ML20205M915
| ML20205M915 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/26/1988 |
| From: | Mcduffie M CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20205M919 | List: |
| References | |
| NLS-88-104, NUDOCS 8811030359 | |
| Download: ML20205M915 (13) | |
Text
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0 cp&L Carolina Power & tight Company OCT 26 jggs SERIAL:
NLS 88-104 10CFR50.90 88TSB04 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 6 50-324/ LICENSE NOS. DPR-71 6 DPR-62 REQUEST FOR LICENSE AMENDMENT REACTOR COOLANT SYSTEM PRESSURE / TEMPERATURE LIMITS Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power 6 Light Company (CP6L) hereby requests a revision to the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.
The proposed amendment revises TS Section 3/4.4.6, "Pressure / Temperature Limits" to modify the current TS wording, the Lirniting Conditions for Operation, and Pressure / Temperature Limit Curves consistent with current regulatory guidance.
Revistor, of TS Bases Section 3/4.4.6 is also included to reflect the revised Pressure / Temperature Limit Section. Repagination of TS Sections 3/4.4.6, 3/4.4.7 and 3/4.4.8 is included to accommodate three additional pages resulting from this proposed amendment.
Though it is customary to revise pressure / temperature limit curves only after removing and testing reactor vessel materials surveillance specimens, CP6L has opted for an earlier revision in order to incorporate changes which the NRC has made to Appendix C of 10CFR50 and Regulatory Guide 1.99 via Revision 2.
This submittal therefore, fulfills the requirements of Generic Letter 88-11: "NRC Position On Radiation Embrittlement Of Reactor Vessel Materials And Its Impact On Plant Operations", dated July 12, 1988. provides a detailed description of the proposed changes and the basis for the changes. 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 for each unit. provides a suminary of the proposed Technical Specification
'r changes for each unit on a page by page basis.
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.m Document Centrol Dask NLS-88-104 / Page 2 provides the proposed Technical Specification pages for each unit.
In accordance with the requirements of 10CFR170.12, a check for $150 is also enclosed.
-Please refer any questions regarding this submittal to Mr. Stephen D.
Floyd at (919) 836-6901.
Yours very truly, M. A. McDuffie Senior Vice President Nuclear Generation AWS/aws
Enclosures:
1.
Basis for Change Request 2.
10CFR50.92 Evaluation 3.
Instructions for Incorporation 4.
Summary List of Revisions 5.
Technical Specification Pages cc:
Mr. Dayne H. Brown Dr. J. Nelson Grace Mr. W. H. Ruland Mr. B. C. Buckley M. A. McDuffie, 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, contractora, and agents of Carolina Power &
Light Company.
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50-325 6 50 324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT REACTOR C001 ANT SYSTEM PRESSURE / TEMPERATURE LIMITS BASIS FOR CHANGE REQUEST Prooosed Chance 1 Currently TS Section 3.4.6.1 specifies reactor vessel shell temperature and
' reactor vessel pressure. The proposed changa revises this wording to specify reactor coolant syster temperature ard pressure.
Proposed Change 2 Currently, TS Section 3/4.4.6 includes three temperature / pressure limit curves contained in Figures 3.4.6.1-1 through 3.4.6.1-3.
These curves cover: (1) non-nuclear heatup, low power physics tests and cooldown following a shutdown, (2) criticality and (3) in service hydrostatic tests.
The proponed change replaces the present curves with five new curves which were generated in accordance with current regulatory guidance.
These curves cover the same operational conditions as the previous curves; however, two additional curves are provided for hydrostatic and leak tests. This results in three new hydrostatic and leak test curves which cover operation at less than or equal to 8, 10, and 12 effective full power years (EFPY).
Proposed Channe 3 Currently, TS Section 3.4.6.1 contains limiting conditions for both heatup and cooldown.
