ML20128C073
| ML20128C073 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/25/1993 |
| From: | Starkey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128C076 | List: |
| References | |
| NLS-93-007, NLS-93-7, NUDOCS 9302030302 | |
| Download: ML20128C073 (14) | |
Text
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CIEL Carolina Power & Light Company P O. Box 1551
- Ralegh. N C. 27t:02 JAN 251993 SERIAL: NLS-93 007 R D STARKEY, JR.
10 CFR 50.90 ve. Pr.****
TSC 86TSB02 Ntriear Servces Departmet United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC '20555 BRUNSWlCK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR 71 & DPR 62 REOUEST FOR LICENSE AMENDMENT CRD AND CRD SCRAM ACCUMULATORS Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests a re. vision to Append;x A of Operating Licenses DPR-71 and DPR 62 (the Technical Specifications) for the Brunswick Steam Electric Plant (BSEPL Units 1 and 2.
1 The propot ed amoi.dment includes two changes. The first change involves the addition of an exemption statement from the requirements of Technical Specification 3.0.4 in Technical Specification 3.1.3.1, ACTION b. The second change revisec Technical Specification 3.1.3.5, Control Rod Scram Accumulators, to address operation with more than one inoperable Control Rod Drive (CRD) scram accumulator. provides a detailed description of the proposed changes and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides an environmenttu evaluaticn which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 Cm 51.22(c)(9).
Therefora, pursuant to 10 CFR 51.22(b), no environmental assessment needs to be prepared in connection with issuance of the amendment.
Enclosures 4 and G provide marked-up pages of the proposed Technical Specification changes for Unit Nos.1 and 2.
Carolina Power & Light Company is providing, in accordance with 10 CFR 50.91(b), Mr. Dayne H.
Brown of the State of North Carolina with a copy of the proposcd !! cense amendment.
N in order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.
010103 igd 9302030302 930125 l
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c Document Control Desk NLS 93 007 / Page 2 '
. Please refer any questions regarding this submittal to Mr. D. B. Waters at (919) 546 3678.
- Yours very truly,.
R. B. Starkey, Jr.
KAM/kah (nis93007.wpf) r
Enclosures:
1.
Basis for Change Request
^
2.
10 CFR 50.92 Evaluation 3.
Environmental Considerations 4.
Proposed Technical Specification Changes Unit No.1 5.
Proposed Technical Specification Changes Unit No. 2 R. B. Starkey, Jr., having been first duty sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.
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v ENCLOSURE 1 BRUNSWlCK' STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2:
NRC DOCKET NOS, 50-325 & 50 324 OPERATING LICENSE NOS. DPR 71 & DPR 62-REQUEST FOR LICENSE AMENDMENT CRD AND CRD SCRAM ACCUMULATORS -
D_ ASIS FOR CHANGE REQUESI X
Backoround:
Control Rod Drive System
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The control rod drive system controls changes of reactivity by incrementally positionirig control rods within the core in response to reactor manual control signals. The system is also required to quickly shutdown the reactor in emergencies by rapidly inserting control rods into the core irt response to a manual or automatic signal.
Each control rod is positioned and supported by a separate positioning device, and a failure of any.
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one positioning device will not affect the operation of any other positioning device.. Control rod withdrawal will not occur due to a single positioning device malfunction, and no single component :
can prevent control rod insertion or scram, in the event of a scram, the system provides sufficiently rapid control rod insertion so that no fuel damage results from an ' abnormal operating i
The specifications of this section of the Brunswick Technical Specifications ensure that 1) the-minimum SHUTDOWN MARGIN is maintained,2) the control rod insertion times are consistent with those used in the accident analysis, and 3) the potential effects of the rod ejection accident are limited. The ACTION statements permit variations from the basic requirernents but at the same time impose more restrictive criteria for continued operation. A limitation on inoperable rods is set ~
such that the resultant effect on total rod worth and scram shape remains acceptable.
Control Rod Drive Hvdraulic System The control rod drive hydraulic system supplies pressurized and_ demineralized water to provide hydraulic operating pressure and cooling water to the control rod drive mechanisms, The control rod hydraulic system consists of the necessary pumps, valves, piping, and instrumentation to provide water at the proper pressures and flow rates through the hydraulic control units for operation of the control rods.
