ML20245J691
| ML20245J691 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/01/1989 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20245J695 | List: |
| References | |
| NLS-89-068, NLS-89-68, NUDOCS 8905040222 | |
| Download: ML20245J691 (10) | |
Text
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- t MAY 01 1989 S IA N
8 A, B CUTTER Vice Presiderit.,
10CFR50.90 Nuclear Services Department 89TSB04 United States Nuclear Regulatory Commission ATTENTION:-Document Control Desk' Uashington, DC 20555 BRUNSUICK STEAM ELECTRIC PLANT, UNIT NO. 1 DOCKET NO. 50 325 / LICENSE NO. DPR-71 REQUEST FOR LICENSE AMENDMENT ONE TIME TECHNICAL SPECIFICATION
' SURVEILLANCE EXEMPTION REQUEST Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, i
Parts'50.90 and 2.101, Carolina Power.6 Light Company (CP&L) hereby requests a revision to the Technical-Specifications for the Brunswick Steam Electric Plant (BSEP), Unit 1.
The proposed change revises the snubber surveillance requirements in Technical Specification 4.7.5.b on a one time basis.
Currently, if one snubber is determined inoperable during a visual inspection, the subsequent visual inspection must be performed within 12 months +/-25%.
The proposed change would establish the next visual inspection interval I
for hydraulic snubbers as 18 months +/-25%. provides a detailed description of the proposed change and the basis for the change. details the basis for the Company's determination that the proposed change does not involve a significant hazards consideration.
- provides instructions for incorporation of the proposed changes into the Technical Specifications for Unit 1. provides a summary of the proposed Technical Specification change for Unit 1 on a page by page basis provides the proposed Technical Specification page for Unit.l.
In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendment, once approved by the NRC, be issued with an l
effective date to be no later than 60 days from the issuance of the 8905040222 890501 k
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amendment.
The 12 month visual inspection interval _ described herein will expire on November 12, 1989; Therefore, CP&L requests completion of Nuclear Regulatory Commission review and issuance of the required amendment no later than October 1, 1989.
j Please refer any questions regarding this submittal to Mr. Stephen D.
Floyd at (919) 546-6901.
Yours very truly, 2
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Enclosures:
1.
Basis for Change Request 2.
10CFR50.92 Evaluation 3.
Instructions for Incorporation 4.
Summary List of Revisions 5.
Technical Specification Pages - Unit 1 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.
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 NRC DOCKET 50-325 OPERATING LICENSE DPR-71 j
REQUEST FOR L' CENSE AMENDMENT i
ONE TIME TECHNICAL SPECIFICATION SURVEILLANCE EXEMPTION REQUEST 4
BASIS FOR CHANGE REQUEST Procosed Chance The proposed change. revises the snubber surveillance requirements in Technical Specification 4.7.5.b to establish a new visual inspection period for snubbers located on the reactor recirculation system.
The existing requirement states that if one snubber is found inoperable during a visual insp;ction, _the subsequent visual inspection of snubbers on that system must be performed within 12 months +/-25%.
The proposed change would establish a one time subsequent visual inspection reriod of 18 months +/-25%.
Basis CP&L believes that adequate justification exists to maintain the visual inspection frequency for snubbers located on the reactor recirculation system at 18 months +/-25%.
This justification is based on the as-found condition of the one snubber that was declared inoperable, and the as-left condition of the balance of snubbers in the plant.
First, the snubber declared inoperable, Snubber 1-B32-inoperablesolelyonthebasisofavisualinspection;{SB5,wasdeclared snubber hydraulicf}uidwasidentifiedonthebodyofthesnubberbythe inspectors, llowever, additional information collected during the inspection would indicate that the snubber was indeed operable. The fluid level was acceptable per procedures and indicated adequate fluid level was available to perform its design function.
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Technical Specification 4.7.5.c states that:
Visual inspections shall verify that: (1) there are no visible indications of damage or impaired OPERABILITY.
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Plant procedures do not require inspectors to attempt to determine the source of leaks of foreign materials.
Consequently, a snubber which may not be leaking, but which may have snubber hydraulic fluid from other sources (e.r.,
fluid addition to snubber in the overhead), can be delineated as leaking.
