ML20149E191

Forwards Addl Info Addressing NRC 871203 Concerns Re Util 870313 Application for Amends to Licenses DPR-71 & DPR-62, Revising Tech Spec 3/4.4.1.2, Jet Pumps

ML20149E191
Person / Time
Site:	Brunswick
Issue date:	01/06/1988
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
84TSB32, NLS-88-005, NLS-88-5, NUDOCS 8801130247
Download: ML20149E191 (5)

Text

r Cp&L Carolina Power & Light Company JAN 6 Iggp SERIAL: NLS-88-005 84TSB32 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENT JET PUMP SURVEILLANCE REQUIREMENTS Gentlemen:

On March 13, 1987, Carolina Power & Light company submitted a request for license amendment for the Brunswick Steam Electric Plant, Units 1 and 2 to revise the Surveillance requirements specified in Technical Specification 3/4.4.1.2, "Jet Pumps". The purpose of this correspondence is to address concerns, relative to this license amendment request, which were identified by letter from the NRC dated December 3, 1987.

Enclosure 1 contains additional information in support of the proposed amendment and addresses each of the concerns raised by the Staff.

Please refer questions regarding this matter to Mr. Stephen D.

Floyd at (919) 836-6901.

Yours very truly, f S finum Zimmerman Manager Nuclear Licensing Section EKN/ekn cc: Dr. J. Nelson Grace Mr. W. H. Ruland Mr. E. D. Sylvester Enclosure 8801130247 800106 PDR ADOCK O g4 I

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ENCLOSURE 1 As discussed in the initial request for license amendment, the proposed changes to the jet pump surveillance requirements will provide more reliable indications of jet pump performance. The changes are consistent with the guidance specified in the General Electric Service Information Letter No. 330, Supplement 1 (SIL 330), and enhance the ability to detect jet pump hold down beam failures. Additional information relative to each of the proposed changes is provided below.

Surveillance Reauirements - Acolicability The current surveillance testing required by Technical Specification (TS) 4.4.1.2 is designed to provide reliable performance data while the recirculation pumps are operating at medium to high speeds. Reliable data has been obtained at slower recirculation pump speeds (<25 percent of rated thermal power) .

However, data acquired at pump speeds corresponding to Operational Condition 2 (<15 percent of rated thermal power) has proven to be too scattered to provide an effective determination of jet pump pettormance. The proposed TS change would require that the specified TS surveillance apply to only Operational Condition 1. The requirement for jet pump operability would still apply to both Operational Conditions 1 and 2. This approach was discussed with the Staff via telephone ca'l on September 17, 1987. Surveillance requirements for verification of jet pump operability during Operational Condition 2 will be incorporated into the specification and submitted as an additional supplement by March 11, 1988. This surveillance will consist of verifying flow indication for each jet pump prior to entering Operational Condition 2 and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. This flow verification provides a more reliable indication of jet pump operability while in Operational Condition 2 than the present surveillance requirement.

Surveillance Recuirements - Simultaneous Criteria The current TS surveillance requires that three criteria be evaluated to determine jet pump operability; if all three criteria are exceeded simultaneously, then the jet pumps should be declared inoperable and the unit placed in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. With this requirement, only one criteria needs to be monitored and satisfied to satisfy the conditions of the surveillance. The proposed change enhances the surveillance rcquirement by requiring a two-out-of three logic which necessitates testing of at least two criteria to aatisfy the surveillance requirement. This more restrictive surveillance requirement will provido a clearer indication of potential jet pump problems.

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Surveillance Reauirements - Items a and b The current TS 4.4.1.2.a surveillance requires that the recirculation pump flow be within 10 percent of the established speed-flow characteristics. The company agrees with the guidance of SIL 330 to restrict the allowable deviation to 5 percent. The proposed change to 5 percent will enhance the surveillance requirement by forcing additional jet pump performance evaluation when smaller deviations from normal recirculation pump speed-flow characteristics are detected.