Hydraulic Control Unit Each control rod has one hydraulic control unit associated with it. The hydraulic control unit combines operating valves and components needed for the normal positioning or scram of a single control rod and consists of the following:
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E (1)
Piping assembly, which has seven hydraulic risers (insert line, exhaust line, cooling-
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water line, scram discharge line, drive water line, charging water line, and withdraw; line).
-(2)
Manifold, which directs water between the seven risers on the hydraulic control-unit. The manifold contains cooling and drive water check valves and filter elements to protect the directional control valves and the control rod drive -
mechanism. Exhaust water is discharged to the exhaust header via the overpiston port valve or the underpiston port valve based on whether the control rod is being inserted or withdrawn, respectively.
(3)
Air-operated (air to close, spring to open) inlet and outlet scram valves, which inject '
and exhaust water to and from the control rod drive for scram insertion.
(4)
Scram pilot valves, which control air supplied to the scram valve actuators _and are interconnected with the reactor protection system to function as required to rapidly insert the control rod in response to a reactor scram.
Each hydraulic control unit contains four solenoid operated directional control valves: (1) the insert drive valve opens on an insert signal and supplies drive water to the bottom side of the main drive piston; (2) the insert exhaust valve opens on an insert signal and discharges water from above the drive piston to the exhaust header; (3) the withdrawal drive valve opens on an withdraw signal and supplies drive water to the top side of the main drive piston; (4) the withdrawal exhaust valve opens on a withdraw signal and discharges water from below the d*ive piston to the exhaust
- header, Scram Accumulator Each control rod has an associated scram accumulator which serves as an independent source of energy to initiate scram insertion of the issociated control rod drive. The accumulator is a piston type accumulator connected to a nitrogen cylinder, with the piston serving as the barrier between high pressure nitrogen (source of stored energy) and the water used to initiate a control rod scram.
The charging water header supplies pressurized, filtered, and demineralized water to the scram accumulators. The water is supplied at approximately 1400 psig and maintains the accumulators -
charged and ready for service in the event of a scram. Following a scram, the charging water header routes water to the scram accumulators to refill and recharge the accumulators.
The position of the scram valves and the state of readiness of accumulator are continuously _
monitored by instrumentation on the hydraulic control unit.' A light in the control room indicates when the scram valves for a hydraulic control unit are open, and an alarm is actuated in the control room in the event of water,eakage past the piston or loss of nitrogen pressure.
Prooosed Chance Nc.1:
This proposed change adds a statement to exempt Specification 3.1.3,1, ACTION b from the requirements of Technical Specif; cation 3.0.4. In addition, the BASES section associated with this Technical Specification is being revised to reflect this change.
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m Basis for Proposed Chance No.1:
Technical Specification 3.1.3.1,' ACTION b addresses control rods that are inoperable for reasons other than those determined to be immovable or untrippable, as described in Technical
-Specification 3.1.3.1. ACTION a. In this context, Technical SpecificatiorJ 3.1.3.1, ACTION 6 is.
J generic to the o_ther control rod Technical Spacifications 3.1.3.2, 3.1.3.4,- 3.1.3.5, 3.1.3.6, and 3.1.3.7, which' identify !ndividual types of control rod inoperability. Each of the individual control rod Technical Specifications identifies that the provisions of Technical Specification 3.0.4 are not applicable provided the specification ACTIONS are satisfied, the affected control red is declared i
inoperablo, and the re luirements of Technical SpeSfication 3.1.3.1 ara satisfied Adding an exemption from Technical Specification 3.0.4'to Specification 3.1.3.1, ACTION b allows changing from OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 1 with inoperable controt rods Justification for allowing entry into OPERATIONAL CONDiT!ON 1 from-OPERATIONAL CONDITION 2 may be evaluated in terms of the corresponding impact on plant safety due to the following types of contro! rod inoperability:
Control Rod Scram insertion Times: The most significant impact of withdrawn control rods that i.re declared inoperable due to scram insertion times in excess of 7 seconds would be on the negative ree.ctivity of a scram. Technical Specifications limit the number of such rods to eight and require that the rods be separated from each other by at least two control cells in every direction; Past ana yses' have shown that more than eight control rods with the permitted inoperable distribution co.ild fall completely in contributing to any transient negative reactivity inserticn; however/ the required operating limits ensure the associated safety limit is protected. The reclusions of those.