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A snubber that may appear inoperable during a visual inspection can be i
subs met.gquentlydeterminedoperableprovidedthatcertainconditionsare A maintenance. work request was generated for Snubber 1-B32-SSB5 to determine why hydraulic fluid was present on the body of the snubber and to funct However, in response to a different requirement,jonallytestit.
this snubber was rebuilt before the work could be performed.
Snubber 1-B32-SSBS was scheduled for replacement in accordance with Specification 4.7.5.i.5 Although CP&L generally maintains replacement snubbers available to prevent rebuilding of snubbers during outages, one was not.available.
Consequently, a maintenance work request was generated prior to the outage for removing, rebuilding, functionally testing, and reinstalling this snubber during the outagc.
This work was performed before the snubber could be functionally tested in the as-found condition for visual inspection frequency considerations.
Second, CP&L believes that, if the snubber could have been evaluated and functionally tested, the snubber would have been determined operable per the provisions of Specification 4.7.5.c for the following reasons:
The as-found fluid level indicated that the snubber was full of fluid. This indicates that any fluid leakage rate would have been expected to be insignificant.
Consequently, the snubber would be expected to be able to perform its intended safety function.
3 Technical Specification 4.7.5.c states that:
Snubbers which appear inoperable as a result of visual inspections may be determined OPERABLE for the purpose of establishing the next' visual inspection interval, provided that: (1) the cause of the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type on that system that may be generically susceptible; and (2) the I
affected snubber is functionally' tested in the as-found condition and determined OPERABLE per Specifications 4.7.5.f.
4 Technical Specification 4.7.5.1, snubber seal replacement program.
5 Maintenance activities in response to Specification 4.7.5.1 i
are scheduled independently from maintenance work requests j
that may result form surveillance activities.
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- The rebuilt snubber passed functional testing and did not
' leak. This indicates that any previous leakage would have had to be located at the seal. However, the mechanic who rebuilt the snubber did not notice any seal abnormalities or problems with the installation of the seal. Therefore, reasonable assurance exists that the snubber would have passed the functional test.
l Third, if the inspection frequency is reduced from 18 months to 12 months the inspection would require that Unit i be shutdown just to inspect snubbers located on the reactor recirculation system.
Thesc snubbers are located in the primary containment (drywell) and are inaccessible during normal plant operation.
Furthermore, workers performing this inspection would receive radiation dosage which would otherwise be unnecessary.
Finally, this snubber, even if it was leaking, would not have adversely affected the piping to which it was attached.
Any snubbers which might have been generically susceptible to similar leakage were-inspected during the refueling outage and determined to be acceptable. Thus there is no evidence indicating the existence of a generic problem with similar snubbers of.this type.
In sum, CP&L believes that the circumstances that prompted the change in inspection frequency do not warrant the resulting cold shutdown and additional radiation exposure to workers.
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i ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 NRC' DOCKET 50-325 i
OPERATING LICENSE DPR-71 REQUEST FOR LICENSE AMENDMENT ONE TIME TECHNICAL SPECIFICATION SURVEILLANCE EXEMPTION REQUEST 10CFR50.92 EVALUATION The Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazards consideration exists. A proposed l
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 margin of safety. Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazarda consideration.
The bases for this determination are as follows:
Proposed Channe The proposed change revises the snubber surveillance requirements in Technical Specification 4.7.5.b to establish a new visual inspection period for snubbers located on the reactor recirculation system. The existing requirement states that if one snubber is found inoperable during a visual inspection, the subsequent visual inspection of snubbers in that system must be performed within 12 months +/-25%.
The proposed change would establish a one time subsequent visual inspection period of 18 months +/-25%.
Halls The change does not involve a significant hazards consideration for the I
following reasons:
1.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
CP&L believes that there is reasonable assurance, as explained below, that the snubber that was declared inoperable could have subsequently been determined operable per the provisions of Specification 4.7.5.c.
Consequently, both the probability and consequences of accidents previously evaluated would remain unchanged.
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i First, the snubber declared inoperable, Snubber 1-B32-SSB5, was declared inoperable solely on the basis of a visual inspection; i
snubber hydraulic fluid was identified on the body of the snubber by the inspectors. However, additional information collected during the inspection would indicate that the snubber was indeed operable.
The fluid level was acceptable per procedures and indicated adequate fluid level was available to perform its design function.
