BECO-87-095, Revised Application for Amend to License DPR-35,changing Tech Specs Re Primary Containment & Primary Containment Testing.Original Application Submitted on 870621

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Revised Application for Amend to License DPR-35,changing Tech Specs Re Primary Containment & Primary Containment Testing.Original Application Submitted on 870621
ML20215A802
Person / Time
Site: Pilgrim
Issue date: 06/04/1987
From: Bird R
BOSTON EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20215A805 List:
References
BECO-87-095, BECO-87-95, NUDOCS 8706170090
Download: ML20215A802 (9)
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{{#Wiki_filter:- -- _ _ _ l 10CFR50.90 l' BOS10NE!DISON Executive Offices 1 800 Boylston Street . Boston, Masscchusetts c2199 June 4, 1987-Ralph G. Wrd BEco 87-095~ .. senior %s President - Nuclear Proposed Change 87-11 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License-DPR-35 Docket 50-293 Proposed Primary Containment Technical Specification Change

Dear Sir:

Pursuant to 10CFR50.90, Boston Edison Company proposes.the attachid modification to Appendix A of Operating License No. DPR-35. This modificatiot revises sections concerning primary containment'and primary containment testing. Please review this as a revision of our June 21,1985 :.tmittal for which the application fee has been paid. MTL/jcp Attachments One original and 39 copies cc: See next page gook g 6 Commonwealth of Massachusetts) County of Suffolk ) 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. My commission expires: kn / 5, /792 ' 

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l BOSTON EDISON COMPANY June 4, 1987 Page Two 1 cc- U.S. Nuclecr Regulatory Commission i Region I l 631 Park Avenue  ! King of Prussia, PA 19406 Senior NRC Resident Inspector -{ Pilgrim Nuclear Power Station Robert M. Hallisey, Director Radiation Control Program Mass. Dept. of Public Health 150 Tremont Street F-7 Boston, MA 02111 1 l i 1 1 l j

7 AttLchment A PROPOSED CHANGE The NRC letter of 7/2/84 requested BECo to update Technical Specifications for 

   . Primary Containment Testing in accordance with 10CFR50, Appendix J (with appropriate exemptions). This request was completed via BECo Proposed Technical Specification 85-08, dated 6/21/85.

This proposal supplements our previous submittal'by providing an updated Table of Primary Containment Isolation Valves which Receive an Automatic Isolation-Signal, and modifies pages affected by amendments and plant changes that have occurred since June 1985. Plant changes being implemented in RF0 #7 are also included. For your convenience, we are providing a complete set of Technical i Specification pages. The following list identifies changes which are being made in this submittal: Definition M - This was revised to include an additional condition for check i valves. I I Definition EE - This was previously submitted as Definition Y, however, due to Amendment 89 the number must change to EE. Table 3.2.B - Two new HPCI vacuum breakers are being added (further described under Table 3.7-1). The appropriate isolatior signals are described. 3.7.A.2.A.5 - An additional condition for check valves is added.- 3.7.A.2.b - Added Reference to Table 3.7-1 (note: This wording is nos similar to present Technical Specifications. This was changed in proposed  ; Technical Specification 85-08) ) 4.7 A.2.b.2 - Added Reference to. Table 3.7-1 (note: This wording is nce , similar to present . Technical Specifications. This was changed i in proposed i Technical Specification 85-08) Table 3.7-1 - Changed title for clarity. 

                   - Added valve and penetration numbers for ease of identification.
                   - Reactor water sample valves H0-220-44/45 position changed to normally open for crack arrest verification modifications.
                   - A0-5035A/B, A0-5036A/B, A0-5042A/B, A0-5044A/B - Changed operating time from 15 set to 5 sec due to modification (valves changed from 20" to 8").
                   - A0-50338, A0-50358, A0-5036A/B - Position changed from normally closed in accordance with valve line-ups.
                   - Feedwater and standby liquid control check valves were deleted because they do not receive primary containment isolation signals..