The proposed change adds additional limiting conditions for hydrostatic or leak testing along with a limiting condition for the reactor vessel flange and head flange temperatures with the reactor vessel head bolting studs undet tension.
Procosed Change 4 The proposed change repaginates TS Section 3/4.4.6, Section 3/4.4.7 and Section 3/4.4.8 to accommodate three additional pages.
Proposed Change 5 The proposed change revises TS Bases Section 3/4.4.6 to reflect the previously described proposed changes.
Basis General Design Criteria 14 of Appendix A to 10CFR50, "Reactor Coolant Pressure Boundary," requires that the reactor coolant pressure boundary be El-1
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designed, fabricated, erected, and tested to assure ar. extremely low probability of abnormal leakage, rapid failure, or gross rupture.
In order to assess the structural integrity of the reactor vessel, General Design Criteria 32, "Inspection of Reactor Coolant Pressure Boundary," requires a materials surveillance program for the reactor vessel beltline region.
In addition, General Design Criteria 3).,
"Fracture Prevention of Reactor Coolant Pressure Boundary," requires that the reactor coolant pressure boundary be designed with sufficient margin to assure that the boundary continues to behave in a non brittle manner when under stress associated with operation, maintenance and testing.
In order to assure adequate safety margins for the structural integrity of the reactor coolant pressure boundary, pressure / temperature limits are imposed on the pressure boundary during operation and testing. Appendices G and H to 10CFR50 describe the conditions that require pressure / temperature limits and provide the general basis for these limits.
Specifically, these appendices require that pressure / temperature limits provide safety margins at least as great as those recommended in the ASME Boiler and Pressure Vessel Code,Section III.
Appendix G, "Protection Against Nonductile Failure," for heatup, cooldown, and test conditions.
Pressure / temperature limits which provide safety margins when the reactor core is critical, except for low power physics testing, are required by Appendix C to 10CFR50.
Though it is customary to revise pressure / temperature limit curves only after removing and testing reactor vessel materials surveillance specimens, the Company has opted for an earlier revision in order to incorporate changes which the NRC has made to Appendix C of 10CFR50 and Regulatory Guide 1.99 via Revision 2.
Calculations used to generate the new curves were performed in accordance with the requirements of Appendix G to Section III of the ASME Boiler and Pressure Vessel Code and directions contained in the Welding Research Council Bulletin 175 and the Standard Review Plan (NUREG 0800). Nozzle calculations were taken from identical calculations for sister plants.
Specific use was made of the following equations:
KIR - 26.78 + 1.233 exp [0.0145(T-RTNDT + 160)]
where K is the reference stress intensity factor as a function of the IR vessel temperature at the area being analyzed, and the alloy initial reference nil ductility temperature RTNDT, and CK,. + KIT $EIR y
where K is the stress intensity factor caused by membrano stress gg K
is the stress intensity factor caused by thermal gradients IT K
is a function of temperature to RTNDT f the material IR C - 2.0 for heatup and cooldown operations C - 1.5 for hydrostatic and leak testing El 2
i The revised curves are also based on actual neutron flux / fluence data.
These nautron flux / fluence data were determined by cavity dosimetry measurements and transport calculations described in Westinghouse Report WCAP-10903, "Reactor Cavity Neutron Dosimetry Program for Brunswick Unit 2",
and were applied to Unit 1 as well because of the inherent similarities between these units. Reactor vessel material properties reported in General Electric Report NEDO 24161, November 1978 and NEDO-24157, December 1978 titled "Information on Reactor Vessel Material Surveillance Program", for BSEP 1 and 2 respectively were also used.
The results of reactor vessel materials testing, including the initial RTNDT, were contained in these reports. No correction for precision is included in the initial RTNDT, as deteruined with drop weight tests, since any deviation which might be i
derived is insignificant.
