ML20213G669
| ML20213G669 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/13/1986 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20213G670 | List: |
| References | |
| 85TSB22, NLS-86-081, NLS-86-81, NUDOCS 8611180255 | |
| Download: ML20213G669 (3) | |
Text
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CD&L Carolina Power & Ught Company SERIAL: NLS-86-081 NOV 131986 85TSB22 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 REQ';EST FOR LICENSE AMENDMENT TEMPERATURE SENSOR RESPONSE TIME TESTING
Dear Mr. Muller:
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 deletes the requirement to perform response time testing on various temperature switches and thermocouples listed in Table 3.3.2-3.
DISCUSSION Currently, Surveillance Requirement 4.3.2.3 requires that the isolation system response time of the applicable functions shown in Table 3.3.2-3 shall be demonstrated to be within its limit at least once per 18 months. As part of this requirement, Table 3.3.2-3 includes the testing of: (1) primary containment isolation within 13 s(conds of indication of high main steam line tunnel temperature (Item 1.d); (2) reactor water cleanup system (RWCS) isolation within 13 seconds of indication of high area temperature (Item 3.b);
(3) RWCS isolation within 13 seconds of indication of high area ventilation temperature gradient (Item 3.c); and (4) high pressure coolant injection isolation within 13 seconds of indication of high HPCI steam line tunnel temperature (Item 4.a.4). Temperature sensors are provided primarily for detection of small line breaks. The Final Safety Analysis Report (FSAR) does not take credit for temperature sensor initiation of main steam line isolation in the event of a main steam line break. Therefore, these sensors are not subject to the design base accident response time.
The present surveillance program utilizes two distinct testing methods to determine the response time of the temperature sensors for the systems described above. However, the test results are not repeatable and, thus, au not give a reliable indication of the real response time. The Brunswick FSAR 13fety analysis does not address individual temperature sensor response times or the response times of the logic systems to which 8611180255 861113 PDR ADOCK 05000324 P
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- NLS-86-081/ Page 2 NOV 131986 the temperature sensors are connected. The isolation times of primary containment, RWCS, and HPCI can be determined by other parameters such as reactor low level, high steam flow, or system low pressure.
In addition, the testing of the RWCS thermocouples requires removal of the devices.
This may result in increased instrument wear causing decreased accuracy and reliability.
Based on the above, CP&L proposes to delete the requirements for response time testing of the temperature sensors discussed. This change is consistent with the requirements for these devices as provided by the GE BWR/4 Standard Technical Specifications and with current Brunswick TS for similar devices.
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 iicense for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would.iot: (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 margin of safety. Carolina Power & Light Company has determined that the requested amendment does not involve a significant hazards consideration for the following reasons:
1.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated because the FSAR safety analysis does not address individual temperature sensor response times or the response times of the logic systems to which the temperature sensors are connected. The purpose of these sensors is to initiate isolation of a given system in the event of a breach in the pressure boundary. The operability status of their safety-related function is adequately monitored by the remaining surveillance requirements of TS 3/4.3.2 (i.e., channel check, channel calibration, channel functional test, and logic system functional test).
2.
For the same reasons as given in item I, the proposed amendment does not create the possibility of a new or different kind of accident than previously evaluated.
3.
The proposed amendment does not involve a significant reduction in a margin of safety. The affected isolation actuation instrumentation response times are only measured and recorded to enhance overall system reliability and to monitor instrument channel response time trends. Since the temperature sensors discussed in this request do not provide repeatable results when tested, the data collected does not serve any useful purpose. The primary containment, RWCS, and HPCI system isolation time is more accurately tested by using other parameters (pressure, flow or level) currently tested by the surveillance requirements, i
Based on the above, CP&L has determined that the proposed amendment meets the criteria of 10 CFR 50.92(c) and, therefore, does not involve a significant hazards consideration.
I r
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Mr. Dan Muller
, NLS-86-081/ Page 3 NOV 131986 ADMINISTRATIV6 INFORMATION The proposed Brunswick-1 and Brunswick-2 TS pages are provided in Enclosures I and 2.
Carolina Power & Light Company has evaluated this request in accordance with the provisions of 10 CFR 170.12 and has determined that a license amendment fee is required. A check for $150 is enclosed in payment of this fee. The Company requests that this amendment be issued by February 27,1987.
Should you have any questions concerning this submittal, please contact Mr. S. R.
Zimmerman at (919) 836-6242.
Your ery tru
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A. B. Cutter - Vice President Nuclear Engineering & Licensing ABC/ MAT /ccj (1852NLU)
Enclosures cc:
Mr. Dayne H. Brown W/ Enclosure Mr. W. H. Ruland (NRC-BNP) W/ Enclosure Dr. J. Nelson Grace (NRC-Ril) W/ Enclosure Mr. E. D. Sylvester (NRC) W/ Enclosure 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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