ML20236V560
| ML20236V560 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/03/1987 |
| From: | Sylvester E Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| TAC-64910, TAC-64911, NUDOCS 8712040372 | |
| Download: ML20236V560 (5) | |
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DEC 0 31987 Docket Nos. 50-325/324 DISTRIBUTION.
- Docket-File -, i E. Jordan Mr. E. E. Utley NRC & Local PDRs J. Partlow Senior Executive Vice Pre Ehnt PD21 r/f ACRS (10)
Power Supply and Engineering & Construction S. Varga Carolina Power & Light Company G. Lainas P. O. Box 1551 E. Adensam Raleigh, North Carolina 27602 P. Anderson B. Mozafari
Dear Mr. Utley:
E. Sylvester OCG-B
SUBJECT:
JET PUMP SURVEILLANCE REQUIREMENTS AMENDMENT 84TSB32 - REQUEST FOR ADDITIONAL INFORMATION BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 and 2 (TAC NOS. 64910 and 64911)
By letter dated March 3,1987, you submitted an application to revise Brunswick Steam Electric Plant Units 1 and 2, Technical Specification 3/4.4.1.2. These proposed amendments involve changes to Jet Pump Surveillance requirements 4.4.1.2, 4.4.1.2.a. 4.4.1.2.b, 4.4.1.2.c and the corresponding BASES section.
In our review of this amendment application, we find that we need the information requested in the enclosure to complete our review.
Please respond to this request within 30 days of receipt of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
I Sincerely, l
S/
Ernest D. Sylvester, Project Manager Project Directorate 11-1 Division of Reactor Projects I/II
Enclosure:
As stated l
cc: See next page
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D:PD21:DRP PAriddrs'o'n BMozafari/dsf ESylvester EAdensam 12/S/87 12/g/87 12/7 /87 12/o 7/87 l
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Mr. E. E. Utley Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 cc:.
i Mr. P. W. Howe Mr. C. R. Dietz Vice President Plant General Manager i
Brunswick Nuclear Project Brunswick Nuclear Project Box 10429 Box 10429 Southport, North Carolina 28461 Southport, North Carolina 2,8461 Mr. R. E. Jones, General Counsel Mr. H. A. Cole l
Carolina Power & Light Company Special Deputy Attorney General 1
P. O. Box 1551 State of North Carolina Raleigh, North Carolina 27602 Post Office Box 629 Raleigh, North Carolina 27602 Mr. Mark S. Calvert Associate General Counsel Mr. Robert P. Gruber l
1 Carolina Power & Light Company Executive Director I
Post Office Box 1551 Public Staff - NCUC l
Raleigh, North Carolina 27602 Post Office Box 29520 Raleigh,-North Carolina 27626-0520 Mr. Christopher Chappell, Chairman l
l Board of Commissioners Post Office Box 249
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i Bolivia, North Carolina 28422 Mrs. Chrys Baggett State Clearinghouse I
Budget and Management 116 West Jones Street Raleigh, North Carolina 27603 Resident Inspector i
U. S. Nuclear Regulatory Commission l
Star Route 1 Post Office Box 208 1
Southport, North Carolina 28461 l
Regional Administrator, Region 11 U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 i
Atlanta, Georgia 30303 Mr. Dayne H. Brown, Cnief Radiation Protection Branch Division of Facility Services H. C. Department of Human Resources i
701 Barbour Drive Raleigh, North Carolina 27603-2008 k
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ENCLOSURE 1 REQUEST FOR ADDITIONAL INFORMATION BRUNSWICK 1 & 2 LICENSE AMENDMENT JET PUMP SURVEILLANCE REQUIREMENTS DOCKET NOS. 50-325 AND 50-324 1.
The applicability of the surveillar.ce tests designed to ' detect jet pump performance degradation is limited to Operational Condition 1.
- However, there is no change proposed to the requirement that jet pumps be operable in Operational Conditions 1 and 2.
Provide justification for some reasonable expectation that jet punps are operable while in Operational Condition 2.
l This should include a technical specification provision (or at least a procedural commitment) that jet pump operability status will be checked by some feasible means prior to startup (e.g., flow indication from all jet pumps). The need for a comprehensive operability test in Operational Condition 2 may be minimal when considering the required surveillance fre-quency (daily) and the action requirement (cold shutdown in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) in relation to the normal operating time in Operational Condition 2.
2.
Your submittal justifies the proposed revision to Surveillance Requirement 4.4.1.2.C on the basis that it provides a more accurate indication of jet pump operability at lower recirculation pump speeds. This argument appears to be inconsistent with the other proposed revision which appears to request removal of the operability requirement at low pump. speeds (Operational Mode 2). Clairfy whether ' surveillance should or should not be performed as an indicator of jet pump operability prior to startup l
(see item 1 above) and justify your position.
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' 2-3.
How frequently will the baseline data on jet pump operating characteristics be updated? Should new data be acquired for each operating cycle? If so, shouldn't this be stated in the surveillance requirement or in the Bases?
1 4.
Your "Significant Hazards Analysis" states:
"(1) The proposed change does not involve a significant increase in the probability or q
consequences of an accident previously evaluated because jet pumps have no moving parts or operating controls.
Flow through the jet pumps and '
their resulting function of providing the driving flow within the core is l
controlled solely by the operation and control of the recirculation pumps. Therefore, the deletion of the requirement for jet pump operability in Operational Condition 2 does not effect the function, operating or accident analyses of any plant system."
The above analysis is unacceptable for several reasons:
(a) The fact that jet pumps have no moving parts or operational controls is irrelevant to the safety functions of (1) providing the driving flow within the core in accordance with established relationships to recirculation pump flow, and (2) maintaining a blowdown flow area and core water level consistent with assumptions in the design basis LOCA analyses, which require that the mechanical integrity and flow area of the jet pumps be maintained.
(b) Your proposed TS revisions do not delete the requirement for jet pump operability in Operational Condition 2.
However, the first paragraph on page four of your submittal indicates proposed deletion of the.'oper-ability requirement in Operational Condition 2.
If this was your intention, the analysis should address deletion of the operability requirement and how an adequate level of assurance of jet pump oper-ability will be maintained.
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- 4. Your continuing discussion in the same paragraph'of your submittal'has similar-deficiencies. You do not explain how a safety margin is reduced. Please-
. revise your submittal.
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