ML20087G613
| ML20087G613 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/11/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20087G603 | List: |
| References | |
| NUDOCS 9508170130 | |
| Download: ML20087G613 (5) | |
Text
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.t UNITED STATES S'
NUCLEAR REGULATORY COMMISSION "f
WASHINGTON, D.C. 20555-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.178 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO. 209 TO FACILTY OPERATING LICENSE NO. DPR-62 CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324
1.0 INTRODUCTION
By letter dated January 25, 1993 (Reference 1), and supplemented December 28, 1993 (Reference 2), September 13, 1994 (Reference 3), and January 13, 1995 (Reference 4), Carolina Power and Light Company (the licensee) requested changes to the Technical Specifications (TS) for Brunswick Steam and Electric Plant (BSEP), Units 1 and 2.
The proposed changes would exempt TS 3.1.3.1 Action b., the specification concerning one or more inoperable control rods, from the requirements of TS 3.0.4, allowing transition from Operating Condition 2 to Operating Condition I with up to eight inoperable control rods.
Also requested was a change to TS 3.1.3.5, to address operation with more than one inoperable scram accumulator in order to avoid entry into TS 3.0.3, which requires plant shutdown in the event multiple scram accumulators are declared inoperable. Associated TS Bases changes were also submitted. The proposed change to TS 3.1.3.5 was withdrawn by the licensee by [[letter::BSEP-95-0226, Submits Partial Withdrawal of Request for License Amend Re Control Rod Drive & Control Rod Drive Scram Accumulators|letter dated May 25, 1995]] (Reference 5).
References 2, 3, 4, and 5 did not expand the scope of the original Federal Reaister notice or change the no significant hazards determination.
I 2.0 EVALUATION 2.1 Sackaround The control rod drive (CRD) system regulates reactor reactivity by positioning i
control rods in response to manual control signals during operation, and by shutting down the reactor in emergency situations by quickly inserting rods in response to a manual or automatic signal.
Each control rod is positioned by a separate hydraulic control rod drive, which is furnished pressurized water by the CRD hydraulic system.
Each rod is associated with a particular hydraulic control unit which has the components needed for the normal positioning or scram of the control rod.
Each rod also has an associated scram accumulator.
The accumulator serves as an independent source of energy to insert a control rod during a scram.
i 9508170130 950811 PDR ADOCK 05000324 P
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. The reactivity control technical specifications ensure that; (1) the minimum shutdown margin is maintained, (2) the control rod insertion times are consistent with those used in the plant-specific accident analysis, and (3) the potential effects of a rod ejection accident are limited. A limitation on the number of inoperable rods is set so that the resultant effect on total rod worth and scram reactivity is minimized.
The various requirements for scram times ensure that scram reactivity is within limits assumed for safety analyses and that any indication of systemic problems with rod drives is investigated on a timely basis.
2.2 TS 3.0.4 Exemotion The Reactivity Control Systems section of the Technical Specifications consists of several Limiting Conditions for Operation (LCO) addressing specific grounds for declaring control rod inoperability.
The first, LC0 3.1.3.1, specifies the requirements once a control rod is declared inoperable.
LC0 3.1.3.1 is composed of three Actions, the first (Action a.) dealing with inoperable rods due to immobility or inability to trip, the second (Action b.)
addressing inoperability for all other reasons, and the final Action (Action c.) specifying the 12-hour hot shutdown requirement if more than eight rods are inoperable.
The remaining LCOs deal with specific factors affecting control rod operability:
3.1.3.2 Control Rod Maximum Scram Insertion Times 3.1.3.3 Control Rod Average Scram Insertion Times 3.1.3.4 Four Control Rod Group Scram Insertion Times 3.1.3.5 Control Rod Scram Accumulators 3.1.3.6 Control Rod Drive Coupling 3.1.3.7 Control Rod Position Indication Except for LC0 3.1.3.3, each of these remaining LCOs stipulates that the provisions of TS 3.0.4 are not applicable if the action statement of the LC0 is satisfied and other requirements are met, including the standard separation and insertability requirement for rod inoperability in TS 3.1.3.1 (Action b.).
TS 3.0.4 is the prohibition against establishing new operational conditions if TS LCOs are not met without reliance on provisions contained in the Action statements unless otherwise excepted.
For the remaining LCOs, the 3.0.4 exemption is always accompanied by a requirement to satisfy conditions in TS 3.1.3.1 for inoperable control rods.
The types of rod inoperability addressed in the remaining LCOs above do not include all forms of inoperability, however. One surveillance requirement of LCO 3.1.3.1 includes operability tests of the scram discharge volume vent and drain valves to ensure control rod operability.
