ML20245J722
| ML20245J722 | |
| 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 | |
| ML20245J725 | List: |
| References | |
| NLS-89-010, NLS-89-10, NUDOCS 8905040232 | |
| Download: ML20245J722 (9) | |
Text
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4 coronne power a usht company P.O. Box 1551
- Raleigh, N.C. 27602 MAY 011989 SERIAL: NLS 010 A. B CUTTER 10CFR50.90 Vice President TSC 88TSB22 Nuclear Services Department.
United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555' l
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 & 50-324,- rcENSE NOS. DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT INTEGRATED LEAK RATE TEST METHODS Gentlemen:
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 for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.
The proposed change revises Technical Specification 4.6.1.2 and associated Bases 3/4.6.1.2 to re-establish acceptability of the ANSI N45.4-1972 specified Total Time data analysis methodology and to clarify that, v' Ten a reduced duration Type A Integrated Leak Rate Test is desirable, it will be conducted per the criteria contained in Bechtel Topical Report BN-TOP-1, Revision 1, dated November 1, 1972. provides a detailed description of the proposed changes and the basis for the changes. details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides instructions for incorporation of the proposed changes into the Technical Specifications for each unit. provides a summary of the proposed Technical Specification changes for each unit on a page by page basis. provides the proposed Technical Specification pages for Unit 1.
Enclosure'6 provides the proposed Technical Specification pages far Unit 2.
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In or: der to allow time for procedure revision and orderly incorporation, into copies of the Technical Specifications, CP&L recyests that the proposed amendments, once c.pproved by the NRC, be issued with an effcctive date to be no later than 60 days from the issuance of the amendment.
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- Please refer any questions regarding this submittal'to Mr. Stephen Di Floyd
- at (919) 546-6901.
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Yours very tru y, A. B. Cutter
[BAB/ PDM / pdm '(\\cor\\88TSB22).
Enclosures:
1.
Basis for Change. Request 2.
10CFRL.92 Evaluation 3.
Instructions.for Incorporation 4.
. Summary List.of Revisions
-5.
Technical Specification Pages - Unit 1 6.
. Technical Specification Pages. 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.
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR REQUEST FOR LICENSE AMENDMENT INTECRATED LEAK RATE TEST METHODS BASIS FOR CHANGE REQUEST I
Proposed Change The proposed change revises Technical Specification 4.6.1.2 and associated Bases 3/4.6.1.2 to re-establish acceptability of the ANSI N45.4-1972 specified Total Time data analysis methodology and to clarify that, when a reduced duration Type A Integrated Leak Rate Test is desirable, it will be conducted per the criteria contained in Bechtel Topical Report BN-TOP-1, Revision 1 dated November 1, 1972.
Easis Prior to November 15, 1988, 10CFR50, Appendix J, III.A.3 specified.that all Type A Integrated Leak Rate Tests be conducted in accordance with the provisions of ANSI N45.4-1972.
Pursuant to Section 7.6 of ANSI N45.4-1972 CP&L requested, and on December 9, 1983 received, permission to use the Bechtel Topical Report, BN-TOP-1, Revision 1 criteria, and to also use the Mass Point data analysis technique, when performing reduced duration primary containment integrated leak rate (Type A) testing.
Changes to BSEP Technical Specifications were not required because BN-TOP-1 used the Total Time data analysis technique, as specified by ANSI N45.4-1972, and had been evaluated by the AEC Regulatory Staff (AEC Letter dated 2/1/73) as an acceptable method for compliance with 10CFR50 Appendix J test requirements.
Use of the Mass Point data analysis technique during reduced duration testing was in addition to the BN-TOP-1, Revision 1 mandated Total Time data analysis technique.
The Maes Point data analysis technique was incorporated in a newer standard, ANSI /ANS 56.8-1981 and in fact was accepted by the NRC Staff as an improved alternative method of calculating containment leakage rates during testing.
l However, a subsequent strict interpretation of the specific wording of i
10CFR50, Appendix J, III.A.3, by referencing only the older ANSI N45.4-1972 standard, precluded use of the Mass Point method unless the licensees who wished to use the Mass Point method applied for an exemption to 10CFR50, Appendix J.
