BECO-92-101, Application for Amend to License DPR-35,changing TS 3/4.2 Re HPCI Instrumentation to Support Mod Planned During Refueling Outage 9 of Control Conduit for Several Valves in HPCI Indication in CR Per Reg Guide 1.97

Application for Amend to License DPR-35,changing TS 3/4.2 Re HPCI Instrumentation to Support Mod Planned During Refueling Outage 9 of Control Conduit for Several Valves in HPCI Indication in CR Per Reg Guide 1.97

ML20114B141
Person / Time
Site:	Pilgrim
Issue date:	08/17/1992
From:	Richard Anderson BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20114B143	List: BECO-92-101, Application for Amend to License DPR-35,changing TS 3/4.2 Re HPCI Instrumentation to Support Mod Planned During Refueling Outage 9 of Control Conduit for Several Valves in HPCI Indication in CR Per Reg Guide 1.97 ML20114B145
References
RTR-REGGD-01.097, RTR-REGGD-1.097 BECO-92-101, NUDOCS 9208250093
Download: ML20114B141 (4)

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I 10CFR50.90 BOSTON EDISON RO I*9I PQom Nucioar Power Statica Rocky H41 Road Plymouth. Massachusetts 02360 Roy A. Anderson BECo 92-101 senior vice Presdent - Nuclear August 17, 1992 U.S. Nuclear Regulatory Commission Document Contr Nk Washington, Dt 3

License DPR-35 Docket 50-293 Proposed Technical Specification Chanae to Section 3/4,2: HPCI instrumentation Boston Edison proposes the attached changes to Section 3/4.2 'HPCI Instrumentation" of the Pilgrim Nuclear Power Station Technical Specifications in accordance with 10CFR50.90.

The proposed change supports a modification

. planned for RF0 #9 of the control circuit for several valves in the HPCI system. The modification will upgrade the circuitry to provide valve position indication in the Control Room in accordance with our Regulatory Guide 1.97 program implementation.

The requested change is described in Astachment A, the revised Technical Specification pages are in Attachment B, and the current Technical Specification pages, annotated to indicate the requested revisions, are in Attachment C.

R. A. Anderson MTL/clc/hpciinst Attachments 1 Signed Original and 37 Copies cc:

See Next Page Commonwealth of Massachusetts)

County of Plymouth

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Then personally appeared before me, Roy A. Anderson, who being duly sworn, did stn e 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 know'Tdge and belief.

My commission expires:

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NOTARY PUBLIC 9208250093 920817 PDR ADOCK 05000293 Ag/

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- BOSTONLEDISON COMPANY

- U.. S. Nuclear. Regulatory. Commission -

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Mr. R. Eaton, Project Manager Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Mail Stop:

1401 U. S. Nuclear Regulatory Commission 1 White Flint North

~ 11555 Rockville Pike Rockville, MD 20852 U. S. Nucler.r Regulatory Commission Region I.

475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear-Power Station Mr.- Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 305 South Street Jamaica Plain,. MA 02130 A

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Attachment A to'BECo letter 92-101-P onosed Chanr1g The proposed chuges to the. Pilgrim Technical Specification Table 3.2.B replace the HPCI Steam Line Low Pressure (100>P>50 psig) isolation signal with the-Reactor Low Pressure (100>P>50 psig) signal and remove HPCI from Note 5 of the table.

The proposed change to Table 4.2.8 removes HPCI from Iten 13.

Reason for Chan::e:

This proposed Technical-Specification Change reflects a planned modification to improve reliability of the HPCI low pressure isolation logic.

Presently the HPCI system will isolate on' low pressure sensed at the HPCI turbine steam inlet piping. The planned modification will change the low pressure isolation-signal from the HPCI steam inlet piping to the reactor vessel as sensed by the-

- Analog Trip: System.

