changes relocate the primary containment isolation valve list, currently provided as Table 3.6.3-1, and the secondary containment automatic isolation damper list, currently provided as Table 3.6.5.2-1,
-to Plant Procedure RCI-02.6.
This approach is similar to a TS chan made for-another nuclear plant owned and operated by the licensee. ge
- The procedure is referenced where the Table information used to be contained to
)
ensure that any change to the Table would be subject to the provisions of
{
c10 CFR 50,59.
A paragraph is also added to the. Bases statement to explain the' removal'of these Tables, The-staff does not believe that the listing of the actual valves / dampers need to be provided in toe TS. Removal of such detailed listings of plant equipment from TS have been the subject of license amendments in the recent-past.; For example, snubber listings have been deleted from various plant TS because the actual snubber identification numbers. listed in the TS were_not needed for. plant safety.
The licensea's request to delete the actual valve / damper, identification numbers is similar to.the example, andt the staff agrees.to the change.
The licensee' stated that CP&L has; completed a review of the primary q
containment isolation system TS and determined that Table 3.6.3-1 needs to be: revised to accurately reflect the as-built cesign of the primary containment: isolation system.
The staff requested the licensee to explain the. differences between the TS valve -listing and.the similar listing in
-l the_ procedure.
The licensee's responses in their letter dated December 5, 1989, indicate that the currert Technical Specifications list only automatic isolation valves with stroke time requirements. Technical Specification Interpretation 85-01 -expacded the applicability of Technical Specification Section 3.6.3 to include tha list of the primary containment 1
. isolation valves contained in existing Plant Procedure S0-12.
It will also:specifyTthe same isolation times as currently specified by the-Technical Specifications. -The list'of valvis and requirements specified q
by the'new procedure, therefore -will be tha same as.that currently l
specified by-the Technical Specifications as expanded by the Technical Specification Interpretation.
The proposed relocation primary containment
-isolation system-valve listing is acceptable because it is consistent with TS; simplifications-'already accepted in other nuclear plants, and-this change does not impact en plant safety or operations, u
3.0 ENy_IRONMENTAL CONSIDERATIONS These amendments change a requirement with respect to installation or use Lof a facility component located within the restricted areas as defined in 10 CFR Part 20 and change surveillance requirements. The staff has determined that these amendments involve no significant increase in the j
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amoun t, and no significant change in the typet, of any effluents that may be rele'. sed off site-
.1d that there is no significant increase in individual or curnulative occupational radiation eaposure.
The Comission has previously issued a proposed finding that these arrendi.ents involve no significant hazards consideration, and there has been o public coment on such finding. Accordingly, these 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 irnpact statertent or environmental assessment need be prepared in connection with the issuance of these amendtrents,
4.0 CONCLUSION
The Comission trade a proposed determination that these amendments involve no significant hazards consideration which was published in the Federal Reoister (55 FR 8219) on March 7, 1990, and consulted with the S' tate o'T horth Carolina.
No public coments or requests for hearing were receivea, and the State of North Carolina did not have any coments.
L The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the ublic will not be endangered by operation in the proposed inanner, and p(2) such activities will be conducted in compliance with the Com-mission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Dated: December 5, 1990 Principal Contributor:
H. B. Le
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