BSEP-96-0447, Application for Amends to Licenses DPR-71 & DPR-62,revising Minimum & Maximum Values of Pressure Suppression Pool Water Vols Contained in TS 3.6.2.1.a.1 & Corresponding Bases
| ML20138K663 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/15/1997 |
| From: | Campbell W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138K667 | List: |
| References | |
| BSEP-96-0447, BSEP-96-447, NUDOCS 9702190087 | |
| Download: ML20138K663 (14) | |
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Carolina Power & Light Company William R. Campbell PO Box 10429 Vice President Southport NC 28461-0429 Brunswick Nuclear Plant January 15,1997 SERIAL: BSEP 96-0447 10 CFR 50.90 TSC 96TSB07 U. S. Nuclear Regulatory Commission ATTN.: Document Control Desk Washington, DC 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 AMENDMENTS REVISION OF SUPPRESSION POOL WATER VOLUME Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These proposed amendments revise the minimum and maximum values of the pressure suppression pool water volumes contained in Technical Specification 3.6.2.1.a.1 and corresponding Bases.
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 proposed license amendments.
In order to allow time for orderly implementation of procedure revisions and incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendment, once approved by the NRC, be issued with an effective date of no later than 30 days from the date of issuance of the amendment.
' Please refer any questions regarding this submittal to Mr. Mark A. Turkal at (910) 457-3066.
Sincerely, William R. Campbell SJG/kah 9702190087 970115
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P PDR 180140 Tel 910 457-2496 Fax 910 457-2803 t
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Document Control Desk BSEP 96-0447 / Page 2
Enclosures:
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Basis for Change Request i
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10 CFR 50.92 Evaluation 3.
Environmental Considerations 4
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' Page Change Instructions i
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Marked-up Technical Specification and Bases Pages - Unit 1 2
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Marked-up Technical Specification and Ba:,es Pages - Unit 2 i
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Typed Technical Specification and Bases Pages - Unit 1 8.
Typed Technical Specification and Bases Pages - Unit 2 William R. Campbell, having been first duly 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 l
sources of his information are officers, employees, and agents of Carolina Power & Light l
Company.
N O h ALs kW Notary (Seal) g My commission expires:
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Document Control Desk BSEP 96-0447 / Page 3 l
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U. S. Nuclear Regulatory Commission ATTN.: Mr. Luis A. Reyes, Regional Administrator
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101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323-0199 i
Mr. C. A. Patterson NRC Senior Resident inspector - Brunswick Units 1 and 2 1
U.S. Nuclear Regulatory Commission ATTN.: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) i 11555 Rockville Pike Rockville, MD 20852-2738 The Honorable R. Hunt Chairman (Acting) - Nodh Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Dayne H. Brown Director-Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources P.O. Box 27687 Raleigh, NC 27611-7687 i
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s ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2
-l NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS, DPR-71 AND DPR-62 i
REQUEST FOR LICENSE AMENDMENTS l
REVISION OF SUPPRESSION POOL WATER VOLUMES j
I BASIS FOR CHANGES Current Reauirement i
Technical Specification (TS) 3.6.2.1.a.1 requires the suppression pool water volume to be 8
. between 87,600 ft and 89,600 ft*.
I Prooosed Chanae
- The proposed change to TS 3.6.2.1.a.1 would require the suppression pool water volume to be between 86,545 ft and 89,843 ft. Corresponding changes to Bases 3/4.6.2 are also made.
Backaround On October 19,'1996, Carolina Power & Light Company (CP&L) completed calculations which indicated that the suppression pool water level operating range of -27 to -31 inches required by TS 3 6 2.1 was not equivalent to the corresponding water volumes of 89,600 ft and 87,600 ft the current Bnmswick Nuclear Plant (BNP) TS. Administrative controls on delnies a+
'el were implemented to ensure the minimum and maximum suppress.o o.
volumes specmeu m i s 3.6.L,.e.1 were maintained. The specific actions taken are reported in
. Licensee Event Report 1-96-15. The resulting suppression pool volume values in the revised BNP calculations were analytically derived based upon a review of plant drawings associated with the suppression chamber and submerged structures. These calculations establish that the
-27" and -31" TS limits of the suppression pool water level correspond to suppression chamber water volumes of 89,843 ft* and 86,545 ft, respectively.
The purpose of this proposed change is to revise the values of the minimum and maximum suppression pool water volumes corresponding to the respective upper and lower limits of the suppression water levels specified in TS 3.6.2.1.a.1 such that the implementation of the administrative controls will no longer be necessary to ensure compliance with Technical Specifications. The administrative controls, which ensure the minimum and maximum volumes
- specified in TS 3.6.2.1.a.1 are maintained, will remain in place until this license amendment request is approved and implemented.
