ML032390057

License Amendment Request to Amend Technical Specifications Table 3.2.C-1

ML032390057
Person / Time
Site:	Pilgrim
Issue date:	08/19/2003
From:	Balduzzi M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML032390057 (8)

Text

Et Entergy Nuclear Operations, Inc.

Energy Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Michael A. 8alduzzi Site Vce President August 19, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 License Amendment Request to Amend Technical Specifications (TS)

Table 3.2.C-1

REFERENCES:

1. BECo Letter No. 91-0005, Proposed Technical Specification APRM, RBM, and TS Improvement Program, dated January 22, 1991.

2. License Amendment 138, dated July 1, 1991 3 Entergy Letter No. 2.03.076, Core Operating Limits Report, Revision 15A, dated, May 13, 2003.

LETTER NUMBER: 2.03.090

Dear Sir or Madam:

Entergy requests NRC approval of proposed changes to Pilgrim's Technical Specification (TS)

Tables 3.2.C-1 In accordance with 10 CFR 50.90.

Entergy proposes a correction to the Rod Block Monitor (RBM) power dependent set point numerical allowable value from 529% to s25.9% in TS Table 3.2.C-1. A set point value of Q29%

instead of S25.9% was incorrectly inserted In the proposed Technical Specification change request (Ref. 1) that was carried through the License Amendment 138 (Ref. 2). The plant procedures and Core Operating Limits Report (COLR) (Ref. 3) have enforced the correct set point value of 525.9% derived from the NRC approved methodology In compliance with TS 5.6.5. This proposed change corrects the error in Note 5 for Table 3.2.C-1 to conform to the value used in plant procedures and COLR since the issuance of License Amendment 138.

203090 7to(

Entergy Nuclear Operations, Inc. Letter Number: 2.03.090 Pilgrim Nuclear Power Station Page 2 The enclosure provides an evaluation of the proposed change and mark-up of Technical Specification.

Pilgrim has reviewed the proposed amendment in accordance with 10 CFR 50.92 and concludes it does not involve a significant hazards consideration.

Entergy requests approval of this change by September 1, 2004. Once approved, the amendment will be implemented within 60 days.

If you have any questions or require additional information, please contact Mr. Bryan Ford, Licensing Manager, at (508) 830-8403.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the /t? day of 644 tsr- 2003.

Sincerely, Michael A. Balduzzi

Enclosure:

Evaluation Of The Proposed Changes - 4 pages . Proposed Technical Specification (mark-up) - 1 page cc:

Mr. Travis Tate, Project Manager Mr. Steve McGrail, Director Office of Nuclear Reactor Regulation Mass. Emergency Management Agency Mail Stop: 0-81-1 400 Worcester Road U.S. Nuclear Regulatory Commission P.O. Box 1496 1 White Flint North Framingham, MA 01702 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Mr. Robert Walker Region 1 Radiation Control Program 475 Allendale Road Commonwealth of Massachusetts King of Prussia, PA 19406 Exec Offices of Health & Human Services 174 Portland Street Boston, MA 02114 Senior Resident Inspector Pilgrim Nuclear Power Station 203090

4 .

ENCLOSURE Evaluation Of The Proposed Changes

Subject:

Reauest for Amendment to the Technical Snecifications Table 3.2.C-1

1. DESCRIPTION

2. PROPOSED CHANGES

3. BACKGROUND

4. TECHNICAL ANALYSIS

5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration

6. ENVIRONMENTAL CONSIDERATION

7. REFERENCES Page 1 of 4

1 ^

DESCRIPTION This letter is a request to amend Operating License DPR-35 for Pilgrim Nuclear Power Station. The proposed amendment revises Technical Specification (TS) Note 5 to Table 3.2.C-1.

A correction to the Rod Block Monitor (RBM) Power Dependent Low Power Set Point (LPSP) numerical allowable value from <Q9% to s25.9% in Note 5 to TS Table 3.2.0-1 is proposed. The set point value of s29% instead of s25.9% was incorrectly inserted in the proposed Technical Specification change that was carried through the License Amendment 138 (Reference 1 and 2). This error is corrected to conform to the Core Operating Limits Report (COLR) submitted to the NRC for fuel cycle 15 (Ref. 3). Section 2.3 of COLR correctly identifies the set point allowable value as 525.9% of rated power.