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on Augast 5, 1987, CP&L submitted both the required request for enemption j
from 10CFR50, Appendix J, and the related Technical Specification amendment request to permit usage of the Mass Point methodology at BSEP.
On February 17, 1988, the NRC issued a Safety Evaluation Report (SER) granting the requested exemption with the conditloc that "...a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> [is required] when the Mass Point method is used." (Amendments 116/144, TAC Nos. 66048/66049). As stated in the SER, the NRC basis for the El-1
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s minimum test duration (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) was that Section 7.6fof ANSI N45.4-1972 only allows a test duration less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if approved by the NRC Staff,
'and the only currently approved methodology for such a test is contained in Bechtel Topical R port, BN-TOP-1, Revision 1 dated November 1, 1972.
This approach only allows use of the Total Time method.
Upon review of the NRC SER and the approved BSEP Technical. Specification changes, it has become apparent that, as stated, BSEP Technical Specification 4.6.1.2 and Bases 3/4.6.1.2 could now be' interpreted as precluding.use'of the ANSI N45.4-1972 Total Time. data analysis methodology, and likewise'the BN-TOP-1, Revision 1 reduced duration methodology that uses the Total Time method. This was not the intent of the previous amendment request, nor.do we believe.it was the NRC's intent to preclude their use.
This belief is supported by the November 15, 1988 revision to 10CFR50,.
Appendix J, which added the following words to Section III.A.3:
In addition to the. Total Time.and Point-to-Point' methods described in that standard [ ANSI N45.4-1972)', the Mass Point method, when used with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is an acceptable method to use to calculate leakage rates. A typical description of the Mass Point method can be found in the American National Standard, ANSI /ANS 56.8-1987, " Containment System Leakage Testing Requirements," January 20, 1987.
The Total Time method is an ANSI N45.4-1972 specified method. Further, BN-TOP-1, Revision 1, has been approved (NRC letter dated December 9, 1983) for use at BSEP, and>thereby meets the requirements of ANSI N45.4-1972, Section 7.6.
Therefore, the purpose of the proposed amendment is to re-establish the acceptability of the ANSI N45.4-1972 Total Time data analysis method and to clearly state that the BN-TOP-1, Revision 1 methodology (including Total Time data analysis) will be used when a reduced duration Type A test is desirable.
Re ference s :
AEC letter to Bechtel Corporation dated February 1. 1973
...we [ Regulatory Staff] have concluded that the information in BN-TOP-1, Revision 1, November 1, 1972 will be acceptable by reference in applications for construction permits and operating licenses."
CP&L lettgr dated October 20. 1983. Serial:
LAP-83-412 Requested permission to use BN-TOP 1, Revision 1 criteria, and to also use the Mass Point data analysts technique, when perforains reduced duration Type A tests.
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NRC letter dated December 9. 1983 "The NRC has approved the use of this topical report [BN-TOP-1, Revision 1];
therefore, we have no objection to its use for integrated leakage rate testing at the Brunswick Steam Electtic Plant, Units 1 and 2.
You should, of course, include in ye tr Type A test report required by Appendix J to 10 CFR 50 the calculated leat rate using the mass point technique."
CP&L letter dated Aunust 5. 1987. Serial:
NLS-87-132 Requested exemption from Appendix J, III.A.3 to be allowed to use the Mass Point method.
NRC letter dated February 17. 1988 Granted CP&L's August 5, 1987 exemption request with the condition that a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is required when the Mass Point method is used.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT INTEGRATED LEAK RATE TEST METHODS J0CFR50.92 EVALUATION
'Ibe 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 ci 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 & Lig1t Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration.
The bases for this determination are as follows:
Proposed Chanc.e The proposed change revises Technical Specification 4.6.1.2 and associated Bases 3/4.6.1.2 to re-establish acceptability of the ANSI N45.4-1972 specified Total Time data analysis methodology and to clarify that, when a reduced duration Type A Integrated Leak Rate Test is desirable, it will be conducted per the criteria contained in Bechtel Topical Report BN-TOP-1, Revision 1, dated November 1, 1972.
Basis j
j The change does not involve a significant hazards consideration for the i
following reasons:
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The proposed amendment does not involve a significant increase in the probability of any accident previously evaluated.