analyses are applicable whenever the "67 B" scram insertion time requirements are met.- The 67 B scram time curve assumes an average scram insertion time for all operable rods and for the three fastest control rods in every group of four control rods; As part of the reload licensing and determination of operating limits for each cycle specification of r
the scram times assumed to be met are formally transmitted to the fuel vendor. -The reload licensing for the current cycles of Brunswick Units 1 and 2 assume a scram reactivity function basea on the 67 B curve as specified by CP&L for these cycles. These past analyses and the -
current cycle operating limits are applicable when the 67-8 scram curve is enforced. The 67 B-scram time curve is enforced by the requirements of Technical Specifications 3.1.3.3 and 3.1.3.4.
Since the analyses bound operation at any reactor power level, it is not nt,cessary to preclude -
. changing from OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 1 with no more than eight control rods having excessive (inoperable) scram times.
Control Rod Scram Accumulators: The control rod scram accumulators assist reactor pressure with insertion of a control rod in the prescribed time. At full reactor pressure, control rod insertion can be achieved with reactor pressure alone', although the accumulator provides extra margin over the initial portion of the stroke. As reactor pressure falls below the normal full power operating value, the accumulator plays an increasing role in ensuring adequate scram insertion times; therefore, NEDE-14584, " Assurance of Acceptable Scram Through Control Rod Drive Analysis," Section 5.3, C.C. McNeeley, June 1976 8
FSAR Section 4.6.2.3.(a); APED 4853, " Locking Piston Control Rod Drive Design Evaluation Tests," J.E. Benecki, Nov.1965 El-3
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operating at the higher reactor pressures typical of OFERATIONAL CONDITION 1 may be considered more conservative than operating in OPERATIONAL CONDITION 2, in terms of control rod scram accumulator operability. Consequently, there is no safety concern regarding a change to the higher power condition with an inoperable scram accumuiator.
Centrol Rod Drive Coupling: Uncoualing of controi rods trom the control rod drive mechanism is a prerequisite for a postulated Control Rod Drop Accident. The consequences of this accident are --
bounded by the consequences of the accident occurring when reactor power is less thanz 10 percent of rated power, due to the f!ux flattening that results from increased voiding at higher 8
power levels. The consequences remain bounded when analyzed with GEMINI analytical methods recently approved by the NRC; therefore, changing from OPERATIONAL CONDITION 2 to OPEhATIONAL CONDITION 1 with inoperable control rods does not result in an unacceptable level of safety.
n Control Rod Position Indication: The loss of indication for the position of a control rod provides various optional ACTIONS that may be taken to determine the rod position or requires the rod to be fully inserted and disarmed. Below a reector power level of 10 percent, control rod movement is required to be restricted by the Rod Worth Minimizer (RWM). When operating in the RWM range, the optional ACTIONS for loss of control rod position indication are more difficWt to accomplish. 't may be necessary to bypass control rods in the RWM system and invoke the services of a second -
licensed operator or technical staff member. One additional method of determining control rod position is by noting the influence of a control rod on adjacent LPRM monitors. - This method is typically impractical at low reactor flux / power levels; therefore, managing the loss of control rod position indication is more readily accomplished at the higher power levels of OPERATIONAL CONDITION 1.
The limitation on the total number of allowed inoperable control rods in Specification 3.1,3.1,
- ) quired surveillance of the insertion capability of withdrawn control rods in Specification 4.1.3.1.2, and the required average scram times of Technical Specifications 3.1.3.3 and 3.1.3.4 ensure that the resultant control rod worth and scram insertion function remain bounded by the j
values assumed in determining the applicable operating limits in OPERATIONAL CONDITIONS 1 rnd 2.*
Conctgslons of Procosed Chanao No.1:
The proposed changes to Technical Specification 3/4.1.3.1, ACTION b allow continued start up and operation in the event control rods are declared inoperable. This allowance prevents inoperable control rods from causing lost generation without a significant impact on plant safety.
