ML20207S727
| ML20207S727 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/17/1987 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20207S728 | List: |
| References | |
| 84TSBO3, NLS-86-363, NUDOCS 8703200219 | |
| Download: ML20207S727 (3) | |
Text
F
-o COSA Carolina Power & Light Company MR17 W SERIAL: NLS-86-363 84TSB03 10CFR 50.90
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United States Nuclear Regulatory Commission ATTN: 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 i
SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENT
. CONTAINMENT SYSTEMS - PRIMARY CONTAINMENT AIR LOCKS Gentlemen:
SUMMARY
A conference call was held with your staff regarding our license amendment request dated October 24,1984, as supplemented February 27,1985, and July 8,1985. As a result of this call, Carolina Power & Light Company agreed to revise Surveillance Requirement 4.6.1.3 of the pending request to include a requirement to determine the seal leakage rate of the primary containment air lock doors after their use when no maintenance has been performed. During review of this change, the Company identified additional revisions which have also been incorporated. Revised Technical Specification (TS) pages reflecting these changes are included in Enclosures 1 and 2.
DISCUSSION Surveillance Requirement 4.6.1.3.a has been revised to include a requirement to determine the seal leakage rate of the primary containment air lock doors after their use when no maintenance has been performed. This is in accordance with the agreement made during the conference call. Additionally, the seal leakage rate will be determined after a seat replacement is performed.
Surveillance Requirement 4.6.1.3.c has been revised to require verification of air lock interlock operability: (1) prior to establishing primary containment integrity when the air lock has been used; (2) prior to and following a drywell entry when primary containment integrity is required; and (3) following the performance of maintenance affecting the air lock interlock. Item 1 ensures the interlock is operable prior to entering an operating mode requiring primary containment integrity. Item 2 ensures the operability of the interlock during periods when containment integrity is required and the air lock is being used for primary containment access. Item 3 ensures postmaintenance testing of the interlock. This test frequency is consistent with the intent and more restrictive than the guidance of the STS which requires verification of the air lock interlock operability at least once per six months, except that the inner door need not be opened to verify interlock operability when the primary containment is inerted.
8703200219 870317-PDR ADOCK 05000324 l
P PDR 411 reyetteviiie street. e o Box isst. Rafeegn, N. C 27602 g
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f-Director of Nucl: r Rt ctor Regulttion MAR 171987 NJ.5-86-363 / Prge 2 SIGNIFICANT HAZARDS ANALYSIS The Commission has provided standards in 10 CFR 50.92(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 probabilities or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; 1,
or (3) involve a significant reduction in a margin of safety. The pending amendment i
request was prenoticed on August 28,1985,(50 FR 32934). Carolina Power & Light 3
Company has reviewed the additional changes and determined that:
1.-
The proposed additional changes do not involve a significant increase in the probability,or consequences of an accident previously evaluated. The requirement to verify the seat leakage rate of the primary containment air lock doors af ter their use when no maintenance has been performed constitutes an additional control not presently included in the Brunswick TSs. This provides added assurance of air lock operability. The proposed revision to the air lock interlock testing frequency of Surveillance Requirement provides additional assurance of interlock operability when primary containment integrity is required. The surveillance schedule is expanded to verify interlock operability prior to establishing containment integrity and prior to and following drywell entry when containment integrity is required.
This schedule for testing interlock operability prior to and following a challenge of i
the system, rather than on an arbitrary six-month frequency, decreases the probability of an air lock failure when called upon to perform its safety function.
2.
The proposed additional changes do not create the possibility of a new or different kind of accident than previously evaluated because revision of the surveillance requirements associated with the air locks does not affect the method in which the air locks perform their intended safety function. Assurance of the ability to maintain containment integrity is enhanced through' the revised surveillance requirements. Additionally, the air locks are designed to maintain containment integrity whenever it is required and, thereby, mitigate the consequences of an accident.
3.
The proposed additional changes do not involve a significant ieduction in a margin of safety. The expanded surveillance requirements for air lock seal and air lock interlock verification provide additional assurance of air lock operability, thereby
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resulting in an increase in the margin of safety.
l Based on the above reasoning, the Company has determined that the additional changes to the pending request do not involve a significant hazards consideration.
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Director cf Nucl:ar Reactor Regulation MAR 171987 NLS-86-363 / Paga 3 Please refer any questions regarding this matter to Mr. Sherwood R. Zimmerman at (919) 836-6242.
Yours very truly, T
reshent A. B. Cutter - Vice Nuclear Engineering & Licensing ABC/ MAT /kts (5000 MAT)
Enclosures cc:
Mr. W. H. Ruland (NRC-BNP)
Dr. 3. Nelson Grace (NRC-RII)
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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