The current TS 4.4.1.2.b surveillance requires that indication of total core flow be within 10 percent of the core flow value derived from established power-core flow relationships. This surveillance requirement does provide indication of jet pump performance, but requires a significant amount of analysis time to conclude degradation of jet pump performance. The company concurs with the guidance of SIL 330 in that monitoring of jet pump loop flow / speed ratio will provide a more reliable and offective means for determining jet pump operability. The proposed change will replace the current surveillance requirement with the more reliable surveillance, thus enhancing the ability to detect jet pump degradation.

Surveillance Recuirements - Item c The current TS 4.4.1.2.c surveillance requires that the diffuser-to-lower plenum differential pressure reading on any individual jet pump be within 10 percent of the mean of all jet pump differential pressures in the loop. The proposed change would compare the diffuser-to-lower plenum differential pressure reading of each jet pump to the established operating characteristics for that specific pump. This approach is consistent with the guidance of SIL 330 and will provide a more accurate indication of jet pump operability through all ranges of recirculation pump speed associated with operational condition 1 and >15 percent of rated thermal power. The present surveillance is accurate only at high recirculation pump speeds; therefore, the proposed change will enhance the jet pump surveillance program.

Bases The proposed revision to the Bases 3/4.4.1 will provide additional information describing the methods required to establish acceptance criteria in the proposed surveillance. The present surveillance is based on deviation from analytically evaluated operating relationships. The proposed TS uses deviations from established relationships. These established relationships are based on operational data which has been collected in past for both BSEP Units 1 and 2. Any significant alteration or replacement of the system piping or major components would require testing and/or evaluations to determine the need for updating the baseline data. This method of El-2

analyzing acceptance criteria based upon established data is consistent with the guidance provided in SIL 330 and provides a

-ore accurate means of detecting jet pump problems, i

The following information is provided in response to each of the specific questions contained in the previously referenced NRC i letter.

Response to Question 1: l The proposed change would require that TS 4.4.1.2 apply to only Operational Condition 1. The requirement for jet pump operability would still apply to both Operational Conditions 1  ;

and 2. A stated previously, surveillance requirements for verification of jet pump operability during Operational  !

Condition 2 will be incorporated into the specification and  ;

submitted as an additional supplement by March 11, 1988. This '

surveillance will consist of verifying flow indication for each jet pump prior to entering operational Condition 2 and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter.

t Response to Question 2: i The proposed change to TS 4.4.1.2.c would, as previously stated, apply to only operational Condition 1. The reference to more accurate indication of jet pump operability at lower recirculation pump speeds was not intended to refer to Operational Condition 2, but rather to slower recirculation pump speeds within Operational Condition 1. The proposed change will enhance the jet pump surveillance program by providing a more accurate indication of jet pump operability through all ranges of recirculation pump speed associated with operational conditien 1 Response to Question 3: i As previously stated, baseline data has been compiled in the past for both BSEP Units 1 and 2. This data is sufficient to establish an accurate baseline to whica jet pump operability can  !

be compared. This baseline data will remain accurate as long as there are no significant alterations to the configuration of the  :

recirculation system. Any significant alterations would require  !

testing and/or evaluations to determine the need for updating the f baseline data.

Response to Question 4:

It was not intended to delete the operability requirement for Operational Condition 2, as stated in the original submittal, but rather to not require the specified surveillance for Operational

Condition 2. Appropriate Surveillance Requirements for jet pump l operability for operational condition 2 will be incorporated into j the specification and submitted seperately as previously stated.  !

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The Significant Hazards Analysis for this additional surveillance (Operational condition 2) will also be revised and submitted along with the March 11, 1988 supplement.

Conclusion The previously described proposed changes are being requested to conform to the guidance specified in SIL 330 and to improve the effectiveness of the jet pump surveillance program. The Company believes that these changes will provide a more accurate indication of jet pump performance and will enhance the ability to detect potential problems with the jet pump hold down beams.

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