NEDO 10527, " Rod Drop Accident Analysis for Large Boiling Water Reactors," Section 3.3, March 1972 LLA-92-069, General Electric Technical Evaluation - Brunswick Technical Specification Change for LCO 3.1.3.1, November 5,1992.
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y Proposed Chance No. 2:-
This proposed change revises Technical Specification Section 3.1.3.5, Control Rod Scram Accumulators, to sddress operation with more than one inoperable accumulator. The current specification does not address operating with more than one inoperable scram accumulator, thus requiring entry into Specification 3.0.3. Provisions for operating with one ineperable scram accumulator are also being revised to be more consistent with the guldance of NUREG-1433. In addition, the BASES section of Specification 3.1.3.1 is being revised to include the BASES for the.
revisr>d specification, liasis for Prooosed Chano:, No. 2:
The proposed change allows continued operation with multiple inoperable control rod scram accumulators. The proposed cnance is consistent with the philosophy of operation Mth inoperable accumulators presented in NUREG 1433, Standard Technical Specifications for GE BWR/4, The control rod scram accumulators, in combinatior with the reactor steam dome pressure, cause the issociated control rod to be quickly inserted into the core when on automatic or manual scram occurs. The Updated FSAR (Section 3.9.4.1.3.3) states that the scram accumulators are not necessary to meet scram time requirements when operating at full oper +ing pressure.. The proposed change conservatively assumes potential degradation of the scram nsertion time of control rods with inoperable scram accumulators.
Sufficient pressure to scram a control rod is only needed for control rods which are withdrawn, since an inserted control rod already has its negative reactivity inserted. By inserting and hydraulically or electrically disarming the control rod, the need for that control rod to have sufficient pressure to be inserted upon scram is eliminated. Sufficient pressure for scram insertion of a withdrawn control rod is considered available when either the reactor steam dome pressure is greater than 950 psig or the control rod scram accumulator is OPERABLE.
General Electric Report No. RDE 471290, the General Electric Design Basis Document for the Brunswick Control Rod Drive Hydraulic System, includes General Electric's basis for the control rod drive hydraulic system at the Brunswick Plant. The document states that, under normal reactor operating pressure, both the scram accumulator and reactor water pressure will be available to jointly scram the drive. The document further states that the scram accumulator is used to scram the drive during plant startup or when the reactor pressure is less than 950 psig; therefore, ACTION statements have been developed in the proposed specification based on the reactor steam dome pressure being above or below 950 psig, in the proposed specification, control rods with OPERABLE scram accumulators are considered -
capable of meeting the required scram insertion times whenever the charging header pressure is sufficient to keep the individual scram accumulators charged. The charging water header pressure required to ensure minimum scram performance is met is 940 psig (Reference GE Report No. RDE 471290); therefore, ACTION statements for inoperable accumulators are based on ensuring the charging water pressure is greater than 940 psig.
When the reactor pressure is in the normal operating range, control rods with inoperable scram accumulators will fully insert; however, the scram insertion time may be degraded.' When the reactor pressure vessel pressure is below the normal operating range, a withdrawn control rod with
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an inoperable scram accumulator may not be capable of being inserted upon the occurrence of an El-5
'F automatic or manual scram due to the lack of sufficient drive pressures, ' ACTION' statements' require more immediate compensatory measures be taken for this situation.
~-Technical Specification 3.1.3.3 requires the three fastest control rods of each group of four to moet specified notch insertion times and Technical Specification 3,1.3.1r ACTION b requires '
inoperable control rods (including those due to inoperable scram accumulators) to be separated from other inoperable control rods. These specifications, along with the proposed changes to.
Specification 3.1.3.5, ensure scram insertion times such that the scram reactivity insertion is not less than_ that previously ana1yzed.
During operation in OPERATIONAL CONDITION 5, the proposed change allows more than one control rod with an inoperable scram accumulator; however, the change requires all withdrawn control rods with inoperable scram accumulators to be fully inserted with the directional control valves disarmed.
