ML20137Z382
| ML20137Z382 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/18/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20137Z375 | List: |
| References | |
| NUDOCS 9704240129 | |
| Download: ML20137Z382 (17) | |
Text
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p UNITED STATES
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NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 30646 4001 i
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i SAFETY EVALUATION BY THE OFFICE 0.F NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. I84 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO. 215TO FACILITY OPERATING LICENSE NO. DPR-62 I
CAROLINA POWER & LIGHT COMPANY l
BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1 AND__2 DOCKET NOS. 50-325 AND 50-324
1.0 INTRODUCTION
By letter dated March 27, 1997, and April 11, 1997, Carolina Power and Light Company (CF&L), the licensee for Brunswick Steam Electric Plant (BSEP), Units 1 and 2, requested NRC's approval to implement amendments to its operating licenses DPR-71 and DPR-62 by incorporating changes to the BSEP 1 and 2
' Technical Specifications (TS).
The proposed TS modifications will eliminate response time testing (RTT) requirements for selected sensors and specified instrumentation loops for (1) the Reactor Protection System (RPS), (2) the Isolation System, and (3) the Emergency Core Cooling System (ECCS).
2.0 BACKGROUND
The Boiling Water Reactor Owner's Group (BWROG), with CP&L participation, performed an analysis to assess the impact of elimination of RTT for selected instrument loops. This analysis was documented as Licensing Topical Report (LTR) NED0-32291 " System Analyses for Elimination of Selected Response Time Testing Requirements," and was submitted for NRC approval in January 1994.
The NRC approved NED0-32291 in a generic Safety Evaluation Report (SER) dated December 28, 1994, and approved subsequent revisions to NED0-32291 in a supplemental SER dated May 31, 1995. The generic SER included Tables 1 and 2, which respectively list the make/model of instruments / devices, and systems which were evaluated in NEDO-32291 for RTT elimination.
The generic SER states, "The BWROG concluded that the RTT requirements for the devices identified in Table I can be removed from the TSs when the devices are used in systems listed in Table 2."
In addition to approving elimination of RTT for selected instrumentation, the generic SER stipulated certain conditicas that 9704240129 97041g DR ADOCK 05000324 PDR
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. I individual plant licensees must meet when implementing the NED0-32291 l
guidelines on a plant-specific basis.
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3.0 PROPOSED CHANGE
S AND EVALUATION As approved by the staff, NED0-32291 indicated that response time testing can be eliminated for the following based on other TS testing which is sufficient to detect instrumentation response degradation:
1.
All Emergency Core Cooling System instrument loops; l
2.
All Isolation System actuation instrument loops except for main steam line isolation valves (MSIVs);
3.
Sensors for selected RPS actuation; and 4.
Sensors for MSIV closure actuation.
l CP&L proposed elimination of the following selected RTT requirements from the BSEP Units 1 & 2 TS:
l 1.
ECCS Actuation instrumentation.
2.
Isolation System Actuation Instrumentation except for instrumentation associated with MSIVs; 3.
RPS instrumentation - Sensors for Reactor Vassel Low Water Level - Level 3 and Main Steam Line Flow - High; 4.
Isolation Actuation System instrumentation - Sensors for Reactor Vessel Water Level - Level 3 and Main Steam Line Flow.
The specific sections of the BSEP Unit I and 2 TS to be changed are as follows:
1 (a) BSEP Unit I and 2 Section 3/4.3.1 Reactor Protection System Instrumentation, page 3/4 3-la, Surveillance Requirement 4.3.1.3, Reactor Protection System Response Time.
l Proposed Chanoe: Modify the footnote. The footnote currently states
" Neutron detectors are exempt from response time testing." The modified footnota will state:
e l
Neutron detectors are exempt from response time testing. The sensor response time for,the following functions may be assumed to be the design sensor response time:
Item.3.
" Reactor Vessel Steam Dome Pressure - High"
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Item 4.
" Reactor Vessel Water Level - Low.
Level 1."
Evaluation: This footnote will allow BSEP Unit I to use manufacturer's response time data in the determination of system response time, and eliminate the requirement for a separate measurement of the sensor response time. The remainder of the channel will continue to be tested for response time. This change is consistent with the approved NED0-32291, with one exception. CP&L stated in their submittal "The BWR
[ Boiling Water Reactor) industry reference of Reactor Vessel Water Level Low, Level 1 is the same as the BSEP designation of Reactor Vessel Water Level - Low, Level 3.
