BECO-85-146, Application for Amend to License DPR-35,consisting of Proposed Change 85-09,revising Tech Specs Re Standby Gas Treatment Sys & Control Room High Efficiency Air Filtration Sys.Changes Modify 840809 Submittal

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Application for Amend to License DPR-35,consisting of Proposed Change 85-09,revising Tech Specs Re Standby Gas Treatment Sys & Control Room High Efficiency Air Filtration Sys.Changes Modify 840809 Submittal
ML20134C577
Person / Time
Site: Pilgrim
Issue date: 08/09/1985
From: Oxsen A
BOSTON EDISON CO.
To: Vassallo D
Office of Nuclear Reactor Regulation
Shared Package
ML20134C580 List:
References
BECO-85-146, NUDOCS 8508160360
Download: ML20134C577 (6)
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BOSTON EolSON COMPANY B00 SOYLETON STREET SOSTON, MASSACHUSETTS 02199 August 9, 1985 4.u.Ox.Eu o veCS PASSsOSNT '

NUCLE AR OPERATIONS -

BECo 85-146 Proposed Change 85-09 Mr.~ Domenic 8. Vassallo, Chief Operating Reactors Branch #2-Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ,

Washington, D. C. 20555 License DPR-35 Docket 50-293 ,

Proposed Technical Specification Change on SBGTS and CRHEAF

Dear Sir:

Pursuant to 10CFR50.90, Boston Edison Company hereby proposes the attached modification to Appendix A of Operating License No. OPR-35. This modification revises sections concerning the Standby Gas Treatment System and the Control Room High Efficiency Air Filtration System. These changes modify our submittal of August 9, 1984, and are proposed to reflect a design change to the system and add clarity to the existing Technical Specifications.

Should you require further information on this submittal, please contact us.

Very truly yours, PMK/kmc

- Attachment One original and 39 copies Commonwealth of Massachusetts)

County of Suffolk )

Then personally appeared before me A. L. Oxsen, who, being duly sworn, did state that he is Vice President - Nuclear Operations of the Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of the Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My Commission expires: OMe2'l dg8 M[Not ry Publicb 1

cc: See next page 40l h 85000 t

PDR 'l

. . 7 BOSTON EDISON COMPANY

'Mr..Domenic B.'Vassallo, Chief August 9, 1985 Page 2 cc: Mr. Robert M. Hallisey, Director Radiation Control Program-Massachusetts Dept. of Public Health 600 Washington Street, Room 770

' Boston, MA 02111 u- .m

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Proposed Change Reference is made to Pilgrim Station Operating License No. DPR-35, pages 158, 158A and 158C. By letter of August 9, 1984, Boston Edison (BECo) submitted proposed changes to these-pages, as well as to other pages associated with the Standby Gas Treatment System (SBGTS) and the Control Room High Efficiency Air Filtration System (CRHEAF).

Plant Design Change (PDC) 84-20 subsequently modified the SBGTS, which made necessary a change to technical specification 4.7.B.I.a.(2.). In addition, a recommendation was made that technical specification 3.7.B.I.c and 3.7.B.2.c be. changed to make their wording consistent.

This proposed change addresses both issues, and is submitted as an emendation of our August 9, 1984 submittal. As such, please substitute the attached Pages 158, 158A and 158C for those in our previous submittal.

Currently, Technical Specification (TS) 4.7.B.l.a.(2.) states, in part:

Perform an instrument function test on the humidistats controlling the

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heaters.

The proposed change deletes this requirement because the humidistats have been permanently bypassed.

Our August 9,'1984 proposed Technical Spec!fication (TS) 3.7.B.l.c states:

From and after the date that one train of the Standby Gas Treatment System is found to be Inoperable for any reason, continued reactor operation, irradiated fuel handling or new fuel handling over the spent fuel pool or core is permissible during the succeeding seven days providing that within two hours, and daily thereafter, all active components of the other Standby Gas Treatment train shall be demonstrated to be operable.

He are emending this change to 3.7.B.l.c by deleting "..., and daily thereafter, ..."

The third proposed change concerns TS 3.7.B.2.c, which currently states, in ,

part:

From and after the date that one train of the Control Room High Efficiency Filtration System is made or found incapable of supplying filtered air to the control room for any reason, reactor operation or refueling operations are permissible only during the succeeding 7 days.

The proposed amendment would provide an additional requirement to the above, consistent with the proposed 3.7.B.I.c, which would state:

...providing that within two hours all active components of the other CRHEAF train shall be demonstrated operable.

l A fourth change concerns 4.7.B.2.c, which currently states:

At least once every 18 months demonstrate the operability of the heaters L

at rated power.

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The proposed change shall. state:

At least once every 18 months demonstrate the ability of the heaters to perform their design function.