Basis for Prooosed Chanae A calculation of the suppression chamber pool water volume at the low and high suppression pool E1-1
s water levels was recently revised. The revised calculation specifically considers the volume contained within the submerged portions of the downcomers and displacement of water due to the introduction of structural steel components in support of modifications within the suppression chamber in the early 1980s associated with the Mark I containment modifications. This ana!ysis establishes that a suppression pool water level of-27" corresponds to a water volume of 89,843 ft,
and a level of -31" corresponds to a volume of 86,545 ft'.
The change in the suppression pool water volumes associated with the specified suppression pool water levels impacts the capability of the suppression chamber pool to perform its function as the i
heat sink for the reactor primary system energy for postulated plant accidents and transients.
CP&L has evaluated the impact of the revised suppression pool water volume limits. The conclusion of these analyses is that no adverse impact on containment parameters results from the proposed change to the maximum value of the pressure suppression pool volume. The J
proposed change to the minimum value does potentially increase the peak suppression pool water temperature for certain events. However, the increase is not significant and the resulting temperature remains below acceptable limits. These analyses and their results are summarized in the following paragraphs.
i Evaluations of the impact of the proposed change to the suppression pool volume limits for a postulated 1) Loss of Coolant Accident (LOCA),2) Safety Relief Valve (SRV) blowdown (NUREG-0783 Stuck Open Relief Valve Event) and 3) ATWS events conclude that no adverse impact on containment parameters results from the proposed change to the maximum value of the pressure j
suppression pool volume. The proposed change to the minimum value does potentially increase i
the suppression pool water temperature. However, the increase is not significant and the resulting temperature remains below acceptable limits.
Specifically, analyses indicate that the reduction in the minimum suppression pool volume on the j
pool temperatures and pressures following the design basis Loss of Coolant Accident (LOCA) could result in a peak suppression pool water temperature of 199.5'F. These results do not exceed the suppression chamber design feature limit of 200*F as specified in TS 5.2.2.b. The slight increase in the suppression pool water temperature associated with the occurrence of an event coincident with the suppression pool volume at the proposed minimum value, would also result in a slight reduction in the available Net Positive Suction Head (NPSH) for the Residual Heat Removal (RHR) and Core Spray pumps following a design basis LOCA. However, adequate NPSH is maintained throughout the postulated design basis LOCA as shown in Table 1 of this enclosure.
l The impact of the proposed TS suppression pool water volume limit reduction on ATWS events is a small increase in the suppression pool water temperature to 167'F which remains well within the specified limit of 190*F for ATWS events. Reduced water volume also results in a slight increase in the peak local and bulk suppression pool water temperatures for SRV blowdown events; however, the resultant peak bulk and local temperatures of 187.1*F and 198.1*F, respectively, remain within acceptable limits of 200*F and 203*F, respectively.
CP&L analyses also consider the potential impact of the proposed change to the suppression pool water volume limits on the SRV line loads, SRV discharge line reflood height, wetwell pressurization, suppression pool swell loads, vent thrust loads, and condensation oscillation and chugging loads. SRV discharge line loads are affected by the suppression chamber water level.
Although the volume is changing, the bounding levels remain unchanged. Consequently, there is E1-2
no impact on SRV discharge line loads. The increase in suppression pool water volume without changing the corresponding water level will have essentially no impact on the SRV discharge line reflood height. The small volume increase would also result in a drop in the suppression pool temperature; however, the impact on reflood height is negligible. Due to the increased water volume at the high water level, more water is available to absorb the discharged energy; therefore, the suppression pool heat up is decreased, which results in less pressurization of the wetwell. The dominant factor impacting suppression pool swell is the drywell pressurization rate, which is unaffected since the water levelis unchanged. Vent thrust loads and condensation oscillation (CO) and chugging loads are primarily impacted by drywell and wetwell pressure responses. Drywell pressure responses are unchanged, and, as noted above, wetwell pressure responses decrease by a small amount. Therefore, these loads either decrease slightly or remain essentially unchanged. Based on these analyses, CP&L has concluded that the change in suppression pool water volume limits has no adverse impact on these parameters.
Finally, CP&L analyses concluded the reduction in the minimum suppression pool water volume could slightly increase the peak suppression pool temperature (<0.4 F) when an alternative to the RHR shutdown cooling function is used to reach cold shutdown conditions. This potential increase in peak suppression pool temperature, however, has a negligible impact on the time required by BNP TS to reach cold shutdown.