ANSI N45.4-1972 specified data analysis methodologies (Total Time or Point-to-Point), ANSI /ANS 56.8-1987 specified Mass Point data analysis methodology, and BN-TOP-1, Revision 1, specified reduced duratfor criteria, using the Total Time data analysis method.
Each of these is ar,NRC Staff endorsed methodology for the calculation of primary containment integrated leakage rates during tests.
These uethods, or cany other calculational method used to i
determine containment leakage rates curing testing, are not j
considered to be an initiator of any accident previously evaluated.
The proposed amendment does not involve a significant increase in the 'ansequencas of any accident previously evaluated. As stated E2-1 i
in 10CFR50, Appendix J, the purpose of the required tests is to assure that "... leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values..."
10CFR50, Appendix J endorses the data analysis methodologies (Total Time and Point-to-Point) specified in ANSI N45.4-1972 as well as the Mass Point method specified in ANSI /ANS 56.8-1987.
Thus, the proposed change meets the purpose of the rule and therefore, does not significantly increase the consequences of a previously evaluated accident.
2.
The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment only provides for the use of NRC Staff endorsed and approved methodologies for the calculation of containment leakage rates during tests. No possibility of a new or different kind of accident is created since the technique used to calculate leak rates during tests, 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 allows BSEP to use either BN-TOP-1, Revision 1, which requires use of the Total Time method when performing reduced duration tests, or the Mass Point method with a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
As stated in the NRC February 17, 1988 SER, "The Mass Point method has been recognized by the professional community as superior to the two other methods, Point-to-Point and Total Time, which are referenced in ANSI N45.4-1972 and endorsed by the current regulations." This preference is based on the fact that the Total Time method is d3 pendent on selection of the first point and it's relation to the remaining points, while the Mass Point method places equal emphasis on each point.
Therefore, with the Mass Point method, an error in the firs t point is not as critical.
This means that the upper 95% confidence interval of the leakage for the Total Time method may be higher than that of the Mass Point method. However, this does not decrease the margin of safety in that the acceptance criteria of an integrated leak rate test is based on leakage at the upper 95% confidence interval being less than the acceptance criteria. Therefore, any data scatter in the Total Time method is accounted for in the statistical analysis and must be within set limits for the test to pass.
Such an error would tyoically yield test results whien would pass using the Mass Point method, but would not pass using the Total Time method.
Thus, to successfully perform a reduced duration BN-TOP-1, Revision 1, test, the tect data must be more consistent than what is required for the successful performance of a Mass Point test.
For this reason, CP&L has concluded that the proposed amendment does not significantly decreasc the margin of
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ENCLOSURE 3 i
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT INTEGRATED LEAK RATE TEST METHODS INSTRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to Operating Licenses DPR-71 and DPR-62) would be incorporated as follows:
UNIT 1 Remove Pare Insert Pace
'I 3/4 6-3 3/4 6-3 B 3/4 6-1 B 3/4 6-1 UNIT 2 Remove Pare Insert Page_
3/4 6-3 3/4 6-3 B 3/4 6-1 B 3/4 6-1 E3 1 1
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ENCLOSURE 4 BRUNSWICK FTEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR-71 & DPR-62 REQUEST FOR LICENSE AMENDMENT INTEGRATED LEAK RATE TEST METHODS
SUMMARY
LIST OF REVISIONS UNIT 1 Pares Description of Channes 3/4 6-3 Revise Technical Specification 4.6.1.2 to state that the' primary containment leakage rates will be determined in conformance with the criteria specified in Appendix J of 10CFR50.
B 3/4 6-1 Revise f.he bases to Technical Specification 3/4.6.1.2 to allow use of the Point-to-Point, Total Time, or Mass Point Method for calculating primary containment leakage rates.
UNIT 2 l
Pares Description of Chances l
3/4 6-3 Revise Technical Specification 4.6.1.2 to state that the primary containment leakage rates will be determined in conformance with the criteria specified in Appendix J of 10CFR50.
B 3/4 6-1 Revise the bases to Technical Specification 3/4.6.1.2 to allow use of the Point-to-Point, Total Time, or Mass Point Method for calculating primary containment leakage rates.
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