ML20203M949
| ML20203M949 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/29/1986 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20203M950 | List: |
| References | |
| NLS-86-312, NUDOCS 8609050203 | |
| Download: ML20203M949 (5) | |
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Cp&L Carolina Power & Light Company SERIAL: NLS-86-312 AUG 29 1966 85TSB09 Director of Nuclear Reactor Regulation Attention:
Mr. Dan Muller, Director BWR Project Directorate #2 Division of BWR Licensing United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT PRIMARY CONTAINMENT ISOLATION VALVE TESTING CONDITIONS
Dear Sir:
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 to the Technical Specifications (TS) for the Brunswick Steam Electric Plant, Unit Nos. I and 2. The proposed change will permit the operability of primary containment isolation valves listed in TS Table 3.6.3-1 to be verified while the unit is in operational conditions other than cold shutdown or refueling.
DISCUSSION Technical Specification 4.6.3.2 requires that each primary containment isolation valve listed in TS Table 3.6.3-1 be demonstrated operable during COLD SHUTDOWN or REFUELING at least once every 18 months. This operability test should verify that the valve actuates to the appropriate position upon receipt of a test signal. This requirement limits the operational flexibility of the plant for those valves capable of being tested during power operation. The Brunswick Updated Final Safety Analysis Report (FSAR),
paragraph 7.3.1.1.9, states the following:
The primary containment isolation and NSSS Shutoff System is testable during reactor operation. Isolation valves can be tested to assure that they are capable of closing by operating manual switches in the Control Room and observing the position lights and any t
associated process effects.
The proposed revision to the Brunswick Technical Specifications will delete the phrase "ducing COLD SHUTDOWN or REFUELING" from Surveillance Requirement 4.6.3.2. This revision would allow primary containment isolation valves to be tested and demonstrated operable where such testing is feasible during power operation. The testing will normally be dbne ih conjunction with logic system functional tests for the instrumentation associated with a given isolation valve.
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411 Fayetteydle Street
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Mr. Dan Mull:r
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NL5-86-312 / P:ge 2 SIGNIFICANT HAZARDS ANALYSIS The Commission has provided standards in 10 CFR 50.92(c) for determining when 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 any 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. Carolina Power & Light Company has reviewed this request and has determined that:
1.
The proposed amendment does not involve a significant increase in the probability or consequences of any accident previously evaluated. As noted in the Brunswick Updated FSAR, the Brunswick primary containment isolation system (including isolation valves) was designed to be testable during reactor operation. Therefore, the level of assurance of valve operability is not affected by conducting the testing during plant operation. The proposed amendment would allow more flexibility of plant operation, thereby avoiding unnecessary plant shutdowns solely to perform surveillance requirements.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change does not affect the design of any safety systems. In addition, the performance of any safety functions is not affected since the surveillance testing is intended to actuate the containment isolation valves to their appropriate isolation position.
3.
The proposed amendment does not involve a significant decrease in a margin of safety. The testing of containment isolation valves with the unit in operation would allow the test conditions to more closely reflect the operating conditions under which the isolation valves are expected to perform their safety function. This can be especially important where thermal expansion and system pressures can affect valve performance. Therefore, the margin of safety ma/ actually be increased if certain containment isolation valves are tested with the unit in operation.
Based on the above reasoning, CP&L has determined that the proposed change does not involve a significant hazards consideration.
ADMINISTRATIVE INFORMATION The revised Brunswick Technical Specification pages are provided in Enclosure 1. The Company has evaluated this request in accordance with the provisions of 10 CFR 170.12 and has determined that a license amendment application fee is required. A check for
$130 is enclosed in payment of this fee.
JMr. Dan Muller NLS-86-312 / Pcg2 3 Please refer any questions regarding this submittal to Mr. Sherwood R. Zimmerman at (919) 836-6242.
Yours very truly f4 i
A. B. Cutter - Vic resident i
l Nuclear Engineering & Licensing l
ABC/ MAT /vaw (4056 MAT)
Enclosure i
cc:
Mr. W. H. Ruland (NRC-BNP)
Dr. J. Nelson Grace (NRC-Ril)
Mr. E. Sylvester (NRC)
Mr. Dayne H. Brown A. B. Cutter, 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 sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.
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BRUNSWICK-1 PROPOSED TS PAGE 86TSB09 (4056 MAT)
SUMMARY
LIST OF REVISIONS PAGE NO.
REVISION 3/4 6-13 Removed the words "During Cold Shutdown or Refueling" from Surveillance Requirement 4.6.3.2 (4056 MAT)
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