ML20149D551
| ML20149D551 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/03/1988 |
| From: | Eury L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20149D555 | List: |
| References | |
| NLS-88-021, NLS-88-21, NUDOCS 8802090539 | |
| Download: ML20149D551 (11) | |
Text
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em a u.m c P. O. Box 1551 e Raleigh, N. C. 27602 FEB a E68 SERIAL: N LS-88 -021 10CFR50.90 LYNN W. EURY Senk>r Vice Prescent 87TSB28 operatons support United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 DOCKET NO. 50-324/ LICENSE NO. DPR-62 REQUEST FOR LICENSE AMENDMENT UPGRADED MCPR SAFETY LIMIT, CYCLE 8 Gentlemen:
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 to the Technical Specifications (TS) for the Brunswick Steam Electric Plant, Unit 2 (BSEP-2).
The purpose of this amendment is to incorporate an upgraded Minimum Critical Power Ratio (MCPR) fuel clading integrity safety limit and associated operating limit MCPR values applicable to the operation of BSEP-2 Cycle 8.
This amendment also includes a revision to the TS Bases relative to MCPR safety limit determination.
This license amendment request is being submitted at this time due to recent NRC acceptance (December 27, 1987 letter from NRC to General Electric) of the upgraded MCPR safety limit submitted to the NRC by General Electric on October 2, 1985.
As has been previously discussed with the NRR Project Manager, it has been the intent of the Company to submit a request for license amendment subsequent to this approval.
License amendments related to reload licensing of BSEP-2 Cycle 8 have been previously submitted for the BSEP-2 TS.
Two separate submittals have been proposed by CP&L, with a request that one of the two be issued to support the scheduled startup for BSEP-2 Cycle 8.
The first of these two submittals consisted of a revision which removes cycle specific reload requirements from the TS, while the second submittal included the cycle specific requirements for Cycle 8.
The Company requested that, should the NRC be unable to complete review and issuance of the amendment removing cycle specific requirements by March 1, 1988, that 8802090539 800203 MC*
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Documsnt Control Dask NLS-88-021 / Page 2 the amendment containing cycle specific requirements be issued.
The proposed operating limit MCPR values provided in this request are specific to BSEP-2 Cycle 8.
Should the NRC issue the amendment removing cycle specific requirements by the requested date, then the Company will submit a letter withdrawing the upgraded MCPR amendment request.
Currently BSEP-2 is in the refueling outage prior to the startup for Cycle 8.
Cycle management projections for BSEP-2 Cycle 8 indicate very small margins to the operating limit MCPR values based on the current safety limit MCPR.
Thus, the potential exists that BSEP-2 will experience MCPR limitations that result in the inability to operate at maximum licensed power.
The timely review and issuance of the enclosed amendment will be necessary to enable normal operations during BSEP-2 Cycle 8.
Therefore, CP&L is requesting the issuance of this amendment no later than March 31, 1988 to support the plant startup schedule and avoid a derate of the unit.
The operating limit MCPR values provided in this amendment are based on the operating limit MCPR values provided in the Supplemental Reload Licensing Report for BSEP-2 Cycle 8, which was included in our September 4, 1987 request for license amendment for fuel Cycle No. 8 reload licensing.
The September 4, 1987 request included operating limit MCPR values which reflected an adder of 0.02.
This adder was included to account for operational occurrences such as a main steam line isolation valve out-of-service or a feedwater heater out-of-service, which could impact operation at maximum licensed power.
Due to the projected j
small margins to the operating limit MCPR values for BSEP-2 Cycle 8, the Company has elected not to retain the 0.02 MCPR adder proposed in the previously referenced September 4, 1987 submittal. provides a detailed description of the proposed changes and the basis for the changes.
i details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides instructions for incorporation of the proposed changes into the Technical Specifications. provides a summary of the proposed Technical Specification changes on a page by page basis.
/i Documsnt Control Dank NLS-88-021 / Page 3 provides the proposed Technical Specification pages. providec a. copy of the January 13, 1988 letter from General Electric to CP&L concerning the, effects of the upgraded limit MCPR on operating limit MCPR values.
In accordance with the requirements of 10CFR170.12, a check for $150 is also enclosed.