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                    - RHR dD. charge to radwaste valves were deleted because they are not primary containment isolation valves.
                    - H2/0 2, PASS and leak detection valves are all being added     '

due to plant modifications made during RFC 56. 

                    - TIP ball valves are being added.
                    - HPCI Torus Suction Isolation valves were deleted because these valves are not relied upon to perform a containment isolation function
                    - M0-2301-33,34 HPCI vacuum .,reaker valves are added aue to a plant modification.
                    - Group I Isolation, Condition 5 has been modified to conditions '

5 and 6 for clarity. 

                    - Group 7 Isolation has been added due to HPCI vacuum breaker modification.
                    - Revised Footnotes 1 and 2 for clarity.
                    - Added Footnotes 3, 5, and 6 for clarity.
                    - Added Footnote 4 for TIP ball valves.

flases 3/4.7.A - (Page 169 of present submittal) Added Group 7 definition due to HPCI vacuum breaker modification. REASON FOR CHANGE The proposed Technical Specification is being submitted to update the Table of l Primary Containment Isolation Valves (Technical Specification Table 3.7-1). 2 The changes that are proposed: (a) reflect past design changes. I 

       -(b)- are design changes-proposed-to.be-made during the present refueling-    {

outage, 1 (c) correct previous errors, (d) are editorial to pro.'ide clarity and consistency, (e) remove check valves . rom Table 3.7-1, and (f) remove valves that are not relied upon to perform a certain isolation i function. East and Prooosed Desian Chanaes HPCI Vacuum Breakers - Vacuum breakers are bcing added to the HPCI system to prevent water hammers. This modification will improve system reliability. , Reactor Water Sample - These lines will be used for continuous sampling for crack arrest verification (IGECC). The normal valve position has been changed from closed to open. All isolation signals, in the event of an accident, remain the same. 

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1 Purge Valves - The' original 20" valves have' been replaced with '8" valves for  ; better operability. The closing times have been reduced to' prevent f over-pressurization of the ductwork outside of primary containment following a_ i design basis LOCA. . H,0,, PASS, an'd Leak' Detection Valves - The original = hydrogen and oxygen I sample systems have been modified in accordance.with NUREG 0737. These are j post-accident systems. Correct Previous Errors Valve Line-ups - Valves A0-5033B, A0-50358 and A0-5036 A/B are maintained in a  ! normally closed position. RHR Discharge to Radwaste - These valves were removed from the table because-they are not primary containment isolation valves. TIP Ball valves are being added. Editorial Changes Definition EE - This definition was numbered "Y" in Proposed Technical Specification 85-08. Becau;e of recent Technical Specification amendments, this definition is renumbered to "EE." . 3.7.A.2.b and 4.7.A.2.b.2 - References to Table 3.7-1 have been added to this  ! LC0 and surveillance to incorporate the table;into Proposed Technical ) Specification 85-08. Valve and Penetration Numbers These have been added to the table to assure correct identification of the valves. Group I Isolation, Condition 5 - The original wording of-this condition has caused confusion. The proposed rewording (into Conditions 5 and 6) will avoid 

  -misinterpretation.
  ' Footnotes - The' footnotes ~have been reworded and four footnotes have been-added to provide clarity for the plant operators.                                   ]

Removal of Check Valves Check Valves .- The feedwater and standby liquid control check valves have been i removed from the table. Surveillances associated with Table 3.7-1 do not apply to check valves. The' definition of primary confainment integrity (Def. M) and LC0 3.7.A.2.a.5 have been modified to assure '. neck valve operability. The title of the table has been reworded to exclude check valves. HPCI Suction Valve ' The HPCI torus suction isolation valves (M02301-35 and 36) are removed from-Table 3.7.1'because the line which they isolate terminates below the free water surface of the 3uppression pool and will' remain so throughout-the-duration of any ace'. dent. Consequently, these valves are not relied upon to prevent the escape <4 containment atmosphere to the. environs and, therefore, do not perform a c W oinment isolation function. J

r - SAFETY' EVALUATION AND DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATI0M The Code of Federal Regulations,10CFR50.91, requires that at the time a , licensee requests an amendment, it must provide to the Commission its ' analysis, using the standards in 10CFR50.92, about the issue of no significant hazards consideration. Therefore, in accordance with 10CFR50.91 and 10CFR50.92, the following analysis has been performed.