The BWR industry reference of Reactor Vessel Water Level - Low, Level 2 is the same for BSEP. The BWR industry reference of Reactor V m el Water Level - Low, Level 3 is the same as the BSEP designation of Reactor Vessel Water Level - Low, Level 1.
Thus, the Reactor Vessel Water Level - Low, Level I reference provided in the notation above for Technical Specification 4.3.1.3 is equivalent to Reactor Vessel Wates Level - Low, Level 3 used in Table 2 of NED0-32291."
l The staff finds the above change and the difference noted acceptable since it is consistent with approved NEDO-32291.
(b) BSEP Unit I and 2 Section 3/4.4, Surveillance Requirements, page 3/4 3-11, Surveillance Requirement 4.3.2.3,-Isolation System Response Time.
Proposed Chanae: Modify the footnote. The footnote currently states:
Radiation monitors are exempt from response time testing The new footnote for BSEP Unit I will read:
Radiation monitors are exempt from r'esponse time ' testing. 'The sensor.rasponse times for the following functions may be assumed to be the design sensor response time:
Item 1.a.2, " Reactor Vessel Water Level - Low, Level 3" Item 1.c.3, " Main Steam Line Flow - High"
t
- l Response time testing is not required for the functions noted in Table 4.3.2-1.
s The new footnote for BSEP Unit 2 will read:
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Radiation monitors are exempt from response time testing. The sensor response times for the following functions may be assumed i
to be the design sensor response time:
i Item 1.a.2, " Reactor Vessel Water Level - Low, Level 3"..
Item 1.c.3, " Main Steam 1.ine Flow - High" Item 1.c.4, " Main Steam Line Flow - High" Response time testing is not required for the functions noted in Table 4.3.2-1.
In addition, for both BSEP Unit I and Unit 2, a new footnote (g) is being added to Technical Specification Table 4.3.2-1:
(g) Response time testing of the function is not required.
l This new footnote (g) is being added to the following instrument functions listed in Technical Specification Table 4.3.2-1:
Item 1.a.1, Reactor Vessel Water Level - Low, Level 1 Item 1.b, Drywell Pressure Item 1.c.2, Main Steam Line Pressure - Low Item 1.d,
. Main Steam Line Tunnel Temperature - High Item 1.e, Condenser Vacuum - Low Item 1.f, Turbine Building Area Temperature High Item 1.h, Reactor Building Exhaust Radiation - High Item 2.a, Reactor Building Exhaust Radiation - High Item 2.b, Drywell Pressure - High Item 2.c, Reactor Vessel Water level - Low, level 2 Item 3.a, M1ow - High
i Item 3.b, Area Temperature - High 4
i Item 3.c, Area Ventilation A Temperature - High Item 3.d, SLCS Initiation Item 3.e, Reactor Vessel Water Level - Low, Level 2 Item 3.f.
Flow - High - Time Delay Item 3.g, Piping Outside RWCU Rooms Area Temperature - High Item 4.a.1, HPCI Steam Line Flow - High 4
Item 4.a.2, HPCI Steam Line Flow - High Time Delay Relay Item 4.a.3, HPCI Steam Supply Pressure - Low Item 4.a.4, HPCI Steam Line Tunnel Temperature - High Item 4.a.5, Bus Power Honitor Item 4.a.6, HPCI Turbine Exhaust Diaphragm Pressure - High Item 4.a.7, i PCI Steam Line Ambient Temperature - High Item 4'.a.8, HPCI Steam,Line Area A Temperature - High l
Item 4.a.9, HPCI Equipment Area Temperature - High l
Item 4.a.10,Drywell Pressure - High l
Item 4.b.1, RCIC Steam Line Flow - High l
Item 4.b.2, RCIC Steam Line Flow - High Time Delay Relay Item 4.b.3, RCIC Steam Supply Pressure - Low f
Item 4.b.4, RCIC Steam Line Tunnel Temperature - High Item 4.b.5, Bus Power Honitor Item 4.b.6, RCIC Turbine Exhaust Diaphragm Pressure - High Item 4.b.7, RCIC Steam Line Ambient Temperature - High 5
Item 4.b.8, RCIC Steam Line Area A Temperature - High Item 4.b.9, RCIC Equipment' Room Ambient Temperature - High Item 4.b.10,RCIC Equipment Room A Temperature - High Item 4.b.11,RCIC Steam Line Tunnel Temperature - High Time Delay Relay
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Item 4.b.12,Drywell Pressure - High Item 5.a, Reactor Vessel Water Level - Low, level 1 Item 5.b, Reactor Steam Dome Pressure - High
. Evaluation:
The licensee stated: "The instrument functions listed in the footnote i
above for BSEP Units 1 and 2 differs from the instrument functions listed in Table 2, Item 4 of NEDO-32291. Specifically, the BSEP footnote omits the main steam line pressure - low function. The BSEP Final Safety Analysis Report (FSAR), Section 7.3.4.7 discusses the i
isolation functions and settings of the primary containment isolation
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and nuclear steam supply shutoff system listed in Table 7.3-2.
