BECO-87-092, Application for Amend to License DPR-35,consisting of Proposed Change 87-10,revising Operability Requirements of Control Rod Block Actuation Instrumentation to More Closely Correspond to Logic Design

Application for Amend to License DPR-35,consisting of Proposed Change 87-10,revising Operability Requirements of Control Rod Block Actuation Instrumentation to More Closely Correspond to Logic Design

ML20214U654
Person / Time
Site:	Pilgrim
Issue date:	06/02/1987
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20214U656	List: BECO-87-092, Application for Amend to License DPR-35,consisting of Proposed Change 87-10,revising Operability Requirements of Control Rod Block Actuation Instrumentation to More Closely Correspond to Logic Design ML20214U696
References
BECO-87-092, BECO-87-92, NUDOCS 8706110288
Download: ML20214U654 (5)

Text

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sositwEDiSON Executive Ofhces 800 Boyiston street Boston, Massachusetts 02199 Ralph G. Bird June 2, 1987 Senior Vice President - Nuclear BECo 87-092 Proposed Change 87-10 U. S. Nuclear Regulatory Commission Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 Proposed Technical Specification Change Concernino Control Rod Block Actuation

Dear Sir:

Pursuant to 10CFR50.90, the Boston Edison Company (BECo) hereby proposes the attached modification to Appendix A of Operating License DPR-35. The proposed modification revises the operability requirements of control rod block actuation instrumentation to more closely correspond to the logic design.

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

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' BOSTON EDISON COMPANY June 2, 1987 U.S. Nuclear Regulatory Commission Page Two cc: U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Mr. R. H. Hessman, Project Manager Division of Reactor Projects I/II Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814 Senior NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Robert M. Hallisey, Director Radiation Control Program Mass. Dept. of Public Health 150 Tremont Street F-7 Boston, MA 02111

Attachment Proposed Technical Soecification Chance Descriotion Prooosed Changes It is proposed that the Pilgrim Nuclear Power Station (PNPS) Technical Specifications be changed as indicated on the attached pages and described below:

1. The information on Technical Specification Table 3.2.C, including the associated notes on Page 55, is revised and reformatted into two new Tables 3.2.C-1 and 3.2.C-2, with associated notes, to accomplish the following:

a. As revised, the operability requirements for control rod block actuation instrumentation are stated in terms of the " minimum operable channels per trip function." The old table was misleading because it described operability in terms of two separate trip systems per trip function.

b. The operability requirements and associated action statements are placed on new Technical Specification Table 3.2.C-1. The associated trip setpoints are moved to new Technical Specification Table 3.2.C-2, to improve clarity.

c. The operability requirements for control rod block actuation instrumentation not previously included in Technical Specifications are added to be consistent with the instrumentation described in the Final Safety Analysis Report (FSAR).

d. The operability requirements for APRM Upscale and Inoperative trip functions are revised from Run mode only to Run/Startup/ Refuel to be

, consistent with the FSAR.

2. Technical Specification 3.2.C.1 is revised to include references to new Technical Specification Tables 3.2.C-1 and 3.2.C-2.

.3.

The specification which permits the minimum operable channels for the rod block monitor trip function to be reduced by one for maintenance and/or testing is moved from Technical Specification 3.2.C.2 to new Table 3.2.C-1 (see Footnote 2 on revised Page 55.)

4. New Footnote 4 is added to Table 3.2.C-1 to ensure that the special SRM operability requirements during core alterations contained in Technical Specification 3.10 are referenced.

5. Technical Specification Table 4.2.C is revised to include the instrument test and calibration requirements for the additional trip functions added to Tables 3.2.C-1 and 3.2.C-2.

6. The notes for Tables 4.2.A through 4.2.G on Technical Specification Page 67 are revised to remove a statement from Note 3 that inadvertently conflicted with the calibration frequencies specified on Table 4.2.C.

7. Technical Specification Bases 3.2 are revised to correct the Technical Specification reference for the APRM and IRH downscale trip setpoints.

. Ritason for Changes The proposed Technical Specification changes clarify the operability requirements for control rod block actuation instrumentation by describing operability in terms of the " minimum operable channels per trip function" instead of in terms of two separate trip systems per trip function. This more closely corresponds to control rod block system design because all control rod block functions operate on a one-out-of-n logic. The proposed changes also reformat Technical Specification Table 3.2.C for clarity. To make the Technical Specifications consistent with the FSAR, operability requirements for APRM Upscale and Inoperative trip functions are revised and specifications for control rod block functions not previously listed in Technical

, Specifications are added.

PNPS Licensee Event Report 81-060, dated November 19, 1981, identified the potential for an operator to inadvertently reduce the number of operable APRM and IRM instrument channels in the rod block system to below the minimum required by Technical Specifications. The joystick bypass capabilities of the APRMs and IRMs create this potential Technical Specification violation. This proposed Technical Specification resolves this problem by allowing the operator to bypass any combination of APRM or IRM channels without compromising Technical Specification operability requirements. Additional discussion of this potential problem is found in the NRC memorandum from Mr.

Thomas M. Novak, Assistant Director of the Division of Licensing, to the project managers of operating GE BHRs, dated December 29, 1981,

" Misinterpretation of Number of Operable Instrument Channels for APRM Control Rod Block Hithdrawal Block."

Footnote 3 on Technical Specification Page 67 is revised to remove an inadvertent conflict with the calibration frequencies specified on Table 4.2.C.

The new footnote concerning SRM operability during core alterations in Table 3.2.C-1 is added in response to concerns expressed by the NRC resident inspector at PNPS in NRC Inspection Report 50-293/84-36, dated December 10, 1984.

Safety Evaluation and Determination of No Sionificant Hazards Considerations l

In accordance with 10CFR50.91, the following analysis has been performed using the standards in 10CFR50.92, concerning the issue of significant hazards considerations.

1. Operation of PNPS in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The revised technical specification continues to require the same number of operable channels per control rod block trip function, but removes the misleading description of operability in terms of two separate trip systems per trip function. This change has no impact on the design or operation of the control rod block system because the system trip logic remains a one-out-of-n logic. The trip of any one channel will continue to provide a control rod block and the total number of channels required to be operable for each function is unchanged. Thus, the proposed revision does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Operation of PNPS in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The prcposed revision to technical specifications allows greater operational flexibility without affecting the design and operation of the control rod block system. In addition, the proposed revision requires no plant design modification and does not impact the operation of any other plant system. For these reasons, it is concluded that the proposed revision will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Operation of PNPS in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

As discussed above, the total number of channels required to be operable for each control rod block function remains unchanged. By removing the misleading description of operability in terms of two separate trip systems per trip function, the operator is permitted greater freedom in choosing which channels may be bypassed. Because any channel of a particular trip function can give a control rod block trip (i.e.,

one-out-of-n trip logic), there is no reduction in a margin o'f safety.

Additional assurance that the control rod block function will operate as designed and described in the FSAR is provided by changes to make the Technical Specifications consistent with the FSAR, including the addition of new operational and surveillance requirements for control rod block actuation instrumentation not previously included in Technical Specifications.

This modification to PNPS Technical Specifications does not present an unreviewed safety question as defined in 10CFR50.59. It has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Schedule of Chance It is requested that the proposed amendment become effective immediately upon receipt of approval by the Commission.

Fee Determination Pursuant to 10CFR170.12(c), a check for $150.00 will be electronically mailed to your offices.