1. Operating Pilgrim Station in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

HPCI Vacuum Breakers - The HPCI vacubm breaker modification requires a new penetration in primary containment. Two valves are provided to ensure completion of the safety acticn (primary containment isolation) prior to uncovering the fuel in the event of a design basis accident (DBA). This modification enhances the performance of +he HPCI system, > and other accident mitigating systems which utilize the torus, by reducing the possibility of failure due to hydrodynamic transients. 1 l The function of relieving vacuum in the HPCI turbine exhaust line is f better performed by the added vacuum breaker. All equipment installed i will have qualifications per IEEE-323 and IEEE-344 and will be of a  ! quality consistent with its Class IE function. Addition of this vacuum j breaker, which will improve the HPCI system performance, does not j increase the probability or consequences of an accident previously ' evaluated. Reactor Water Sample - Changing the normal position of the Deactor Water Sample valves, from closed to open, does not affect the . J function of the valves or any other system. The safety function of the valves is to isolate the line upon receipt of an appropriate signal. The isolation signals remain unchanged. Therefore, this change does not create a significant increase in the probability or consequences of an accident previously evaluated. Purge and Vent-Valves- Reduction of. the. maximum. closing times for the 

        . Purge- and Vent -valves will have .no.-adverse effects on- pr.imary. containment -

integrity. The original 20" valves have been replaced with more reliable 8" valves. Reduction of the maximum closing times prevents over-pressurizing the ductwork located outside containment following a , design basis LOCA. The reduction of containment isolation valve closing  ! times improves the assurance of achieving containment isolation, thus the ] change does not involve a significant increase in the probabliity or j consequences of an accident previously evaluated. l H220 , PASS and Leak Detection Valves - The original Hydrogen and Oxygen Analyzer systems were modified for the H 22 0 , PASS and Leak Detection ) Systems. The modifications included a reduction in the total number of i primary containment isolation valves (several penetrations were cut and i capped) and upgrading the system with faster closing solenoid valves. l These valves ensure completion of the safety function (primary ) containment isolation) prior to uncovering fuel in the event of an 1 accident, thus the changes do not involve a significant increase in the l probability or consequences of an accident previously evaluated. l E__ )

l Removal of Check Valves - Removal of check valves, which receive no isolation- signal, from Technical Specification -Table 3.7-1. is an administrative change. The check valve's contribution to containment integrity remains assured by Technical Specification 3.7.A.2.a. which i requires containment integrity when the reactor is critical or when reactor water temperature is above 212*F. Technical Specification 3.7.A.2.a(5) gives further assurance by requiring that all containment isolation check valves be operable, or that the appropriate line be secured in the isolated position. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated because through other sections of Technical Specification, reliability of the check valves will be maintained. HPCI Suction Valves - The HPCI torus suction isolation valves.(M02301-35 and 36) are removed from Table 3.7.1 because the line which they isolate terminates below the free water surface of the~ suppression pool and will remain so throughout the duration of any accident. Consequently, these valves are not relied upon to prevent the escape of containment atmosphere to the environs and, therefore, do not perform a containment isolation function. The containment isolation function of these valves was reviewed previously by the NRC, and their concurrence with the above evaluation is documented in NRC letter to BECo, dated 4/28/81. l t Although M02301-35 and 36 meet the generic definition of containment ' isolation valves that appears in PNPS-FSAR Section 5.2, the primary safety objective of the primary containment system is to limit the release of fission products in the event of a postulated DBA so that offsite dose would not exceed values -set forth in 10CFR100. Because M02301-35 and 36 do not contribute to the plant capability in this regard, removing these valves from Table 3.7-1 will not increase the probability or consequences of an accident. i 

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Corrections of Previous Errors - During our review of Table 3.7-1, j several errors were identified and have been corrected: 4 valves were  ! shown open and are normally closed; 2 valves have been removed because 

          -they are-not -primary <ontainment isolation valves.;..and, the TIP. Ball            l
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valves.have been added.. ~ Corrections of. errors is an administrative  : 

        --change-and does-not involve an increase in.the..probabi11ty.or                       I consequences of an accident previously analyzed.