' Changing to:the reactor vessel pressure signal ensures a divisional single failure-proof isolation logic design that is an improvement when compared to the existing HPCI steam' inlet pressure isolation logic. After this logic change, the following' Group IV HPCI components will isolate on low reactor vessel pressure vs. low HPCI-steam inlet pressure:

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HPCI Turbine M0 2301-4 HPCI Steam to Turbine M0 2301-5 HPCI Steam to Turbine M0.2301-35 HPCi Pump Suction from Torus M0 2301-36 HPCI Pump. Suction from Torus M0 2301-14 HPCI Miniflow Bypass to Torus CV 9068A Turbine Exhaust Drain s'ot Isolation CV 9068B Turbine Exhaust Drain Pot Isolation Timing.of this Technical Specification change is driven by a window of opportunity created by planned replacement of the two Turbine Exhaust Drain Pot Isolation valves CV-9068 A & B. ' These valves are being changed to meet the Regulatory Guido 1.97 requirement for position indication in the control re nt...- During change out of CV9068 A & B. a convenient opportunity exists.to p

make the previously discussed ir-:.rovement in our HPCI Group 4 isolation -logic.

In addition to improv mg reliability ~ of the HPCI low pressure isolation logic, this chango will also reduce radiation' exposure of worLers conducting HPCI serveillance tests.

Determination of No Sionificant Hazards

- The Code'of Federal Reculations, 10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its

. analysis, using the standardt in 10CFR50.92, about the issue of no significant hazards consideration. Therefore, in accordance with 10CFR50.91 ano 10CFR50.92 the following analysis has been performed.

. ~

Attachment A to BECo letter 92 101 1.

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

The HPCI steam line' low pressure signal is an operational interlock that trips the HPCI turbine and closes system valves to shutdown the HPCI system when inadequate steam pressure is available to run the HPCI system with the closure of the HPCI vacuum breakers by eliminating the potential for a situation where HPCI is runt.ing and the vacuum breakers are closed.

Therefore, using the Reactor loy Pressure signal (100>P>50 psig) to initiate a Group 4 HPCI isolation is equivalent to using the HPCI Steam Line Low Pressure signal (100>P>50 psig) and does not involve a signif'. ant increase in the probability or cons 3quences of an accident previously evaluated.

Replacing HPCI Steam !ine Low P-essure with Reactor Lov Pressure on Tables 3.2.B and 4.2.8 does not affect the instrument functional test or calibration frequency of the Analog Trip System.

The valve functional and :,ystem operability test frequencies remain unchanged.

2.

The operation of 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 evaluatcd.

The proposea amendment does not create the possibility of a new nr different kind of accident from any accident previously evaluated because HPCI will continue to operate as designed and the HPCI 5 team Line Low Pressure and Reactor Low Pressure signals are functionally equivalent Group 4 initiation signals. The change does not affect the HPCI system's ability to shutdown and isolate when required.

This change improved the coordination of the shutdown of the HPCI system with the closure of the HPCI vacuum breakers by eliminating the potential for a situation waere HPCI is running and the vacuum breakers are closed.

3.

The operition of Pilgrim Station in accordance with the proposed amendment will not involve a signdficani reductice su a margin of safety.

The proposed amendment does not involve a significant reduction in a margin of safety because the nw Group 4 isolation initiation signal is functionally equivalent to the existing initiation signal. This change t' as not affect the HPCI systev s ability to shutdown and

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isolat when required. This change improves the coordination of the shutdown of the HPCI system with the closure of the HPCI vacuum breakers by eliminating t'Te potential for a situation where HPCI is running and the vacuum breakers are clostd.

U is change has been reviewed and recommended for approval by the Operations E lew Committee and reviewed by the Nuclear Safety Review r d Audit b aittee.

Schedule of Chanae This change is requested on or before February 1, 1993, to allow the valve modification to be performed during RF0 #9.

This change will be implemented following completion of the modification and prior to plant startup. - _ _ _ _ - _ _ _ _

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