The reference temperature increases due to fast neutron (E > 1Mev) fluence resulting from reactor operation. The revised pressure / temperature limit curves include predicted adjustments for this shift in RTNDT, consistent with the indicated effective full power years, and adjustments to account for the location of the pressure sensing instruments. The actual shift in RTNDT of the reactor vessel material will be evaluated periodically by removal and testing of reactor vessel material surveillance specimens.
The curves identify those regions for which the actual curves are based.
These regions include the vessel flange, the feedwater nozzles and the recirculation pump suction (the latter being representative of the vessel beltline region).
These regions were utilized to assure the required margin of safety since they are controlling for the given pressure / temperature ranges within the c.urves.
Revision of the wording in TS Section 3/4.4.6, from reactor vessel shell temperature to reactor coolant system temperature, was done to reflect the fact that the reactor recirculation pump suction temperature is used as an indication of reactor vessel beltline temperature. The recirculation suction temperature is representative of the water temperature in the beltline region and is used because there are no thermocouples within this region.
The additional limiting conditions for operation were added to assure adequate safety margins during hydrottatic and leak testing, and to place limits on the reactor vessel flange and head flange temperatures when the head bolting studs are under tension.
These limiting conditions for operation provide additional operational constraints and safety margin, and were added in accordance with the requirements of Appendix G to 10CFR50.
1 E1 3
e ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 & 50-324 OPERATING LICENSES DPR 71 & DPR 62' REQUEST FOR LICENSE AMENDMENT REACTOR COO 1 ANT SYSTEM PRESSURE / TEMPERATURE LIMITS 10CFR50.92 EVALUATION The Commission has provided standards in 10CFR50.92(c) 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 marl n of safety. Carolina Power & Light Company has i
reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The bases for this' determination are as follows:
i Pronosed Channe 1 The proposed change revises the wording in TS Section 3.4.6.1 to specify reactor coolant system temperature and pressure rather than reactor i
vessel shell temperature and reactor vessel pressure.
Basis The change does not involve a significant hazards consideration for the following reasons:
i 1.
Reactor coolant system temperature and pressure are currently l
utilized to comply with the requirements of TS Section 3/4.4.6 and have been evaluated to confirm that they are representative of the vessel shell temperature and vessel pressure.
The proposed change 4
is being requested to clarify the specification to preclude potential confusion.
The reactor coolant system temperature, measured at the recirculation pump suction, is actually lower than that of the vessel shell during various phases of operation (i.e., reactor startup, operation, and immediately following i
reactor shutdown) because of the effects of gamma heating af the reactor vessel.
Therefore, use of recirculation pump suction temperature is more conservative during these operational phases.
Since the coolant system data is representative of the vessel 1
shell temperature, the probability of a pressure boundary failure will remain the same and will provide the same limitations on the consequences of a pressure boundary failure. Based on this reasoning, CP&L has determined that the proposed amendment does b
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not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because the postulated accident scenario and accident initiators remain the same. Moreover, the source of the data used to satisfy the requirements of TS Section 3/4.4.6 is representative of the reactor vessel shell temperature.
The change in wording will have no impact on reactor coolant system operation and will not create the possibility of any new accident mode.
3.
Revision of the wording to reflect the actual data source will clarify the specification. Since the reactor coolant system temperature (taken at the reactor recirculation pump suction) is representative of, and at times slightly more conservative than the reactor vessel shell temperature, the proposed amenda t does not involve a significant reduction in the margin of safety.
Proposed Chance 2 The proposed change replaces the present temperature / pressure limit curves contained in Figures 3.4.6.1 1 throu6h 3.4.6.1 3 with five new curves. The new curves cover the same operational conditions as the previous curves (i.e., non nuclear heatup, low power physics tests, cooldown following a shutdown, criticality and inservice hydrostatic tests) along with two additional curves for hydrostatic and leak tests.
This results in three hydrostatic and leak test curves which cover testing operations at less than or equal to 8,10, and 12 effective full power years (EFPY).
Basis The change does not involve a significant hazards consideration for the following reasons:
1.