Editorial Changes - This proposed amendment consists, in part, of minor editorial changes to provide clarity. These changes are administrative in nature and do not increase the probability a consequences of an accident previously evaluated.

2. Operating Pilgrim Station in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously analyzed.

The new vacuum breaker line for the HPCI system has been designed to equal cr Jiore stringent requirements than the original requirements' for the HPCI system. The new primary containment penetration has been , provided with automatic isolation valves with. closing times in accordance with the Pilgrim FSAR. Because the original design requirements for the HPCI system are met or exceeded, no new or different types of accidents are postulated. i

n Changing the normal position of the Reactor Water Sample valves from open l to closed does not impact their safety operation. The isolation signals remain unchanged, and function to isolate on all Group 1 and 2-signals. j Therefore, this. change'does not create a new or different kind of. accident. j 1 The modification to the Purge and Vent lines replaces the 20" valves with_  ! more reliable 8" valves. This change does not create.a new or different type of accident. The post accident sampling modifications, made in accordance with NUREG < ' 0737, utilized existing sampling system primary containment penetrations. The original valves were replaced with more reliable solenoid valves. No new or different type of accident from those previously analyzed are postulated. j Removal of the HPCI suction valves from Table 3.7-1 does not represent a j plant design change. These valves are not relied upon.to perform a 1 containment isolation' function and therefore, no new or different types of accidents are postulated. The correction of errors and editorial changes are performed and administrative and thus do not create the possibility of a new or different type of accident. Check valves are removed from the Technical Specification because they are not within the scope of the table (valves which received an automatic  ; isolation signal). Their contribution to containment integrity is maintained by Technical Specifications 3.7.A.2.a and 3.7.A.2.a(5). Because there is'no change to the' design of Pilgrim Station, this change does not create the possibility of a new or different type of accident from those previously analyzed. '

3. Operating Pilgrim Station in accordance with the proposed amendment will  !

not involve a significant reduction in the margin of safety. 

    'Each of the affected components, with the exception of'the'HPCI torus suction valves (see below),'are safety-related containment isolation             ,

valves that are required to automatically isolate or remain isolated upon l receipt of an isolation signal. The primary function of the containment system and containment isolation valves is to limit the release of R radioactive material, and thereby limit the radiological consequences of accidents to within the limits set by 10CFR100. The containment and components necessary to maintain the containment provide a margin of safety to protect the public and environment from radioactive releases following a Design Basis Accident (DBA). In order to accomplish this function, containment isolation valves must meet specified leakage rates and closing times, and be periodically tested to assure that the specified rates and times are met. The HPCI torus suction valves are safety-related valves that are required to isolate or remain isolated upon receipt of an isolation signal. These valves perform safety functions which are important to the operation of the HPCI system and are not relied upon to perform a containment isolation function. m

The discussions provided in Sections 1 and 2 above on the 'various_ changes I demonstrate that the proposed amendment is bounded by the Pilgrim DBA. 1The changes will not result in the violation of containment integrity, and therefore the proposed amendment does not involve a significant-reduction in the margin of safety. These proposed changes involve additions and deletions of valves listed on Table 3.7.1 due to plant modifications, changes in the normal . valve line-up, reduced valve operating times, and editorial changes for clarity and consistency. BECo has performed safety evaluations for all changes in accordance with 10CFR50.59 and determined that no unreviewed safety questions exist. This change has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee. SCHEDULE OF CHANGE It is requested that the proposed amendment becomd effective within 30 days of Boston Edison's receipt of approval by the NRC. j i l t 

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