ML20084N772

Application for Amend to License DPR-71,requesting one-time Only Deferment of Tech Spec Required Surveillance Re full-stroke Cycling of Four Reactor Instrumentation Sys Isolation Valves Until 841102 Outage.Fee Encl

ML20084N772
Person / Time
Site:	Brunswick
Issue date:	05/10/1984
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
NLS-84-206, NUDOCS 8405170202
Download: ML20084N772 (8)

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CD&L Carolina Power & Light Company SERIAL: NLS-84-206 MAY 101984 Director of Nuclear Reactor Regulation Attention: Mr. D. B. Vassallo, Chief >

Operating Reactors Branch No. 2 i Division of Licensing ,

United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 1  !

DOCKET FO. 50-325/ LICENSE NO. DPR-71 (

REQUEST FOR LICENSE AMENDMENT  ;

EXCESS FLOW CRECK VALVE SURVEILLANCE INTERVAL EXTENSION

SUMMARY

In accordance with the' Code of Federal Regulations, Title 10, Parts 50.90 l and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Operating License (OL) for the Brunswick Steam Electric Plant, Unit 1.  :

This proposed OL change requests a one-time only deferment of Technical  !

Specification (TS) required surveillance involving full-stroke cycling of four reactor instrumentation. system isolation valves until the outage  ;

scheduled to begin no later than November 2, 1984.

DISCUSSION [

The valves involved in this request are excess flow check valves (EFCV)  :

located in the instrument sensing lines on drywell (DW) penetrations X-53A, ,

X-53B, X-69F,_and X-83A. These instrument lines provide input to reactor l instrumentation transmitters as described below:

Instrument Tag Nos.

Penetration EFCV Function and Function X-53A IB21-F049C Reactor Vessel 1B21-LT-N017A-1 Level Sensing- RPS Channel A "High" Leg Low Level 1 i'

1821-LT-N017A-2 RCIC Channel A High Level Turbine Trip  ;

X-53B IB21-F047C Reactor Vessel IB21-LT-N004C Level Sensing- Feedwater Control

" Reference" Leg High Level Main Turbine Trip k

X-69F IB21-F049D Reactor Vessel IB21-LT-N017D-1 Level Sensing- RPS Channel D j I 9405170202 840510 "High" Leg Low Level 1 d PDR ADOCK 05000325 T P- PDR W {g qkqW >

44, e.yoir...ii. si,.. . e. o. so issi . naieign. N. C. 27602 g ,

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- ,.Mr. Dr. B. Vassallo . 'X-83A 1821-F047D Reactor Vessel IB21-LT-N017D-2 Level Sensing- HPCI Channel D

" Reference" Leg High Level Turbine Trip Attachment 2'provides a diagram which illustrates the equipment arrangement.

Brunswick Steam _ Electric Plant (BSEP) Technical Specification Section 4.6.3.4 l requires that each reactor instrumentation system isolation valve be F demonstrated operable at least every 18 months by cycling each valve through at least one full cycle of travel. The four EFCVs involved in this request were last-tested on October 2, 1982. Utilizing the maximum surveillance period of 125 percent, the latest required performance date is August 19, 1984. This proposed OL-revision will permit a one-time only extension of the surveillance interval until the. outage scheduled to begin no later than

-November 2, 1984. The requested extension results in only an additional 11 weeks, or a 10.9 percent increase, in the maximum surveillance interval permitted by the TS.

.If the unit should experience a forced outage prior to November 2, 1984, the expected duration of the outage will be evaluated. If at any time the expected remaining duration of the outage and unit conditions permit, the

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surveillance will be performed during the forced outage. It is anticipated

- that an outage of at least 10 days duration will be required to permit performance of the testing in a safe manner.

The scheduled date for the next performance of the surveillance test will be based on the original due date, not the extended due date.

The testing of-the EFCV is normally performed during refueling outages at system hydrostatic test conditions. The testing cannot be performed during Operational Conditions 1 or 2 due to the potential for a reactor scram resulting from hydraulic spikes involving the reactor protection system (RPS) safeguard channel transmitter associated with the EFCV being tested and the RPS safeguard channel transmitter which is hydraulically connected to the same

-reactor pressure vessel (RPV) instrument nozzle (see Attachment 2).

Testing in Operational Condition 3 is undesirable from a personnel safety standpoint and the potential for the spread of contamination in the event the EFCV_ fails to properly seat with the primary coolant temperature in excess of

'212*F.

The EFCVs perform reactor coolant system and primary containment isolation functions in the unlikely event of an instrument line failure downstream of the EFCV. The instrument lines involved in this request are seismically qualified and were tested during a reactor pressure vessel hydrostatic test on

, ' June 1,.1983.- In the unlikely event of a downstream piping failure and the simultaneous failure of the associated EFCV, flow through the break would be limited by a 1/4-inch flow restricting orifice located at the RPV instrument nozzle.