Item 5 discusses the low steam pressure at the turbine inlet function. This function is provided to handle a pressure regulator malfunction in which the turbine control valves or turbine bypass valves open fully. This FSAR section states that "although this isolation function is not required to satisfy any of the safety design bases for this system, this i
discussion is included here to make the listing of isolation functions complete." The same information can also be found in Section 7.3.1.1.6.5 of the Updated FSAR.
Because the main steam line pressure - low instrument function is not needed to satisfy any safety j
bases for the main steam supply system, CP&L has determined that this function does not need to be included in list of MSIV isolation actuation functions which will continue to require response time testing (excluding the sensor)." This difference is acceptable to the staff based on the above justification.
The new footnotes will allow BSEP Units 1 and 2 to use manufacturer's response time data in the determination of system response time, and eliminate the requirement for a separate measurement of the sensor response time.
The remainder of the channel will continue to be tested for response time. Since the BWR industry reference of Reactor Vessel Water Level - Low, Level 1 is the same as the BSEP designation of Reactor Vessel Water Level - Low, Level 3, this change is consistent with the approved NEDO 32291.
i CP&L stated in the March 27, 1997, submittal, that they had previously
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requested and received NRC approval to actuate MSIV closure using l
Reactor Vessel Water Level - Low, level 3 instead of Reactor Vessel Water Level - Low, Level 2.
This change was approved in Amendment 122 to the BSEP Unit 1 Facility Operating License and in Amendment No. 146 4
to the BSEP No. 2 Tacility Operating License.
Because the same J
instrument transmitters ara used for both Reactor Vessel Water Level i
- Low, level 2 and Reactor Vessel Water level - Low, Level 3, the conclusions of the evaluation regarding delay in trip functions documented in Appendix J of NE00-32291 remain applicable. This change is consistent with the approved NED0-32291.
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l The last sentence in the footnote, stating ' Response time testing is not required for the functions noted in Table 4.3.2-1" is used to note both those functions for which RTT has never been required because those l
functions are not credited in a design basis accident analysis, and those items where the entire isolation instrumentation function is l
exempted from RTT as a result of the approval of NEDO-32291. These l
functions listed in table 2 of the staff SER for NED0-32291 are:
(a)
RCIC System (b)
HPCI System (c)
HPCS System (d)
RWCU System (e)
Primary Contairc.ent (f)
RHR Shutdown Cooling / Head Spray For BSEP units 1 and 2, these instrument functions are as follows:
Item 1.a.1, Reactor Vessel Water Level - Low, Level 1 Item 1.b.
Drywell Pressure Item 1.d.
Main Steam Line Tunnel Temperature - High Item 1.e, Condenser Vacuum - Low Item 2.a, Reactor Building Exhaust Radiation - High Item 2.b,.
Drywell Pressure - High Item 2.c, Reactor Vessel Water level - Low, level 2 Item 3.e, Reactor Vessel Water Level - Low, Level 2 Item 4.a.1, HPCI Steam Line Flow - High Item 4.a.3, HPCI Steam Supply Pressure - Low Item 4.b.1, RCIC Steam Line Flow - High The licensee also stated that there are other isolation actuation instrument functions which, prior to the approval of NED0-32291, had no l
response time requirements identified (i.e., their function response I
times were listed as "NA") and, thus, do not require response time l
testing. These instrument functions include the following:
Item 1.f, Turbine Building Area Temperature - High
i
. Item 1.h, Reactor Building Exhaust Radiaticn - High Item 3.a, K low - High Item 3.b, Area Temperature - High Item 3.c, Area Ventilation A Temperature - High Item 3.d, SLCS Initiation Item 3.f.