Conclusions of Prooosed Chance No. 2 Basiw The proposed changes to Technical Specification 3/4.1.3.5 will allow continued operation in OPERATIONAL CONDITIONS 1,2, and 5 with one or more control rod scram accumulators _-
inoperable. The proposed changes provide greater operational flexibility for the Brunswick Plant and prevent lost generation opportunity without significantly impacting plant safety. ' In addition, the changes reduce the operator burden for dealing with control rod OPERABILITY issues and eliminate the need for an existing Technical Specification interpretation by allowing continued -
operation with multiple control rod drive scram accumulators inoperable.
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r ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS 50 325 & 50-324 OPERATING LICENSE NOS DPR 71 & DPR 62-REQUEST FOR LICENSE AMENDMENT CRD AND CRD SCRAM ACCUMULATORS -
10 CFR 50.92 EVALUATION The Commission has provided staridards in 10 CFR 50.92(c) for determining whether a significant-harards 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 -
arnendment would not: (1) involve a significant increase in the probability or cansequences 'of an accident previously evaluated, (2) create the possibile:y of a t ew or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
Pursuant to 10 CFR 50.91(a)(1), Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant -
hazards consideration. The bases for this determination are as follows:
Prooosed Chance 1:
This proposed change adds a statement to exempt Specification 3.1.3.1, ACTION b from the requirements of Technical Specification 3.0.4. In addition, the BASES section associated with this Technical Specification is being revised to reflect this change.
Basis For Prooosed Chanoe 1:
The proposed change does not involve a significant hazards consideration for the following reasons:
1.
The proposed change d)es not involve a significant !ncrease in the probability of an accident previously evaluated in the Updated Final Safety Analysis Report (FSAR).
Exemption of Technical Specification 3.1.3.1, ACTION b from the requirements of Specification 3.0.4 allows entering OPERATIONAL CONDITION 1 from OPERATIONAL CONDITION 2 with one or more inoperable control rods. The operability status and function of a control rod does not change when the OPERATIONAL CONDITION of the plant changes; therefore, a change in OFERATIONAL CONDITION is not a precursor of any accident and cannot increase the probability of any accident previously evaluated.
The proposed change does not involve a significant increase in the consequence of any -
accident previously_ evaluated in the Updated Final Safety Analysis Report (FSAR).-
Exemption of Technical Specification 3.1.3.1, ACTION b from the requirements of Specification 3.0,4 allows entering OPERATIONAL CONDITION 1 from OPERATIONAL CONDITION 2 with one or more inoperable control rods. Continued operation in OPERATIONAL CONDITION 1 is currently permitted when no more than eight control rods are inoperable. The consequences of accidents in all OPERATIONAL CONDITIONS are bounded by the consequences of accidents previously evaluated and allowing a change E2-1
L from OPERATIONAL CONDITION 2 to OPERATIONAL COND'ITION 1 does not increase the -
consequences of any accident previously evaluated.
2.
The proposed change does not create the possibility of a new or different kind of accident-
- trom any accident previously evaluated. -
Exemption of Technical Specification 3.1.3.1, ACTION b from the requirements of Specification 3.0.4 allows entering OPERATIONAL CONDITION 1 from OPERATIONAL -
CONOITION 2 with one or more inoperable control rods. Withdrawn inoperable control rods do not affect power any differently than movable and operablo withdrawn control rods.
Changing from OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 1 occurs prior =
to puwer ascension and is not impacted by the presence of control rods that are inoperable.
Thereforei changing from OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 1' does create the possibility of a new or different kind of accident.
3.
The proposed change does not involve a significant reduction in a margin of safety as 1
defined in the basis of any operating license technical specification.
Exemption of Technical Specification 3.1.3.1, ACTION b from the requirements of-Specification 3.0.4 allows entering OPERATIONAL CONDITION 1 from OPERATIONAL-CONDITION 2 with one or more inoperable control rods. Operation in _ OPERATIONAL CONDITION 1 is currently permitted when no more than eight control rods are inoperable.
The proposed change'only allows moving from OPERATIONAL CONDITION 2 to -
OPERATIONAL CONDITION 1 within the restrictions previously evaluated; therefore, this addition does not involve a significant reduction in the margin of safety as defined in the,-
basis of any operating license technical specification.