Carolina Power & Light Company believes that the extension of the maximum i surveillance intervals from August 19, 1984 until the outage scheduled to begin no later than November 2, 1984 does not result in a significant increase in risk to the public's health and safety.

• Nr. DI. B. Vsesallo REASON FOR REQUEST Carolina Power & Light Company has already made arrangements to purchase-1500.MWe of generation during the summer-peak months due to the unavailability of Brunswick Unit 2 and H. B. Robinson Unit 2 during this period. Even with this additional 500 MWe, the projected CP&L reserves during the week of August 19, 1984 will be only approximately 400 MWe. If Brunswick Unit 1 is required to shut down to perform the EFCV surveillance test, CP&L system generation reserves would be reduced by its 790 MWe generation capability.

Carolina Power & Light Company would then be forced to attempt to purchase additional electric generation during a period of expected high electricity usage. This problem is compounded by the potential for a coal miners' strike-in September of 1984.

The extension of this surveillance until November 2, 1984, will result in the maximum utilization of CP&L nucicar generation capability resulting in the most effective conservation of coal stockpiles with the prospects for a coal miners' strike this fall.

CONCLUSION Carolina Power & Light Company requests a one-time extension of the surveillance requirement for full-stroke testing of four EFCVs due to:

1. Power requirement with low system reserves.

2. Need to stockpile coal.

3. Potential for tripping of the RPS and resultant reactor scram if performed during operation.

4. Potential safety hazard if performed in Operational Condition 3.

5. Minimal extension of 11 weeks (10.9 percent increase) of the maximum surveillance interval permitted by the TS.

SIGNIFICANT HAZARDS ANALYSIS Carolina Power & Light Company has reviewed this request and determined that extending the surveillance interval for the valve cycling of the EFCVs involved, f rom a maximum surveillance interval of 687 days to 762 days, does not constitute a significant reduction in the verification of-operability of the involved EFCVs for the following reasons:

.1. The high level of confidence in the instrument lines involved based on seismic qualification and hydrostatic testing.

2. The minimal increase in probability of a malfunction of the EFCVs resulting from the 11-week (10.9 percent) increase in the maximum surveillance frequency permitted by the TS.

3. The extremely low probability of the simultaneous failure of an instrument line and the associated EFCV.

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- Mr. D B. Vccasilo The proposed change to the OL represents relaxation in the surveillance requirements; however, CP&L believes that the length of the requested extension is minimal with respect to the maximum allowable frequency and that the probability of the need for the EFCVs to function during the proposed extension is very small. Therefore, the result of this change, while reducing the safety margin, is clearly within the acceptance criteria. Thus, this proposed change is similar to an example of "no significant hazards consideration" in the guidance provided by the Commission (48 FR 14870);

namely, a change which "may reduce in some way a safety margin but where the results are clearly within all acceptance criteria with respect to the system as specified in the Standard Review Plan." Carolina Power & Light Company, therefore, believes the proposed change involves no significant hazards consideration.

ADMINISTRATIVE INFORMATION The proposed revision to the Brunswick Unit 1 Operating License is provided in Attachment 1. Carolina Power & Light Company has evaluated this request in accordance with the provisions of 10 CFR 170.22 and has determined that a Class III license amendment fee is required. A check for $4,000 is enclosed in payment of the license amendment fee.

Should you have any questions concerning this submittal, please contact our Licensing Staff.

Yours very tr y, A. B. Cutter - Vice President Nuclear Engineering & Licensing MAT /ccc (9989 MAT)

Attachments cc: Mr. Dayne H. Brown Radiation Protection Branch Division of Facility Services Department of Human Resources Mr. D. O. Myers (NRC-ESEP)

Mr. J. P. O'Reilly (NRC-RII)

Mr. M. Crotenhuis (NRC)

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 af8""""'4,,..

officers, employees, contractors, and agents of Carolina Power & Lighh.p,...... .'f[('

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I ATTACHMENT 1 SERIAL: NLS-84-206 BRUNSWICK STEAM ELECTRIC PLANT

• PROPOSED UNIT 1 OPERATING LICENSE REVISION CP&L SERIAL NO. 84TSB22 i

1 9

(9989 MAT /cfr)

Revise Paragraph C.2.b to read.as follows: j The end of the current surveillance period for the surveillance requirements i below may be extended beyond the time limit specified by Technical l Specification 4.0.2a. After November 2, 1984, the plant shall not be operated in Operational Conditions 1, 2, or 3 until the surveillance requirements  ;

listed below have been completed. Upon accomplishment of the surveillances, the provisions of Technical Specification 4.0.2a shall apply.  ;

Technical Specification 4.6.3.4; as applicable to excess flow check valves  ;

B21-F047C, B21-F047D, B21-F049C, and B21-F049D. ,

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ATTACHMINT 2 SERIAL: NLS-84-206 BRUNSWICK STEAM ELECTRIC PLANT UNIT 1 FLOW CHECK VALVE ARRANGEMENT EXCESS CP&L SERIAL NO. 84TSB22 e

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