Mlow - High - Time Delay 4
Item 3.g, Piping Outside RWCU Rooms Area Temperature - High l
Item 4.a.2, HPCI Steam Line Flow - High Time Delay Relay i
Item 4.a.4, HPCI Steam Line Tunnel Temperature - High l
Item 4.a.5, Bus Power Honitor Item 4.a.6, HPCI Turbine Exhaust Diaphragm Pressure - High Item 4.a.7, HPCI Steam Line Ambient Temperature - High Item 4.a.8, HPCI Steam Line Area A Temperature - High I
Item 4.a.9, HPCI Equipment Area Temperature - High l
Item 4.a.10 Drywell Pressure - High Item 4.b.2, RCIC Steam Line Flow - High Time Delay Relay I
1 Item 4.b.3, RCIC Steam Supply Pressure - Low Item 4.b.4, RCIC Steam Line Tunnel Temperature - High i
Item 4.b.5, Bus Power Monitor
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Item 4.b.6, RCIC Turbine Exhaust Diaphragm Pressure - High f-Item 4.b.7, RCIC Steam Line Ambient Temperature - High Item 4.b.8, RCIC Steam Line Area A Temperature - High l~
Item 4.b.9, RCIC Equipment Room Ambient Temperature - High Item 4.b.10,RCIC Equipment Room A Temperature - High i
Item 4.b.11,RCIC Steam Line Tunnel Temperature - High Time Delay Relay Item 4.b.12,Drywell Pressure - High Item 5.a.
Reactor Vessel Water Level - Low, Level 1 i
Item 5.b,.
Reactor Steam Dome Pressure - High i
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The new footnote (g) to Table 4.3.2-1 of the BSEP Units I and 2 TS combines those functions for which RTT is no longer required in accordance with the staff SER on NED0-32291 with those functions for 4
which RTT has never been required or those where the requirement for RTT has previously been climinated. Since this footnote does not add any i
i
. RTT elimination except those approved in the staff SER for NEDO-32291, this footnote is acceptable to the staff.
(c)
BSEP Units 1 and 2, Section 3/4.3.3, Emergency Core Cooling System Actuation Instrumentation, page 3/4 3-33, Surveillance Requirement 4.3.3.3, ECCS Response Time.
Propose) Chanae:
TS 4.3.3.3 currently states the following:
l The ECCS RESPONSE TIME of each ECCS function shall be demonstrated to be within the limit at least once per 18 months.
Each test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N
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times 18 months, where N is the total number of redundant channels in a specific ECCS function.
l CP&L has proposed ' deleting TS 4.3.3.3.
In its place, CP&L has proposed adding requirements for system RTT of those ECCSs which require such testing (High Pressure Coolant Injection System, Core Spray System, and the Low Pressure Coolant Injection System). These requirements will now be contained in the system-spicific 7.'S (e.g., TS 3/4.5.1 for the High Oressure Coolant Injection System, 15 3/4.5.3.1 for the Core Spray Systen, and TS 3/4.5.3.2 for the Low Pressure Coolant Injection System).
4 TS 3/4.5.1 (Hiah P m wy_q_(oolant Iniection System) i TS 4.5.1 states the following:
4.5.1 The HPCI shall be demonstrated OPERABLE:
c.
At least once per 18 months by:
1.
Performing a system function test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow
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path actuates to its correct position. Actual injection of coolant into the reactor vessel is excluded from this test.
1 2.
Verifying that the system develops a flow of at least 4250 gpm for a system head corresponding to a reactor pressure 2 165 psig when steam is i
being supplied to the turbine at 165, i 15, psig.
i 3.
Verifying that the suction for the HPCI system is automatically transferred from the condensate
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storage tank to the suppression pool on a condensate storage tank low water level signal l
or suppression pool' high water level signal.
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TS 4.5.1.c.4 is being added and will state:
4.
Verifying that the ECCS RESPONSE
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HPCIsystemiswithinitslimit.JIMEforthe 4
8 Instrumentation response time may be assumed to be the design instrumentation response time.
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l TS 3/4.5.3 (Low Pressure Coolina Systems)
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Core Sorav System
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i TS 3.5.3.1 and 4.5.3.1 provide Limiting conditions for Operation and Surveillance Requirements for the Core Spray System.
i TS 4.5.3.1 states the following:
4.5.3.1 Each CSS subsystem shall be demonstrated OPERABLE:
1 TS 4.5.3.1.e is being added and will state:
At least once per 18 months by verifying the ECCS* RESPONSE e.
TIME for each CSS subsystem is within its limit.
i
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. i 8 Instrumentation response time may be assumed to be the design instrumentation response time.
l l
. Low Pressure Coolant In.iection System TS 3.5.3.2 and 4.5.3.2 provide Limiting Conditions for Operation and Surveillance Requirements for the Low Pressure Coolant Injection System.