The revised temperature / pressure limit curves are based on the most current regulatory requirements along with actual neutron flux / fluence data. These curves provide the necessary safety nargin to assure structural integrity of the reactor coolant pressure boundary.
This safety margin is designed to preclude the probability of a pressure boundary failure.
The consequences of a pressure boundary failure are not impacted by the proposed change.
Since these curves are based on the most current regulatory guidance and fluence data, CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The accidents analyzed in Chapter 15 of the Updated FSAR are not affected by the revised temperature / pressure limit curves.
These curves are designed to provide fracture protection for the reactor E2 2
coolant pressure boundary and do not create any new accident modes. Accident modes for the reactor coolant pressure boundary, due to nonductile failure, are well understood within the industry.
The temperature / pressure limit curves merely provide the protection mechanisms to preclude such a failure. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Temperature / pressure limit curves are designed to provide a specific margin of safety. This margin is required to be at least as great as that specified in the ASME Boiler and Pressure Vessel Code,Section III, Appendix G, and Appendix G to 10CFR50. The revised curves are based on the latest NRC guidelines ( Regulatory Cuide 1.99, Rev. 2), along with actual neutron flux / fluence data for the Brunswick Units.
Thus, the revised curves provide a greater confidence level than the present curves.
Based on this reasoning CP&L has determined that the proposed amendment does not involve a significant reduction in the margin of safety.
Proposed Chance 3 The proposed change adds additional limiting conditions for operation to TS Section 3.4.6.1 for hydrostatic or leak testing and for the reactor vessel flange and head flange temperatures with the reactor vessel head bolting studs under tension.
Basis The change does not involve a significant hazards consideration for the following reasons:
1.
The proposed limiting conditions for operation provide added protection against the probability of a reactor coolant pressure boundary failure during hydrostatic and leak testing and during conditions when the vessel head boltin6 studs are under tension.
The consequences of a reactor coolant pressure boundary failure are not affected by the additional operational constraints.
Based on this reasoning, CP&L has determined that the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The accidents analyzed in Chapter 15 of the Updated FSAR are not affected by the additional limiting conditions for operation.
The additional operational constraints have been added to comply with the current regulation and provide added reactor coolant pressure boundary protection. As stated previously, accident modes for reactor coolant pressure boundary due to nonductile failure are well understood within the industry.
The revised limiting conditions for operation merely provide an additional protection mechanism without creating any new accident modes.
Therefore, the E2 3
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proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
2 3.
The additional limiting conditions for operation were added to assure adequate safety margins during hydrostatic and leak testing, and to place limits on the reactor vessel flange and head flange temperatures when the head bolting studs are under tension.
These additional operational constraints provide added safety margin relative to the requirements of 10CFR50, Appendix G.
Based j
on this reasoning, CP&L has determined that the proposed amendment j
does not involve a significant reduction in the margin of safety.
I
}
Pronosed Channe 4 The proposed change repaginates TS Section 3/4.4.6, Section 3/4,4.7 and Section 3/4.4.8 to accommodate three additional pages.
Basis i
The change does not involve a significant hazards consideration for the following reasons:
1.
The proposed change is an administrative change to the Technical Specifications to prevent the need for adding subpages.
Repagination is necessary to accommodate additional text and figures, and has no impact on the specification. Therefore, the proposed amendment does not involve a significant increase in the l
probability or consequences of an accident previously evaluated.
2.
The proposed change is purely administrative.
It will provide numerical consistency of the pages within the specified TS j
Sections without creating any change to the technical content of the specifications. Therefore, the proposed amendment does not create the possibility of a now or different kind of accident from any accident previously evaluated.
I 3.
The proposed change is an administrative change. There will be no l
impact on the specification as a result of this change.
The i
change will merely provide numerical consistency of the pages in the specified sections, and will eliminate the need for using j
subpages.
