ML20245B080

Application for Amend to License DPR-62,adding Footnote to Surveillance Requirement 4.6.1.2.b Re Exemption from Type a Testing Required During Reload Scheduled for Sept 1989.Encls Include Description of & Basis for Proposed Changes

ML20245B080
Person / Time
Site:	Brunswick
Issue date:	06/14/1989
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245B081	List: ML20245B080 ML20245B094
References
NLS-89-167, TAC-73271, NUDOCS 8906230005
Download: ML20245B080 (11)

Text

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JUN 141989 SERIAL: NLS-89-167.

A. B CUTTER :10CFR50.90 Vice President Nucioar Services Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk.

Washington,-DC .20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2

. DOCKET No.'50-324/ LICENSE NO. DPR-62 REQUEST'FOR. LICENSE AMENDMENT-TYPE A TESTINC FREQUENCY (NRC. TAC NO. 73271)

Centlemen:

In accordance with the Code.of' Federal Regulations,l Title 10 Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby, requests a revision to the Technical Specifications for the Brunswick.

Steam Electric' Plant (BSEP), Unit 2.

The proposed amendment adds a footnote to Surveillance Requirement 4.6.-l.2.b which provides a one-time exemption from the Type A testing required during-the upcoming Brunswick-2, Reload 8 outage, currently.

scheduled to begin in September 1989. This amendment request is based on'the Company's 10CFR50, Appendix J exemption request, dated May 23, 1989., regarding the Type A testing frequency.for Brunswick-2. Should the exemption be approved, the next Type A test at Brunswick-2 will be performed during the Reload 9 outage, currently scheduled to begin March 1991.

Enclosure 1 provides a detailed description of the proposed changes and

.the basis for the changes.

Enclosure 2. details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 7 is an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical

. exclusion set forth in 10CFR51.22(c)(9); therefore, pursuant to

• 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

Enclosure 4 provides instructions for incorporation of the proposed changes into the Technical Specifications for each unit.

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.. .. Docum:nt Control Desk NLS-89-167'/ Page 2 e 9

Enclosure 5 provides a summary of the proposed Technical Specification'

changes for Brunswick-2 on a page by page basis.

Enclosure 6 provides the proposed Technical Specification page for Unit 0

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l Please refer any questions regarding this submittal to Mr. William R. .

Murray at (919) 546-4661. j d

Yours very tr y,-

f , l A. B. Cutter ABC/ MAT l

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Enclosures:

1. Basis for Change Request

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2. 10CFR50.92 Evaluation

3. Environmental Evaluation

4. Instructions for Incorporation

5. Summary List of Revisions 6'. Technical Specification Page - Unit 2 cc: Mr. Dayne H. Brown Mr. S. D. Ebneter Mr. W. H. Ruland Mr. E. G. Tourigny 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. J l

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My commission expires:

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n l- ENCLOSURE 1 l

l BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT TYPE A TESTING FREQUENCY 1 (NRC TAC No. 73271)

BASIS FOR CHANGE REOUEST Proposed Change The proposed amendment adds a footnote to Surveillance Requirement 4.6.1.2.b which provides a one-time exemption from the Type A testing required during the upcoming Brunswick-2, Reload 8 outage,. currently scheduled to begin in September 1989. This amendment request is based on the Company's 10CFR50, Appendix J exemption request, dated May 23, i 1989, regarding the Type A testing frequency for Brunswick-2. Sh9ald the exemption be approved, the next Type A test at Brunswick-2 will be performed during the Reload 9 outage, currently scheduled to begin March 1991.

Basis Since 1986, the. Company has conducted two Type A (containment integrated leakage rate test - ILRT) tests at Brunswick-2. Each of these tests 'l were considered to be failures due, in part, to leakage penalty additions from Type C (containment isolation valves local leakage rate test - LLRT) testing. The problems identified by the Type C testing were corrected. _0verall, these last two Type A tests have indicated a high degree of containment integrity; however, these failures have forced the unit into an accelerated ILRT testing frequency.

Surveillance Requirement 4.6.1.2.b states, in part:

J If two consecutive Type A tests fail to meet 0.75 L a , a Type A test shall be performed at least every 18 months until two consecutive Type A tests meet 0.75 L, at which time the above t:st schedule may be resumed.