Reason for Change The humidistats associated with the SBGTS heaters were determined to be not qualified, in accordance with IE Bulletin 79-018, for the environment in which ,

they would exist during certain postulated events. Quallfled replacements are not available, and it was determined that humidistats are not essential to the proper operation,of the system.

.The wording being added to 3.7.8.2.c is proposed at the suggestion of NRC. It makes 3.7.8.2.c consistent with 3.7.8.1.c, which is associated with a similar system, and provides a clear description of the appropriate actions to be taken when one train of CRHEAF is incapable of performing its designed function.

Safety Considerations

~ The proposed change to 4.7.B.I.a does not compromise safety because the purpose of the humidistats, which are relative humidity sensors intended to control the relative humidity (RH) of the incoming gas stream by energizing the SBGTS heaters, is not essential. The humidity will continue to be adequately controlled by the SBGTS heaters, which will now be energized when the exhaust fans are energized. The heaters are protected from overheating by high temperature sensors, which deenergize the heaters prior to temperatures which could imperti the charcoal beds. Therefore, the system is capable of performing its designed function without the humidistats, and because of the unavailability of qua11 fled humidistats, bypassing them enhances assurance of proper heater operation. This bypassing, of course, removes the need to test the humidistats, and the need to have such a surveillance test in 4.7.B.1.a. .

The removal of this test is not a safety concern.

The change to 3.7.B.1.c does not compromise safety because once the redundant train has been demonstrated operable there is reasonable assurance it will perform its designed function while the inoperable train is being repaired.

Daily testing does not necessarily add to that assurance because excessive testing may degrade the equipment.

The change to 3.7.B.2.c enhances safety in that it requires further testing of the operable train of CRHEAF when one train is inoperable, which provides additional assurance that that train will be available if called upon.

The change to 4.7.B.2.c is made to remove ambiguity. " Rated power" could be ,

misinterpreted to mean rated reactor power. This, of course, is not meant.

It is intended that the heaters be tested at a predetermined value such that they will control humidity to protect the charcoal beds from degradation.

This proposed change has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

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Significant Hazards Consideration The Commission has provided guidance for the application of the standards for determining whether a significant hazards consideration exists by providing examples of amendments not likely to involve significant hazards considerations (48FR14870). One such amendment involves a change that

. corresponds to section (vi) of 48FR14870 in that the change may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but the results of the change are clearly within all acceptable criteria.

Excessive humidity in the SBGTS could reduce the effectiveness of the charcoal beds in filtering out radiolodines from gaseous effluents during an accident.

In the past, humidity was measured by the humidistats, which activated heaters at the appropriate setpoint to remove humidity and thereby preclude degradation of the beds. The bypassing of the humidistats does not constitute a significant hazard because the ability to remove humidity is ensured by the heaters, which are now made operational whenever the SBGTS fans are turned on. Heater-dependability and life are maintained by overtemperature switches, which protect the heaters and the charcoal beds from degradation caused by excessive heat. Since the objective of SBGTS humidity control can be achieved without the humidistats, and since the humidistats cannot be qualified, their being bypassed does not degrade, but enhances the assurance that the SBGTS will perform its designed function.

Section (vi) is also applicable to removing the daily survelliance of the redundant SBGTS train when a train is found or made inoperable. While at first this may seem to slightly reduce confidence in SBGTS availability, such a reduction is countervalled by the lessening of surveillance induced degradation of system components.

In the case of adding a further restriction to 3.7.B.2.c, no significant hazards consideration exists because adding initial testing of active components of the operable train of the CRHEAF provides greater assurance that that train will perforTi its designed function if required to when the redundant train is made or found inoperable. This corresponds to example (11) of 48FR14879 in that it constitutes an additional limitation, restriction, or control not presently included in the subject technical specification.

Specifically, it is a more stringent surveillance requirement.

The rewording of 4.7.8.2.c is similar to section (1) of 48FR14870 in that it

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represents a change in nomenclature, and is therefore an administrative change. Existing CRHEAF heater testing frequency and methodology will not be changed. This change is proposed to avoid potential misinterpretation caused by the connotation of " rated power" in nuclear parlance.

For the reasons discussed above, the changes proposed herein do not require the application of a significant hazards consideration because the operation of Pilgrim Nuclear Pow r Station in accordance with these proposed changes would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the 4

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.

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-Schedule ~of Change.

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This~ change wil1.become effective 30 days following BECo's receipt of_ approval bytthe Commission.

- Fee Determination-

. Pursuant to.10 CFR 170.12(c), an application fee of $150.00 was provided'with our August 9, 1984_ submittal. Since this submittal is an emendation of that submittal, and since review of the August 9. 1984 submittal has.not commenced.,

we believe no additional application fee is.necessary.

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