Please refer any questions regarding this submittal to Mr. Sherwood R. Zimmerman at (919) 836-6242.
Yours very truly,
$4 L. W.
Eur Senior Vice Pr ident EKN/ekn (CYC8MCPR)
Enclosures:
1.
Basis for Change Request 2.
10CFR50.92 Evaluation 3.
Instructions for Incorpcration 4.
Summary List of Revisions 5.
Technical Specification Pages 6.
January 13, 1988 Letter cc:
Mr. Dayne H.
Brown
)
Dr. J.
Nelson Grace Mr. W.
H. Ruland Mr.
E.
D.
Sylvester L.
W. Eury, having been first duly sworn, did depose and say j
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.
1 OLLLu O
bpd u ace Notary (Sepl)
My commission expires:
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 NRC DOCKET 50-324' OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT UPGRADED MCPR SAFETY LIMIT, CYCLE 8 3 ASIS FOR CHANGE REQUEST Procosed Chance 1 Currently, BSEP-2 TS reference the use of a safety limit MCPR value of 1.07.
The proposed amendment changes the MCPR safety limit, specified in the BSEP-2 TS, from 1.07 to 1.04.
Procosed Chance 2 Currently, BSEP-2 TS specify operating limit MCPR values based on the safety limit MCPR value of 1.07.
The proposed amendment adjusts the MCPR operating limits, specified in TS 3/4.2.3, to be consistent with the upgraded safety limit MCPR value of 1.04.
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Procosed Chance 3 Currently, BSEP-2 TS Bases Section 2 contains a description of the input data to the methodology.used for determining the MCPR safety limit.
Much of this data is no longer applicable due to the changes in fuel design characteristics of current reload cores.
The proposed amendment revises the Bases description, consistent with the upgraded MCPR safety limit, and eliminates this out-of-date data.
Basis The Minimum Critical Forer Ratio (M'CPR) fuel cladding integrity safety limit of 1.07, currently used for BSEP-2 reload cores, was established in 1978 based on fuel design characteristics typical of those used at the time.
An upgraded safety limit of 1.04, specified in Amendment 14 to NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel" (GESTAR II), has been approved by the NRC, for D-lattice plants when applied to second successive relcad cores of P8X8R, BP8X8R, GE8X8E or GE8X8EB fuel types with high bundle R-factors (>1.04).
The Brunswicx Plant, Unit 2 is such a D-lattice plant, with Cycle 8 being the third successive reload core with high bundle R-factor fuel designs.
The description of the fuel designs loaded in Cycles 6 through 8 were contained in the amendment requests for those cycles.
Safety limits are established to protect the integrity of El-1
a the fuel cladding during normal operations and anticipated plant transients.
The NRC accepted methodology utilized by General Electric to derive the upgraded safety limit MCPR value of 1.04 was the same methodology used to derive the original safety limit MCPR value of 1.07.
This methodology establishes the MCPR safety limit, based on the acceptance criteria that more than 99.9% of the fuel rods in the core are expected to avoid boiling transition, considering the power distribution within the core and all other uncertainties.
The safety limit MCPR value of 1.04 derived by this methodology, because of the new fuel design characteristics of the reload cores, meets the same criteria as the original safety limit MCPR value of 1.07 and therefore provides the equivalent protection of the fuel cladding.
Since the safety limit MCPR is used to determine the operating limit MCPR values for applying this margin of protection to plant operations, the operating limit MCPR values are being adjusted to be consistent with the upgraded safety limit MCPR.
This adjustment is being made in accordance with the guidance provided in Enclosure 6.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT UPGRADED MCPR SAFETY LIMIT, CYCLE 8 10CFR50.92 EVALUATION The Commission has provided standards in 10CFR50.92(c) for determininJ 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..ew or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration.
Basis Safety limits are established to protect the integrity of the fuel cladding during normal operations and anticipated plant transients.
The fuel cladding integrity safety limit is defined as the critical power ratio in the limiting assembly for which more than 99.9% of the fuel rods in the core are expected to avoid boiling transition, considering the power distribution within the core, and all uncertainties.
This limit is set such that no fuel damage is calculated to occur if the limit is not violated.