This surveillance requirement is based on the schedule requirements of 10CFR50, Appendix J, Section III.A.6(b). On May 23, 1989, CP&L requested a one-time exemption from the schedule requirements of paragraph III.A.6(b) so that the normal retest schedule can be resumed in accordance with Section III.D. The proposed amendment adds a footnote to Surveillance Requirement 4.6.1.2.b which provides a one-time exemption from the Type A testing required during the upcoming Brunswick-2, Reload 8 outage. This amendment request is based on the Company's 10CFR50, Appendix J exemption request, dated May 23, 1989 El-1 1

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t which providec ' details of'the. Brunswick-2JType A tests, the reasons for' the respective failures,:and th6 actions taken. to correct. the situation.

The previous two. Brunswick-2 ILRT failures were due,to extenuating circumstances.which are not indicative of the overall containment integrity. . While technically considered' failures, these ILRTs have demonstrated a level of, containment integrity which meets or exceeds the 1

' standards required of similar nuclear units. The existing allowable

, leakage rate '(L ) specified in the Brunswick-2 Technical Specifications is0.5%byweig$tperday.'Thisvalueisextremelyconservativewhen compared ~with similar BWRs such as: Hatch,1.2% by weight' per day;

' Millstone, 1.2% by weight'per day; Pilgrim, 1.5% by weight per day; and Duane Arnold', 2% by weight per day. This overly conservative L, limit has resulted-in difficulties in meeting the ILRT limit of . ,

- (0.5) ( . 75)' -10. 375%' by weight per day. -Carolina Power &~ Light Company is in the process.of preparing a license' amendment request which justified raising the L, limit to' 1.0% by weight per day. The. initial 1986 and.1988 ILRT.results'(Mass Point at'95% upper confidence limits) were 0.590 and 0.400 by weight per day, As such, the previous two ILRTs would have passed an ILRT limit of 0.75% by weight per day prior to leakage penalty additions..

TheLpurpose of Type A testing is.to measure and ensure that the leakage

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through the primary containment does not exceed the maximum allowable-

'takage. It also'provides assurance that periodic surveillance,.

maintenance and repairs are made to systems or components penetrating the containment. Containment integrity is best ensured through strong Type B and C testing ~ programs. These programs have proven effective.in

~ identifying problem areas.at Brunswick-2. Accelerated integrated leak rate testing results in elevated outage costs, it unnecessarily' focuses 6: management attention without resulting in a significant ' safety benefit, and it unduly stresses

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m' a primary containment.

Based on the above reasoning, CP&L'is requesting the proposed amendment.

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ENCLOSURE 2  :

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO 2 NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT TYPE A TESTING FREQUENCY (NRC TAC NO. 73271) 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 nargin of safety. Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The base s for this determination are as follows:

Proposed Chance The proposed amendment adds a footnote to Surveillance Requirement 4.6.1.2.b which provides a one-time exemption from the Type A testing required during the upcoming Brunswick-2, Reload 8 outage, currently scheduled to begin in September 1989. This amendment request is based on the Company's 10CFR50, Appendix J exemption request, dated May 23, 1989, regarding the Type A testing frequency for Brunswick-2. Should the exemption be approved, the next Type A test at Brunswick-2 will be performed during the Reload 9 outage, currently scheduled to begin March 1991.

Heal.E The change does not involve a significant hazards co aideration for the following reasons:

1. The proposed amendment does not involve a significant increase in the probability or consequences of a previously evaluated accident. The proposed amendment does not involve any physical changes, additions, modifications, or deletions to existing equipment or systems. The change does not affect the method by l which any safety related equipment or systems perform their intended function. Nor is any safety related setpoint or parameter revised as a result of the change. Therefore, the probability of previously evaluated accidents is not affected by the change.

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The previous two Brunswick-2 ILRTs have demonstrated a level of containment integrity which meets or exceeds the standards required of similar nuclear units. The purpose of Type A testing is to measure and ensure that the leakage th.augh the primary reactor containment does not exceed the maximam allowable leakage.

The testing also provides assurance that periodic surveillance, maintenance and repairs are made to systems or components penetrating the containment. -Containment integrity is best ensured through strong Type B and C testing programs. These-programs have proven effective in identifying problem areas at Brunswick-2. Therefore, the consequences of previously evaluated accidents are not affected by the change.

2. The proposed amendment does not create the possibility of a new or  !

different kind of accident from any accident previously evaluated.