CP&L also reviewed the impact the proposed change to the suppression pool water volume limits could have on the consequences of an Appendix R fire and station blackout (SBO) events. The BNP Appendix R analyses were reviewed to determine the impact from this proposed suppression pool volume limit change. These analyses indicate that the peak suppression pool water temperature increases shghtly as a result of the proposed change; however, the peak suppression pool water temperature of 186.4'F remains below the suppression chamber design feature limit of 200*F stated in TS 5.2.2.b.
The resulting peak temperature for the SBO event, using the assumptions and methodology consistent with the SBO Safety Evaluation (SE) for BNP, is 198.8'F. This value is below the 200"F acceptance criteria stated in the NRC SBO SE (Reference 1, p. 8). A more in-depth discussion of the revised SBO analysis, including the assumptions used, is provided in a CP&L letter to the NRC dated December 23,1996 (Reference 2).
Based on the results of these avaluations, CP&L has concluded that the proposed suppression pool water volume limits preserve accident and event analyses within acceptable limits and have a negligible impact on the time required to reach cold shutdown conditions when utilizing the suppression pool in the event the normal RHR shutdown cooling function is unavailable. The proposed change, therefore, does not analytically impact plant safety and will eliminate the need for administrative controls and restore consistency between the suppression pool water levels and volumes specified in BNP TS 3.6.2.1.
CP&L has included the proposed suppression pool water volume values and referenced this request in the license amendment request for the proposed conversion of the BNP TS to the BWR Improved Standard Technical Specifications (Reference CP&L letter BSEP 96-0414, dated November 1,1996). Therefore, no additional changes to that package result from this proposed change.
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References:
1.
NRC Letter to CP&L, " Station Blackout Evaluation - Brunswick Steam Electric Plant, Units 1 and 2 (NRC TAC Nos. 68520 and 68521)," October 4,1990.
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2.
CP&L Letter to NRC (BSEP 96-0449), Response to Request for Additional Information -
Power Uprate License Amendment Request (NRC TAC Nos. M90644 / M90645),
December 23,1996.
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3.
CP&L Letter to NRC (BSEP 96-0414), License Amendment Request - Conversion to
. improved Standard Technical Specifications, November 1,1996.
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TABLE 1 TO ENCLOSURE 1 ECCS PUMP NPSH i
Pump / Mode Flow /# Pumps Torus Temp NPSH NPSH NPSH Margin
(*F)
Available**
Required (ft. H 0) 2 (ft. H O)
(ft. H O) 2 2
RHR - LPCI 21,000 gpm / 2 161.8*
21.40 20.18 1.22 RHR-11,550 gpm / 2 189.4 21.04 14.47 6.57 Containment Cooling
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6,700 gpm /1 162.5*
23.74 19.42 4.32 Short Term l
4,725 gpm /1 189.4 19.76 13.42 6.34 Long Term The short term temperature is different for the RHR and Core Spray pumps because of the different break locations assumed. The line break location assumed for the Core Spray pumps was the suction side of the recirculation pump, identical to a DBA-LOCA. The line break location assumed for the RHR pumps was the " tee" connection between the RHR discharge piping (LPCI mode) and the discharge piping of the recirculation pump. Although the resulting torus temperature is slightly lower when assuming a break in the recirculation
-pump discharge piping than a break in the suction piping, the resulting NPSH margin for this location is the most limiting due to the higher RHR flowrate.
NPSH values do not credit containment pressurization in accordance with Safety Guide 1.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS REVISION OF SUPPRESSION POOL WATER VOLUMES 10 CFR 50.92 EVALUATION
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l The Commission has provided standards in 10 CFR 50.92 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 consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
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Carolina Power & Light Company has reviewed these proposed license amendment requests and
. believes that their adoption would not involve a significant hazards consideration. The basis for this determination follows.
1.
The proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.
j The proposed change revises the values of the minimum and maximum suppression pool water volume limits. The water inventory of the suppression chamber is not a precursor of an accident and, therefore, cannot increase the probability of an accident previously evaluated. The pressure suppression chamber water pool mitigates the consequences of loss-of-coolant accidents (LOCAs), transients, and other events by providing a heat sink for reactor primary system energy releases. The proposed minimum and maximum pool water volume values will be consistent with the current suppression pool water level limits. No changes to setpoints will be made as a result of the proposed change. The impact of the i
proposed change to the minimum and maximum suppression pool volume limits on the suppression pool temperatures and pressures following a design basis LOCA, an SRV blowdown event, an Anticipated Transient Without Scram (ATWS) event, an Appendix R fire event, and a station blackout event has been evaluated and does not cause accident parameters to exceed acceptable values. In addition, the impact the proposed change has on the time to reach cold shutdown when using the alternate RHR shutdown cooling function j
is negligible.