A snubber that may appear inoperable during a visual inspection can subsequently be determined operable provided that certain conditions are met.
A maintenance work request was generated for Snubber 1-B32-SSB5 to determine why hydraulic fluid was present on the body of the snubber and to functionally test it.
However, in response to the requirements of Technical Specification 4.7.5.1, this snubber was rebuilt before the work could be performed.
Snubber 1-B32-SSB5 was scheduled for replacement in accordance with Specification 4.7.5.1.
Although CP&L generally maintains replacement snubbers available to prevent rebuilding of snubbers during outages, one was not available.. Consequently, a maintenance work request was generated prior to the outage for removing, rebuilding, functionally testing, and reinstalling this snubber during the outage. This work was performed before the snubber could be functionally tested in the as-found condition for visual' inspection frequency considerations.
Second, CP&L believes that, if the snubber could have been evaluated and functionally tested, the snubber would have been determined operable per the provisions of Specification 4.7.5.c for the following reasons:
The as-found fluid level indicated that the snubber was full j
of fluid.
This indicates that any fluid leakage rate would have been expected to be insignificant.
Consequently, the snubber would be expected to be able to perform its intended safety function.
- The rebuilt snubber passed functional testing and did not leak. This indicates that any previous leakage would have had to be located at the seal. However, the mechanic who rebuilt the snubber did not notice any seal abnormalities or problems with the installation of the seal.
Therefore, l
reasonable assurance exists that the snubber would have l
passed the functional test.
i The determination was not performed because of exceptional circumstances created by other procedural requirements which prompted the snubber to be refurbished before the actions stipulated in Specification 4.7.5.c could be performed.
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However, CP&L believes that the snubber could have successfully met the criteria of Specification 4.7.5.c.
In sum, since there is reasonable assurance that the snubber that was declared inoperable would have been determined operable if it had not been refurbished, CP&L maintains that both the probability and consequences of accidents previously evaluated would remain unchanged.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
As noted above, the proposed amendment only provides for the use of a different schedule for computing snubber inspection frequency. No possibility of a new or different kind of accident is created since the schedule used to calculate snubber inspection frequency, in itself, is not considered to be an initiator of an accident, transient, incident, or event.
3.
The proposed amendment does not involve a significant reduction in the margin of safety. The proposed amendment will continue to require that "all hydraulic and mechanical snubbers
. be OPERABLE " during operational conditions 1, 2, and 3.
For operational conditions 4 and 5, snubbers located on systems required operable in those operational conditions must also be operable.
This was confirmed by inspections performed during the refueling outage. The changes only impact the surveillance frequency for snubbers located on the reactor recirculation system.
CP&L believes that the proposed amendment provides a margin of safety equivalent to the margin of safety provided by Specification 4.7.5.c.
As noted above, CP&L believes that if the snubber that was declared inoperable had not been rebuilt to satisfy a different requirement, it would have been determined operable through functional testing in accordance with Specification 4.7.5.c.
Nevertheless, the snubber has been rebuilt. This assures the snubber has been reinstalled in optimal operating condition and is, therefore, fully capable of performing its design function.
For this reason, CP&L has concluded that the proposed amendment does not significantly decrease the margin of safety.
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ee ENCLOSURE 3-BRUNSWICK STEAH ELECTRIC PLANT, UNIT 1-NRC DOCKET 50-325 j
OPERATING LICENSE DPR-71 1
REQUEST FOR LICENSE AMENDMENT ONE TIME TECHNICAL SPECIFICATION SURVEILLANCE EXEMPTION REQUEST-I INSTRUCTIONS FOR INCORPORATION-
- The proposed change to the Technical Specifications-(Appendix A to g_
Operating License DPR-71) would be incorporated as follows:
UNIT 1
> Remove Pace Insert Page 3/4 7-10 3/4 7-10 1
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ENCLOSURE 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 NRC DOCKET 50-325 OPERATING LICENSE DPR-71 REQUEST FOR LICENSE AMENDMENT ONE TIME TECHNICAL SPECIFICATION SURVEILLANCE EXEMPTION REQUEST
SUMMARY
LIST OF REVISIONS UNIT 1 Panes Description of Channes 3/4 7-10 Revises schedule for snubber visual inspection of snubbers located on the reactor recirculation system.
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