As stated above, the proposed amendment does not involve any i physical changes, additions, modifications, or deletions to l existing equipment or systems. The change does not affect the  !

method by which any safety related equipment or systems perform  !

their intended function. Nor is any safety related setpoint or  !

parameter revised as a result of the change. As such, the proposed amendment can not create the possibility of a new or different kind of accident.

3. The proposed amendment does not involve a significant reduction in the margin of safety. The purpose of Type A testing is to measure and ensure that the leakage through the primary reactor l containment does not exceed the maximum allowable leakage.

The testing also provides assurance that periodic surveillance, maintenance and repairs are made to systems or components i penetrating the containment. Containment integrity is best ensured through strong Type B and C testing programs. These _

erograms have proven effective in identifying problem areas at j Brunswick-2.. The previous two Brunswick-2 ILRTs have demonstrated '

a level of containment integrity which meets or exceeds the standards required of similar nuclear units. Based on the above, it is concluded that the proposed amendment will not result in a significant reduction in the margin of safety.

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ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 NRG DOCKET 50-324-OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT TYPE A TESTINC FREQUENCY (NRC TAC NO. 73271)

ENVIRONMENTAL CONSIDERATION 10CFR51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment vould not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; and (3) result in a significant increase in individual or cumulative occupational l

radiation exposure. Carolina Power & Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9).

Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment. The basis for this determination follows: 1 Pronosed Change The proposed amendment adds a footnote to Surveillance Requirement 4.6.1.2.b which provides a one-time exemption from the Type A testing required during the upcoming Brunswick-2, Reload 8 outage, currently I scheduled to begin in September 1989. This amendment request is based on the Company's 10CFR50, Appendix J exemption request,' dated May 23, 1989, regarding the Type A testing frequency for Brunswick-2. Should '

the exemption be approved, the next Type A test at Brunswick-2 will be performed during.the Reload 9 outage, currently scheduled to begin March 1991.

Basis l

l The change meets the eligibility criteria for categorical exclusion set '

forth in 10CER51.22(c)(9) for the following reasons:

1. As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

l 2. The proposed amendment does not result in a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite. The previous two Brunswick-2 ILRTs have demonstrated a level of containment ,

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integrity <which meets or exceeds the standards required lof similar.

nuclear ~ units. 'The purpose of: Type A testing is to. measure'and ensure.that the leakage through1the primary reactor containment, does not! exceed the maximum allowable leakage. The. testing also-provides assurance that periodic surveillance,= maintenance and' repairs-are made to systems or components penetrating'the containment. Containment integrityLis best ensured through strong; i Type Biand C testing programs. These' programs have proven effective in . identifying problem areas. at Brunswick-2. Since accelerated Type A-testing does notlprovided a significant e

. increase in assurance of primary containment' integrity,.the proposed amendment does not result in a significant change in the types or a significant increase in the amounts of any' effluents that may be released offsite.

3. The' proposed amendment does not result in a 'sig'nificant. increase in individual or. cumulative occupational radiation. exposure. A

one-time relaxation of the Type A testing frequency for Brunswick.2 will result in a slight decrease in the.overall personnel doses for the Brunswick-2, Reload 8 outage.

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, 4 ENCLOSURE 4

(, BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2-NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT TYPE A TESTING FREQUENCY (NRC TAC NO. 73271)

INSTRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to Operating License DPR-62) would be incorporated as follows:

Unit 2 Remove Page Insert Pace 3/4 6-3 3/4 6-3 E4-1 d

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L ENGLDSURE 5 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT TYPE A TESTING FREQUENCY (NRC TAC NO. 73271)

SUMMARY

LIST OF REVISIONS Unit 2 Pares Description of Channes 3/4 6-3 Add footnote to Surveillance Requirement 4.6.1.2.b stating " Brunswick-2 is granted a one-time exemption from the scheduled Type A testing required to be performed during the Reload 8 outage. The next Type A test shall be performed during the Reload 9 outage. Should the Reload 9 Type A test fail, the accelerated testing frequency, required by Appendix J.will be resumed." Otherwise the normal testing frequency (i.e., 40 10 months) will be resumed.

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ENCLOSURE 6 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2-NRC DOCKET 50-324 OPERATING LICENSE DPR-62 REQUEST FOR LICENSE AMENDMENT TYPE A TESTING FREQUENCY (NRC TAC NO. 73271)

TECHNICAL SPECIFICATION PAGE - UNIT 2 l.

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