Therefore the proposed amendment does not involve a significant reduction in the margin of safety.
Prooosed Channo 5 i
The proposed change revises TS Bases Section 3/4.4.6 to reflect the l
previously described proposed changes.
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Basis 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 PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 & 50 324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT REACTOR C001 ANT SYSTEM PRESSURE / TEMPERATURE LIMITS INSTRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to I
Operating Licenses DPR 71 and DPR 62) would be incorporated as follows:
UNIT 1 F
Remove Pare Insert Pare VI VI 3/4 4 13 3/4 4 13 3/4 4 14 3/4 4 14 3/4 4 15 3/4 4-15 l
3/4 4 16 3/4 4-16 3/4 4 17 3/4 4 17 3/4 4 18 3/4 4 18 3/4 4 19 3/4 4-19 3/4 4-20 3/4 4-20 3/4 4-21 i
3/4 4-22 3/4 4 23 B3/4 4 3 B3/4 4 3 B3/4 4 4 B3/4 4-4 UNIT 2 Remove Pait Insert Pare VI VI r
3/4 4 13 3/4 4-13 3/4 4 14 3/4 4 14 3/4 4 15 3/4 4 15 i
3/4 4 16 3/4 4-16 L
3/4 4 17 3/4 4 17 3/4 4 18 3/4 4 18 i
3/4 4 19 3/4 4 19
(
3/4 4 20 3/4 4 20
[
3/4 4 21 L
3/4 4-22 3/4 4-23 l
B3/4 4 3 B3/4 4 3 B3/4 4 4 B3/4 4 4 I
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ENCIASURE 4 BRUNSWICK STEAM ELECTRIC PiANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50 324 OPERATING LICENSES DPR 71 & DPR-62 REQUEST FOR LICENSE AMENDMENT REACTOR C001 ANT SYSTEM PRESSURE / TEMPERATURE LIMITS
SUMMARY
LIST OF REVISIONS UNIT 1 Pares Descrintion of Channes VI Revise the Index to reflect repagination 3/4 4-13 Revise the wording and limiting conditions for operation in TS Section 3/4.4.6 3/4 4-14 Add additional text to TS Section 3/4.4.6 3/4 4-15 Revise Figure 3.4.6.1 1 3/4 4-16 Revise Figure 3.4.6.1 2 3/4 4 17 Replace Figure 3.4.6.1-3 with Figure 3.4.6.1-3a 3/4 4 18 Add new Figure 3.4.6.1-3b 3/4 4-19 Add new Figure 3.4.6.1-3c 3/4 4 20 Repaginate to accommodate additional l
text and fi5ures 3/4 4 21 Repaginate to accomrnodate additional text and figures 3/4 4 22 Repaginate to accomrnodate additional text and figures 3/4 4 23 Repaginate to accomanodate additional text ar.d fi ures 5
B3/4 4 3 Revise the affected Bases section B3/4 4 4 Revise the affected Bases section 1
E4 1
UNIT 2 Pages Descriotion of Changes VI Revise the Index to reflect repagination 3/4 4-13 Revise the wording and limiting conditions for operation in TS Section 3/4.4.6 3/4 4 14 Add additional text to TS Section 3/4.4.6 3/4 4-15 Revise Figure 3.4.6.1 1 3/4 4-16 Revise Figure 3.4.6.1 2 3/4 4 17 Replace Figure 3.4.6.1-3 with Figure 3.4.6.1 3a 3/4 4-18 Add new Figure 3.4.6.1-3b 3/4 4 19 Add new Figure 3.4.6.1-3c 3/4 4-20 Repaginate to accomodate additional text and figures 3/4 4 21 Repaginate to accomodate additional text and figures 3/4 4-22 Repaginate to accomodate additional text and figures 3/4 4 23 Repaginate to accomodate additional text and figures B3/4 4 3 Revise the affected Bases section B3/4 4 4 Revise the affected Bases section E4 2
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