In this case, inoperability of a scram discharge volume would affect the scram capability of a large number of control rods, thus precluding the possibility of continued operation (TS 3.1.3.1 Action c.).
Such a condition is distinct from inoperability not affecting scram capability, as addressed in TS 3.1.3.1 (b), and is not included in this proposed change.
. This reoposed change does not involve provisions concerned with untrippable cont' ol rods as addressed in TS 3.1.3.1 Action a.
In its justification for including the 3.0.4 exemption in TS 3.1.3.1 Action b., the licensee presented its assessment of the safety impact of allowing entry into Operational Condition 1 from Operational Condition 2 for the types of control rod inoperability addressed in TS 3.1.3.2, 3.1.3.4, 3.1.3.5, 3.1.3.6, 3.1.3.7 listed above.
Approval of this change is justified based upon the fact that, once the applicable Actions of TS 3.1.3.1 are satisfied, these TS specifically grant an exemption from the provisions of TS 3.0.4 for the types of control rod inoperability they govern. Given this, the proposed addition of a corresponding TS 3.0.4 exemption to TS 3.1.3.1 Action b., which is the Action of TS 3.1.3.1 addressing these types of control rod inoperability, does not have an adverse impact on safety.
The proposed change eliminates ambiguity in the TS in this area.
2.3 Acceptability of Proposed Technical Specifications To effect the proposed changes for control rod operability, the licensee submitted the following TS and TS Bases changes for BSEP Units 1 and 2:
a.
A statement exempting the provisions of TS 3.0.4 is added to the limiting condition for operation (LCO) for TS 3.1.3.1 Action b.
This change is acceptable as discussed in the Evaluation section.
b.
TS Bases Section 3/4.1.3, Control Rods, is updated to support the control rod operability requirements associated with the change in (a) above, and is acceptable.
Other changes proposed in Reference I were withdrawn by the licensee in Reference 5.
The proposed change to exempt TS 3.1.3.1 Action b. from the requirements of TS 3.0.4, allowing transition from Operating Condition 2 to Operating Condition 1 with up to eight inoperable control rods is acceptable. Approval of this change is acceptable based upon the fact that, once the applicable Actions of TS 3.1.3.1 are satisfied, TS 3.1.3.2, 3.1.3.4, 3.1.3.5, 3.1.3.6, and 3.1.3.7 specifically grant an exemption from the provisions of TS 3.0.4 for the types of control rod inoperability those TS govern.
Given this, the proposed addition of a corresponding TS 3.0.4 exemption to TS 3.1.3.1 Action b., merely makes clear that TS 3.0.4 does not apply when all the requirements of TS 3.1.3.2, 3.1.3.4, 3.1.3.5, 3.1.3.6, and 3.1.3.7 have been met.
Further, the total number of inoperable control rods is limited by TS 3.1.3.1 Action c.,
and other LCOs ensure that the resulting control rod scram worth and scram capability comply with assumptions for operating limits for both Conditions 1 and 2.
a.;
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3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as~ defined in 10 CFR-Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents.that may be released offsite, and that there'is no :
significant increase in individual-or cumulative occupational radiation exposure. The Comission has previously issued a proposed finding;that the amendments involve no significant hazards consideration, and there has been no public coment on such finding (58 FR 36428). Accordingly, the 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 impact-statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Comission has concluded, based on the considerations discussed above, that -(l) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.
6.0 REFERENCES
1.
Letter from R. B. Starkey, Jr. (CP&L) to NRC, January 25, 1993, Brunswick Steam and Electric Plant, Unit Nos. I and 2, Request for License Amendment, CRD and CRD Scram Accumulators.
2.
Letter from R. A. Anderson (CP&L) to NRC, December 28,.1993, Brunswick Steam and Electric Plant, Unit Nos. I and 2, Response to Request for Additional Information Regarding Control Rod Operability Technical Specification Amendment Request.
3.
Letter from R. A. Anderson (CP&L) te NRC, September 13, 1994, Brunswick Nuclear Plant, Unit Nos. I and 2, Response to NRC Staff Request for Information - Control Rod Drive Scram Accumulator License Amendment Request.
4.
Letter from R. A. Anderson, (CP&L) to NRC, January 13, 1995, Brunswick Nuclear Plant, Unit Nos. I and 2, Request for License Amendments, Control Rod Drive and Control Rod Drive Scram Accumulators.
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, 5.
Letter from R. A. Anderson, (CP&L) to NRC, Nay 25, 1995, Brunswick Nuclear. Plant, Unit Nos. I and-2, Partial Withdrawal of Request for License Amendments, Control Rod Drive and Control Rod Drive Scram Accumulators.
Principal Contributor:
J. Donoghue Date:
August 11, 1995 l
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