The operating limit MCPR values are established for each cycle, based on the safety limit MCPR and the changes in critical power ratio projected to occur during anticipated i
transients, using approved methodologies.
The transients which produce the largest reduction in the critical power l
ratio are considered to be the most limiting and therefore l
require the greatest margin between the safety limit MCPR l
and the operating limit MCPR values.
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The current MCPR fuel cladding integrity safety limit of 1.07 for reload cores was established in 1978.
This safety limit was designed to provide a level of conservatism for establishing operating limit MCPR values, based on fuel design characteristics typical of those utilized at that time.
The level of conservatism built into the safety limit i
provides adequate margin to assure that more than 99.9% of E2-1
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the fuel rods in the core are expected to avoid boiling transition.
Because of current fuel designs, this level of conservatism has been recognized to have shown a marked increase.
This increase in conservatism was part'of the rationale used in developing the upgraded MCPR safety limit of 1.04, specified in Amendment 14 to NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel" (GESTAR II).
This document has been reviewed by the NRC and found to be acceptable for D-lattice plants, when applied to the second successive reload cores of P8X8R, BP8X8R, GE8X8E or GE8X8EB fuel types with high bundle R-factor fuel designs.
The Brunswick Plant, Unit 2 is such a D-lattice plant, with Cycle 8 being the third successive reload core with high bundle R-factor fuel designs.
The proposed change reflects the upgrade in the safety limit MCPR approved in Amendment 14 to NEDE-24011-P-A.
The NRC accepted methodology utilized by General Electric to derive the upgraded safety limit MCPR value of 1.04 was the same methodology used to derive the original safety limit MCPR value of 1.07.
Because of the new fuel design characteristics of the reload cores, the safety limit MCPR value of 1.04 derived by this methodology meets the same criteria (> 99.9%) as the original safety limit MCPR value of 1.07 and therefore provides the equivalent protection of the fuel cladding.
Since the safety limit MCPR is used to determine the operating limit MCPR values for applying this margin of protection to plant operations, the operating limit MCPR values are being adjusted to be consistent with the upgraded safety limit MCPR.
These adjustments are being made in accordance with guidelines provided by General Electric.
The guidelines simply reduce the original operating limit MCPR values, originally identified in the Supplemental Reload Licensing Report (submitted in our letter dated September 4, 1987), by 0.03.
This approach results in a slightly greater and more conservative margin between the adjusted operating limit MCPR values and the safety limit MCPR of 1.04.
Revisions are also being made to the BSEP-2 TS Bases to update the discussion of MCPR safety limit determination and to eliminate the out-of-date data which was used in previous MCPR safety limit determinations.
This data is no longer applicable due to the changes in fuel design characteristics of current reload cores.
Proposed Chance 1:
The proposed amendment changes the MCPR safety limit, specified in the BSEP-2 TS, from 1.07 to 1.04.
The change does not involve a significant hazards consideration for the following reasons:
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1.
The accidents analyzed in Chapter 15 ef the Updated FSAR are not affected by the change in the safety limit MCPR.
The safety limit MCPR is designed to limit the consequences of operational transients previously evaluated, but has no effect on the probability of those transients.
The NRC accepted methodology, used to derive the upgraded safety limit MCPR value of 1.04, applied the same acceptance criteria as that used to derive the original safety limit MCPR value of 1.07 and thus assures that equivalent fuel cladding protection is maintained.
Based on this reasoning, CP&L has determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Adoption of an upgraded safety limit does not change or alter the function of any component or system, including the method of evaluating the MCPR for given operational conditions.
As stated previously, the safety limit MCPR is designed to limit the consequences of those operational transients previously evaluated.
The safety limit MCPR merely set the bounds for acceptable consequences of these operational transients.
Therefore, CP&L has determined that the proposed change does not create thn possibility of a new or different kind of accident from any accident previously eveluated.
3.
As stated previously, the NRC accepted methodology utilized to derive the upgraded safety limit MCPR value of 1.04 provides the equivalent protection of the fuel cladding as the original safety limit MCPR value of 1.07.
Based on this reasoning CP&L has determined that the proposed change does not involve a significant reduction in the margin of safety.
