ML20138P446

Application for Amend to License DPR-62,revising Tech Specs 3.3.3-1,3.3.3-2 & 4.3.3-1 to Reflect Mods Performed on Automatic Depressurization Sys During Reload 6 Outage Commencing 851201.Fee Paid

ML20138P446
Person / Time
Site:	Brunswick
Issue date:	12/20/1985
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20138P448	List: ML20138P446 ML20138P450
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.18, TASK-TM NLS-85-395, NUDOCS 8512260111
Download: ML20138P446 (3)

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Carolina Power & Ught Company SERIAL: NLS-85-395 DEC 2 01985 Director of Nuclear Reactor Regulation Attention: . Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing United States Nuclear Rebulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO 50-324 / LICENSE NO. DPR-62

. REQUEST FOR LICENSE AMENDMENT NUREG-0737, ITEM II.K.3.18, " ADS LOGIC MODIFICATIONS"

SUMMARY

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision of the Technical

- Specifications (TS) for the Brunswick Steam Electric Plant, Unit No. 2. The proposed revision to TS Tables 3.3.3-1, 3.3.3-2, and 4.3.3-1 reflects modificadons to be performed on the Brunswick-2 Automatic Depressurization System (ADS) during the Reload 6 outage commencing December 1,1985. These modifications will remove the high pressure trip from the ADS logic sequence and add a manual inhibit switch, thereby, eliminating the need for manual ADS actuation to ensure core coverage. A similar request was granted for Brunswick-1 by Amendment No. 87 on July 30,1985.

DISCUSSION Currently, the ADS activates automatically upon coincident signals of low reactor vessel water level, high drywell pressure, and initiation of a low pressure emergency core cooling pump. Modifications to be performed on the ADS logic will remove the need for high drywell pressure indication for automatic initiation of the ADS. As a result, transients which do not directly produce a high drywell pressure signal will be encompassed by the operation of the ADS. A time delay of approximately two minutes af ter receipt of the signals allows the operator to reset the logic and prevent an unnecessary actuation.

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Mr. D, B, Vcssallo NLS-85-395/P;g: 2 The requested TS changes remove the ADS high drywell pressure instruments and add manual inhibit switches to the ADS in TS Tables 3.3.3-1, 3.3.3-2, and 4.3.3-1. A BWROG study of alternatives to the present ADS actuation logic identified modifications to eliminate the need for manual actuation to ensure core coverage in the event of certain accident sequences. The proposed TS change is the second option outlined in the BWROG study and is one of the two options indicated to be acceptable by NRC letter dated June 3,1933. The resulting reduction of logic devices will increase ADS reliability and will provide additional assurance of adequate core cooling by further automating reactor pressure vessel depressurization for certain system isolations and stuck open relief valve events, while satisfying design concerns associated with anticipated transients without scram.

SIGNIFICANT liAZARDS ANALYSIS The Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 59.92(c)). A proposed amendment to an operating license 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 ditterent kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Carolina Power & Light Company has determined that the requested amendment does not:

(1) Involve a significant increase in the pubability or consequences of an accident previously evaluated because the modifications result in an enhancement of the ADS and does not affect performance of the intended safety function. As a result of these modifications, ADS operation will be extended to encompass accident and transient conditions which do not produce a high drywell pressure signal.

(2) Create the possibility of a new or different kind of accident than previously evaluated for the same reasons stated in item (1).

(3) Involve a significant reduction in the margin of safety because removing the need for manual actuation eliminates the possibility of operator error thereby ensuring core coverage. In addition, reduction of the number of logic devices increases ADS reliability.

Based on the above reasoning, CP&L has determined that the proposed changes involve no significant hazards consideration.

ADMINISTRATIVE INFORMATION The proposed Brunswick-2 TS pages are provided in Enclosure 1. Carolina Power & Light Company has evaluated this request in accordance with the provisions of 10 CFR 170.12 and determined that a license amendment application fee is required. A check for

$150.00 is enclosed in payment of this fee.

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,. Mr. Di B1 Vassal 19 NLS-85-395/ Pag; 3 '

- Since these modifications will be carried out during the upcoming Brunswick-2 refueling

+. outage,' issuance of this amendment is required by July 31,1986 to support unit startup.

Please refer any questions concerning this submittal to Mr. Sherwood R. Zimmerman at (919) 836-6242..

Your very tr y, f 1 A. B. Cutter - V e esident Nuclear Engineering & Licensing MAT /crs (2089 MAT)

Enc!osure cc: Mr. W. H. Ruland (NRC-BNP)

, Dr. J. Nelson Grace (NRC-Ril) n Mr. M. Grotenhuis (NRC)

Mr. Dayne H. Brown A. B. Cutter, having been first duly sworn, did depose and say that the information con'tained 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 a=ents g6un,,,,,

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