Prooosed Chanae No. 2:
The proposed change revises Technical Specification Section 3.1.3.5, Control Rod Scram Accumulators, to address operation with more than one inoperable accumulator. The current specification does not address operating with more than one Inoperable scram accumulator, thus requiring entry into Specification 3.0.3. Provisions for operating with one inoperable scram accumulator are also being revised to be more consistent with the guidance of NUREG-1433. In addition, the BASES section of Specification 3.1.3.1 is being revised to include the BASES for the -
revised specification.
Basis for Prooosed Chanae No. 2:
The proposed change does not involve a significant hazards consideration for the following reasons:
1.
The proposed change does not involve a significant increase in the probability.of an accident previously evaluated in the Updated Final Safety Analysis Report (FSAR).
3 Control rod scram accumulators contribute to the mitigation of accidents and anticipated.
operational occurrences and the operability of scram accumulators is not a precursor to any accident previously evaluated. Therefore, multiple inoperable control rod scram accumulators do not increase the probability of any accident previously evaluated.
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The proposed change does not involve a significant increase in the consequence of any accident previously evaluated in the Updated Final Safety Analysis Report (FSAR).
Control rod scram accumulators assist in the rapid insertion of control rods as'part of a reactor scram. The conssouences of many accicents and anticipated operational occurrences are mitigated by reactor scram. The consequences of anticipated. operational, occurrences are evaluated assuming the scram insertion of control rods willinsert a specif ed amount of negative re&ctivity as a function of time and with a certain distribution, in addition to the individual centrol rod scram accu"
-- the reactor steam dome pressure contributes to the rapid insertion of contri
. when a scram occurs.
The scram teactivity function or scram curve that is assumed for the evaluation of operating limits for anticipeted operational occurrences is enforced by the requirements of Te:hnical Specification 3.1.3.3 and 3.1.3.4 with all control rods operable. In the event one -
or more control rods become inoperable, the requirements of Technical Specification 3.1.3.1, ACTION a and 3.1.3.1, ACTION b in combination with the requirements of Technical Specification 3.1.#,.3 and 3.1.3.4 ensure that the assumed scram -
curve and associated operating limits rama'a applicable and valid.
Although a withdrawn control rod will r(ill scram without an operable scram accumulator as a result of the reactor steam dome prrssure when this pressure is within the normal operating range, some degradation o' the scram insertion time may occur.- By declaring all control rods with inoperable scram a:cumulators inoperable and imposing the requirements of Technical Specification 3.1.3.1, /.CTION b, the negative reactivity of the inoperable.
control rods is not needed to ensure that the assumed scram curve remains applicable.
With the reactor steam dome pressure below the normal operating range, rapid insertion of all withdrawn control rods is accomplished by the individual scram accumulators,The requirement to verify the available charging header pressure ensures that all operable scram accumulators are maintained at a sufficient level to accomplish rapid irisertion to meet the:
required scram curve. Furthermore, withdrawn control rods without an operable scram accumulator may not be inserted by the available reactor steam dome pressure and are required to be fully inserted.
The requirements of the proposed change will maintain the applicability of the scram curve assumed in evaluation of the consequences of accidents and anticipated operational occurrences. By maintaining the applicability of these evaluations and the associated' consequences, the proposed change does not increase the consequences of any accident previously evaluated.
2.
The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change allows multiple control rod scram accumulators to be inoperable under conditions that ensure that any such control rods that are withdrawn are capable of insertion or are fully inserted. Scram insertion of control rods serves to mitigate many accidents and anticipated operational occurrences. Operation with multiple scram accumulators inoperable within the guidance of the existing control rod specification does not create the possibility of a new or different kind of accident from any previously evaluated.
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3, The proposed change does not involve a significant reduction in a margin of safety as defined in tt. casts of any operating license technical specification..
Control rod scram accumulators assist in the rapid insertion of control rods as part of a reactor scram..Tts consequences of many accidents and anticipated operational-occunences are miticatetl by reactor scram, The consequences of anticipated operational
. occurrences are evaluated assuming the scram insertion of control rods willinsert a specified amount of negative reactivity as a function of time and with a certain distribution.
The assumptions and results of these evaluations form the basis for certain Technical Specification requirements arid operating limits that protect safety limits defined in the -
operating license technical specificetion, By maintaining the applicability of these evaluations and associated safety limits, the proposed change does not involve a significant reduction in the margin of safety as defined in the basis of any operating license technical specification.