Proposed Chance 2:
The proposed amendment revises the operating limit MCPR values, specified in TS 3/4.2.3, to be consistent with the l
upgraded safety limit MCPR value of 1.04.
The change does not involve a significant hazards consideration for the following reasons:
1.
The accidents analyzed in Chapter 15 of the Updated FSAR are not affected by the change in the operating limit MCPR values.
Operating limit MCPR values are designed to limit the ccnsequences of operational transients previously evaluated, but have no effect on the probability of these transients.
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protection is assured in the upgraded operating limit j
MCPR values since they were adjusted to be consistent with the upgraded safety limit MCPR.
The guidance provided by General Electric to adjust the operating limit MCPR values (originally based on the safety limit MCPR value of 1.07) adds slightly to the conservatism established within these operating limits.
Based on this reasoning CP&L has determined that the proposed change does not involve a signific6nt increase in che probability or consequences of an accident previously evaluated.
2.
Adjustment of the operating limit MCPR values to be consistent with the upgraded safety limit MCPR does not affect the function of any component or system.
The adjusted operating limit MCPR values will continue to provide an adequate margin to assure that the safety limit MCPR is not exceeded for even the most limiting operational transient.
Therefore, CP&L has determined i
that the preoosed change does not create the possibility o.' a new or different kind of accident from any accident previously evaluated.
3.
As stated previously, the NRC accepted methodology utilized to derive the upgraded safety limit MCPR value of 1.04 provides the equivalent fuel cladding protection as the original safety limit MCPR value of 1.07.
This equivalent protection has also been applied to the operating limit MCPR values since they were adjusted to be consistent with the upgraded safety limit MCPR in accordance with the guidance provided by General Electric.
This guidance adds slightly to the conservatism established within the adjusted operating limits which were originally based on the safety limit MCPR value of 1.07.
Based on this reasoning CP&L has determined that the proposed change does not involve a significant reduction in the margin of safety.
Procosed Chance 3:
The proposed change revises the BSEP-2 TS Bases, consistent with the upgraded safety limit MCPR, and eliminates out-of-date input data which had been used in the discussion of, previous MCPR safety limit determinations based on previous fuel designs.
A 10CFR50.92 significant hazards evaluation is not provided for this change since the Bases are only summary statements in support of the Technical Specifications, and are not considered part of the actual Technical Specifications consistent with the provisions of 10CFR50.36.
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ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT UPGRADED MCPR SAFETY LIMIT, CYCLE 8 IllSTRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to Operating License DPR-62) would be incorporated as follows:
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UNIT 2 Remove Pace Insert Pace 2-1 2-1 B2-1 Through B2-8 B2-1 Through B2-8 B2-9 Through B2-13 3/4 1-17 3/4 1-17 3/4 2-8 3/4 2-8 3/4 2-12 3/4 2-12 B3/4 1-2 B3/4 1-2 B3/4 2-3 B3/4 2-3 I
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ENCLOSURE 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT UPGRADED MCPR SAFETY LIMIT, CYCLE 8
SUMMARY
LIST OF REVISIONS UNIT 2 Paces Descriotion of Chances 2-1 Revised the MCPR value specified in the Thermal Power Safety Limit B2-1 Revised the MCPR value specified in Bases Section 2.0 and the wording describing the CPR correlation in Bases Section 2.1.1 B2-2 Revised the description of MCPR safety limit determination in Bases Section 2.1.2.
B2 B2-7 Deleted out-of-date input data New B2-4 Revised the MCPR value specified in Bases Section 2.2.1.1 B2 B2-13 Repaginated due to deletion of text (input data) 3/4 1-17 Revised TS 3.1.4.3.a.3 to incorporate the upgraded safety limit MCPR value j
l 3/4 2-8 Revised TS 3/4.2.3 to incorporate the adjusted operating limit MCPR values 3/4 2-12 Revised TS Table 3.2.3.2-1 to incorporate the adjusted cperating limit MCPR values B3/4 1-2 Revised the MCPR value specified in Bases Section 3/4.1.3 B3/4 2-3 Revised the MCPR value specified in Bases Section 3/4.2.3 E4-1
.