TS 4.5.3.2 states the following:
1 4.5.3.2 Each LPCI subsystem shall be demonstrated OPERABLE:
TS 4.5.3.2.d is being added and will sthte:
1 d.
At least once per 18 months by verifying the ECCS RESPONSE TIME for each LPCI subsystem.is within its limit.
' Instrumentation response time may be assumed to be the l
design instrumentation response time.
Evaluation:
This modification moves the RTT requirement from the instrumentation section of the TS to the system portion of the TS.
Since the instrumentation for these protective functions is no longer subject to RTT, the staff has determined that this change / move is appropriate.
The footnotes added to the testing requirements will allow BSEP Units 1 & 2 to use manufacturer's response time data'in the determination of system response time, and eliminate the requirement for a measurement of the instrument channel response time. This change is consistent with the approved NEDO-32291 and is, therefore, acceptable.
4.0 E.RIFICATION OF NEDO-52291 PLANT-SPECIFIC CONDITIONS The staff stipulated several conditions in the generic SER approving NED0-32291 which must be met by the individual licensee referencing NEDO-32291 i
.before its guidance could be implemented in plant-specific TS change proposals.
From the BSEP 1 and 2 licensee's submittals, the staff verified that the licensee has met the applicable conditions as follows:
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4.1 Condition
Confirm the applicability of the generic analyses to the l
plant.
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Licensee's Resnonse: CP&L reviewed this issue and determined that the j
NED0-32291 generic analysis is applicable to BSEP Unit I and 2. The equipment in question are sensors associated with the BSEP RPS, Isolation System, and ECCS actuation instrumentation. The staff concurs with this response.
4.2 Condition
The licensee's revision request shall be submitted as shown in Appendix I of the BWROG LTR.
Licensee's Response: The licensee stated that the March 27,.1997, submittal for proposed TS changes satisfies this condition. The staff concurs with this response.
4.3 Condition
The licensee shall state that they are following the recommendations from EPRI NP-7243 and, therefore, shall perform the following actions:
l (a)
Prior to installation of a new transmitter / switch or following refurbishment of a transmitter / switch (e.g., sensor cell or variable damping components), a hydraulic RTT shall be performed to deter:nine an initial sensor-specific response time value.
Licensee Response: The licensee stated that this recommendation is achieved by providing a step function or fast ramp in the process variable during calibration of a new transmitter / switch or following refurbishment of a transmitter / switch, and as part of each subsequent refueling surveillance. Applicable test procedures at BSEP were. revised to provide a fast ramp change of transmitter input while monitoring the transmitter output.
This test includes injecting a simulated hydraulic signal at the input of the transmitter and noting that an instantaneous output change is received. The staff concurs with this response.
l (b)
For transmitters and switches that use capillary tubes, capillary l
tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage the capillary tubes.
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Licensee Resoonse: The licensee stated BSEP does not have an application of sensors which use capillary tubes where response time testing was eliminated. The staff concurs that this
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recommendation is not applicable to BSEP.
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4.4 Condition
The Licensee must confirm the following:
I
-(a)
That calibration is being done with equipment designed to provide
.a step function or fast ramp in the process variable, J
Licensee Response: The licensee stated that calibration at BSEP is performed with equipment designed to provide a step function or fast ramp in the process variable. Applicable test procedures were revised to provide a fast ramp change of transmitter input while monitoring the transmitter output.
The staff concurs that this response meets the above condition.
i (b)
That provisions have been made to ensure that operators and l
technicians, through an appropriate training program, are aware of the consequences of instrument response time degradation, and that i
applicable >rocedures have been reviewed and revised as necessary j
to assure t1at technicians monitor for response time degradation during the performance of calibrations and functional tests, Licensee Response: The licensee stated that training has been provided to operations and maintenance personnel regarding instrument response time degradation. The staff concurs that this response meets the above condition.
(c)
That surveillance testing procedures.have been reviewed and revised if necessary to ensure calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of units under
- test, 1
I Licensee Resnonse: The licensee stated that applicable instrument calibration and surveillance procedures ensur~e calibrations and functional tests are performed in a manner that allows simultaneous monitoring of both the input and output of units j
under test. The staff concurs that this response meets the above condition.
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(d)
That for any request involving the elimination of RTT for l
Rosemount pressure transmitters, the licensee is in compliance with the guidelines of Supplement I to Bulletin 90-01, " Loss of
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F111-011 in Transmitters Manufactured by Rosemount,"
l Licerisee Resoonse: The licensee stated BSEP is in full compliance 1
with Supplement I to NRC Bulletin 90-01. The staff concurs that this response meets the above conditions.
i (e)
That for those instruments where the manufacturer recomends l
periodic RTT as well as calibration to ensure correct functioning, i
the licensee has ensured that elimination of RTT is neverthele.ss acceptable for the particular application involved.