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ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR 71 & DPR 62 -
REQUEST FOR LICENSE AMENDMENT CRD AND CRD SCRAM ACCUMULATORS ENVIRONMENTAL CONSIDERATION _S 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions -
eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of tha facility in accwdance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3) result in an increase in individual or -
I cumulative occupational radiation exposure. Carolina Power & Light Company has reviewed this
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reouest and determined that the proposed amendment meets the eligibility criteria for categorical excitosion eet for+h in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmentalimpact statement or environmental assessment needs to be prepared in connection with the issuance of I
tne amendment. The basis for this determination follows:
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Prooosed Chance No.1:
This proposed change adds a statement to exempt Specification 3.1.3.1, ACTION b from the requirements of Technical Specification 3.0.4.- In addition, the BASES section associated with this Technical Specification is being revised to reflect this change.
Bas _is for ProqgigglChance No.1:
The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
1.
As demonstrated in Enclosure 2, the proposed amendment does not involve a significant i
hazards consideration.
2.
The proposed amendment does not result in a significant change in the types or significant-increase in the amounts of any effluents that may be released offsite. Technical Specification 3.1.3.1 ensures that control rod operability is consistent with that used in the accident analyses. Specifically, control rod functional requirements are given in the -
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-Technical Specifications to ensure that actual control rod drive performance during a plant j-transient is bounded by the reactivity assumed in the safety analysis to be inserted by a j
reactor scram and to maintain the SHUTDOWN MARGIN.
l The proposed change in Specification 3.1.3.1, ACTION b is consistent with existing requirements given in Sections 3.1.3.2, 3.1.3.4, 3.1.3.5, 3.1.3.6, and 3.1.3.7, which are bounded by previous analyses. As such, the proposed change cannot affect the types or amounts of any effluents that may be released offsite.
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3.
. The proposed change will not resul't _in an increase in individual or cumulative occupational -
radiation exposure. Only the allowable operating conditions for certain control rod --
Inoperabilities are affected by the proposed change. The allowable operating conditions after the proposed change will not result in a change in normal background radiation levels within the plant work areas, nor in existing exposure lengths or frequencies. Therefore, the -
- change will have no affect on either individual or cumulative occupational exposure.
Proposed Chance No. 2:
The proposed change revises Technical Specification Section 3.1.3.b, Control Rod Scram Actniutatora, to address operation with more than one inoperable accumulator. The current -
specification does not address operating with more than one inoperable scram accumulator, thus requiring entry into Specification 3.0.3. Provisions for operating with one Inoperable scram accumulator are also being revised to be more consistent with the guidance of NUREG 1433. In addition, the BASES secticn of Specification 3.1.3.1 is being revised to ir)clude the BASES for the revised specification.
Basis for Prooosed Chanoe'No. 2:
The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
1.
- As demonstrated in Enclosure 2, the proposed amendrnent does not involve a significant -
hazards consideration.
2.
The proposed amendment does not result in a significant chege in the types or significant =
1 increase in the mounts of any effluents that may be released offsite.- Technical Specification 3.1.3.5 ensures that control rod scram accumulator operability is consistent with that used in the accident analysis. Specifically, control rod functional requirements are -
given in the Technical Specifications to ensure that actual control rod drive performance during a plant transient is bounded by the rea0tivity assumed in the safety analysis to be inserted by a reactor scram and to maintain the SHUTDOWN MARGIN.
The proposed changes in Technical Specification 3.1.3.5 are consistent with existing requirements given in Technical Specifications 3.1.3.2, 3.1 3.4, 3.1.3.6, and 3.1 3.7, :
which are bounded by previous analyses. As such, the proposed change cannot affect the l
types or amounts of any effluents that may be released offsite.
3.
The proposed chance will not result in an increase in individual or cumulative occupational
_j radiation exposure. Only the allowable operating conditions for certain control rod scram l
I accumulator inoperabilities are affected by the proposed change. The allowable operating-conditions efter the proposed change will not result in a change in normal background' radiation levels within the plant work areas, nor in existing exposure lengths or frequencies.
Therefore, the amendment has no affect on either individual or cumulative occupational exposure.
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