The potential impact the proposed change to the suppression pool water volume limits has on SRV line loads, SRV discharge line reflood height, wetwell pressurization, suppression i
pool swell loads, vent thrust loads, and condensation oscillation and chugging loads was also reviewed. The proposed change to the suppression pool water volume limits has no adverse impact on any of these parameters.
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The capability of the suppression chamber water pool to perform its mitigative functions is not affected by the proposed change. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.
2.
The proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change revises the values of the minimum and maximum volume of the suppression chamber water pool. Tha proposed change. vill not alter any physical mechanism by which the suppression chamber water pool volurra is maintained between the minimum and maximum values. The suppression pool water level will continue to be maintained between -27 and -31 inches. As a result of the proposed change there are no physical changes to suppression chamber components or instrumentation. No new mode of operation is introduced as a result of the proposed change. Analyses have been performed which conclude that the proposed change would not affect the operability of equipment designed to mitigate the consequences of an accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed license amendment does not involve a significant reduction in a margin of safety.
The proposed change revises the values of the minimum and maximum suppression chamber water pool volumes. The pressure suppression chamber water pool mitigates the consequences of several postulated accidents and transients by providing a heat sink for the primary coolant system. These accidents and events are the postulated design basis LOCA, Safety Relief Valve blowdown, ATWS, Appendix R fire and station blackout events. The j
consequences of the proposed change in the suppression pool water volume limits have been evaluated for these events.
The results of the analyses for the postulated accidents and events indicate the temperature of the suppression pool water could increase slightly as a consequence of the decrease in the minimum suppression pool water volume limit. However, the containment temperatures remain within acceptable values. The impact of the calculated increase in containment i
temperature on the available Net Positive Suction Head (NPSH) for the Residual Heat Removal (RHR) and Core Spray pumps has been evaluated for the postulated design basis LOCA and indicate adequate NPSH is maintained throughout the event.
The potential impact of the proposed change to the suppression pool water volume limits on SRV line loads, SRV discharge line reflood height, wetwell pressurization, suppression pool swell loads, vent thrust loads, and condensation oscillation and chugging loads was evaluated with the conclusion that there are no adverse impacts on these parameters.
In addition, a small suppression pool water temperature increase could result due to the reduction in the minimum suppression pool volume limit in the event reactor shutdown is conducted through a path utilizing the ruppression pool. Such a shutdown path is an E2-2
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alternative to the normal RHR shutdown cooling function, and the small potential increase in temperature results in a negligible increase in the time required to reach cold shutdown conditions. Cold shutdown conditions could still be reached well within the Technical Specification requirements.
The proposed increase in the suppression pool water volume limit does not adversely impact containment parameters as a result of postulated accidents and events. The potential increase in temperature of the pressure suppression pool water does not significantly t
decrease the ability to maintain containment parameters within acceptable limits. The potential increase in time to reach cold shutdown conditions utilizing the suppression pool as an alternative to the normal RHR shutdown cooling function is negligible. Therefore, the proposed change to revise the minimum and maximum suppression water pool volumes does not involve a significant reduction in a margin of safety.
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ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS REVISION OF SUPPRESSION POOL WATER VOLUMES ENVIRONMENTAL CONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions i
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 the facility in accordance 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, or (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power & Light Company has reviewed this request and believes that the proposed 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 of environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows.
1.
These amendments do not involve a significant hazards consideration, as shown in.
2.
The proposed license amendments do not result in a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite. The proposed license amendments do not introduce any new equipment nor do they require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The proposed license amendments do not alter the function of existing equipment and will ensure that the consequences of any previously evaluated accident do not increase. Therefore, CP&L has concluded that there will not be a significant increase in the types or amounts of any effluent that may be released offsite and, as such, does not involve irreversible environmental consequences beyond those associated with normal operation.
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These amendments do not result in an increase in individual or cumulative occupational radiation exposure. No normal operation or accident source terms are impacted by the proposed change. The proposed change does not significantly reduce shielding or result in any increases in personnel entries or stay times for activities conducted in radiation areas.
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i-ENCLOSURE 4 4
I BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 l
REQUEST FOR LICENSE AMENDMENTS REVISION OF SUPPRESSION POOL WATER VOLUMES i
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ENCLOSURE 5 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 l
NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 i
REQUEST FOR LICENSE AMENDMENTS REVISION OF SUPPRESSION POOL WATER VOLUMES MARKED-UP TECHNICAL SPECIFICATION AND BASES PAGES - UNIT 1 i.
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