Licensee Resoonse: CP&L has reviewed vendor documentation for the affected transmitters and has determined that there are no i
specific manufacturer recomendations to perform periodic response time testing. The staff concurs that this response meets the j
above condition.
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5.0 RESULTS 0F REVIEW l
Based upon the above review, the staff concludes.that the licensee has satisfactorily implemented the guidelines for RTT elimination in accordance i
with NED0-32291 and the conditions of the staff generic SER approving NED0-32291. Therefore, the staff concludes that the proposed BSEP Units 1 and 2 TS modifications for selected instrument RTT elimination are acceptable.
6.0 EXIGENT CIRCUMSTANCES
The Comission's regulations,10 CFR 50.91, contain provisions for issuance of amendments where the Commission finds that exigent circumstances exist, in that a licensee and the Comission must act quickly and that time does not permit the Comission to publish a federal Register notice allowing 30 days for prior. public coment. The exigency exists in this case in that the proposed amendments are needed to avoid an unnecessary shutdown of the BSEP, Units 1 and 2, and time does not permit the Comission to publish a notice allowing 30 days for prior public comment. The licensee was unable to make a more timely application because the licensee was not formally notified by the NRC of a possible TS non-compliance issue and need for TS amendment with regard to response time testing until March 21, 1997. The staff has determined that the licensee usea its best efforts to make a timely application.
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Accordingly, the Commission has determined that exigent circumstances exist j
pursuant to 10 CFR 50.91(a)(6) and could not have been avoided, the submittal of information was timely, and that the licensee did not create the exigency.
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7.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
S DETERMINATION l
i The Commission's regulations in 10 CFR 50.92(c) state that the Commission may i
make a final determination that a license amendment-involves no significant i
hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the i
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) result in a significant reduction in the margin
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of safety. The NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by th* criteria contcined in 10 CFR 50.91. The NRC staff's final determination is presented below.
l.
The proposed license amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.
BWR Owners' Group Licensing Topical Report NED0-32291-A demonstrates that quantitative response time testing is redundant to other TS requirements. Qualitative tests are sufficient to identify failure modes or degradation in instrument response time and ensure operation of the associated systems within acceptance limits. There are no known failure modes that can be detected by response time testing that cannot also be detected by other TS required tests.
System response times will continue to be determined using a methodology l
that has been reviewed and approved by the NRC. Therefore, the proposed license amendt ents do not involve a significant increase in the ~
probability or consequences 'of an accident previously evaluated.
2.
The proposed license amendments would not create the possibility of a new or different kind of accident from any accident previously-evaluated.
The proposed license amendments do not affect the capability of the associated systems to perform their intended function within the I
acceptance limits assumed in the plant safety analyses and required for successful mitigation of an initiating event. The proposed amendments do not change the way in which any plant systems are operated.
- ECCS,
i m,
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RPS, and Isolation System response times will continue to be determined using a methodology that has been reviewed and approved by the NRC.
Therefore, the proposed amendments do not create the possibility of a
..new or different kind of accident.
3.
The proposed licer.se amendments do not involve a significant reduction j
in a margin of safety, i
i The current TS response times are based on the maximum allowable values assumed in the plant safety analyses. These analyses conservatively establish the margin of safety. As described above, determination of i
response times-based on an alternate NRC-approved methodology (i.e.,
provided in the NED0-32291-A. report) will not affect the capability of l
the associated systems to perform their intended function within the i
allowed response time used as the bases for the plant safety analyses.
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Plant and system response to an initiating event will remain in i
compliance with the assumptions of the safety analyses; therefore, the margin of safety is not affected.
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8.0 STATE CONSULTATION
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l In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments. The State 3
official had no comments.
9.0 ENVIRONMENTAL CONSIDERATION
l The amendments chsnge a surveillance requirement.
The NRC staff has j
determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released
[
offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (62 FR i
15542). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR SI.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be i
prepared in connection with the issuance of the amendments.
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10.0 CONCLUSION
i The Commission has concluded, based on the considerations discussed above, i
that'(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed m.anner, (2) such i
activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common J
defense and security or to the health and safety of the public, i
l Principal Contributor:
P. Loeser i
Date:
April 18,1997 1
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