The above-proposed change had no impact on the safe operation of Pilgrim station because the actual allowable RBM LPSP set point value of s25.9% has been enforced by COLR and plant procedures.

Entergy requests approval of this change by September 1, 2004.

2. PROPOSED CHANGES The last sentence of Note 5 for TS Table 3.2.C-1 on TS page 3/4.2-22 is revised to state as follows:

"The allowable value for the LPSP is s25.9% of rated core thermal power."

3. BACKGROUND BECo Letter No.91-005, dated January 22, 1991 (Ref. 1) proposed changes to Pilgrim Technical Specifications to implement ARTS (Average Power Range Monitor, Rod Block Monitor and Technical Specification) improvement program. A set point value of s29%

instead of s25.9% was incorrectly inserted in the proposed Technical Specification change request (Ref. 1). That incorrect allowable set point value was carried through the License Amendment 138 (Ref. 2). However, the error was not translated into COLR and plant procedures. The COLR and plant procedures correctly specified the RBM LPSP as 525.9% of rated core thermal power. This proposed TS change corrects the error to conform to the COLR (Ref. 3) and plant procedures. Section 2.3 of COLR correctly specifies the RBM LPSP allowable value as s25.9%.

4. TECHNICAL ANALYSIS Pilgrim is required to operate within the core operating limits, as derived in accordance with NRC approved methodology In compliance with TS 5.6.5. Accordingly, Pilgrim has submitted the core operating limits report for cycle 15. Section 2.3 of the report specifies the allowable values for the power-dependant rod block monitor trip setpoints. The low power set point limit specified is 525.9%. This bounding value is from the calculations Page 2 of 4

done for the ARTS program submitted for the NRC approval (Ref. 1) and approved by License Amendment 138 (Ref. 2).

Compliance with the low power set point assures RBM downscale trip is bypassed for reactor power s 25.9% of rated thermal power.

The proposed TS change is more conservative than the current incorrect requirement.

The proposed RBM LPSP allowable value of 525.9% provides rod block protection over a wider power range from 525.9% to 100%, instead of s29% to 100%, thereby enforcing RBM protection against a rod withdrawal error at a lower power level. The proposed requirement is consistent with the COLR and is in accordance with License Amendment 138. Pilgrim has enforced a RBM LPSP set point value of 525.9% since the License Amendment 138.

5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (Entergy) proposes to correct the Rod Block Monitor Low Power Set Point (LPSP) to S25.9% from s29% in Note 5 of Technical Specification Table 3.2.C-1. Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment, as discussed below:

1. Does the proposed change Involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed Rod Block Monitor (RBM) power dependant Low Power Set Point (LPSP) of S25.9% corrects the incorrect value of S29% in Note 5 of TS Table 3.2.C-1 and is more restrictive than the Incorrect value. The proposed set point allowable value of 525.9% provides rod block protection over a wider power range from Q525.9% to 100%, instead of s29% to 100%, thereby enforcing RBM protection against rod withdrawal error at a lower power level. Also, the proposed requirement Is consistent with the core operating limits report and is in accordance with License Amendment 138.

The proposed RBM LPSP value ensures safe operation of the plant during startup and run modes. This requirement is not an accident precursor. The proposed analytical value Q25.9% was derived from the Average Power Range Monitor, Rod Block Monitor and Technical Specification (ARTS) improvement program methodology that was approved by License Amendment 138 and complies with the analytical methods required by Technical Specification 5.6.5. The proposed change provides additional assurance that the core operating limits are followed for safe operation and assumptions for core operating limits are met.

Page 3 of 4

Therefore, the probability or consequence of an accident previously evaluated is not significantly increased.

2. Does the proposed change create the possibility of a new or different kind of accident for any accident previously evaluated?

Response: No The proposed change does not involve a change to the plant design or a new mode of equipment operation and enforces previously evaluated conditions. As a result, the proposed changes do not affect parameters or conditions that could contribute to the initiation of any new or different kind of accident. Therefore, this proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the change involve a significant reduction in a margin of safety?

Response: No The proposed change increases the margin of safety by providing additional assurance that the RBM downscale trip is not bypassed for reactor power 225.9% of rated thermal power and is based on previously evaluated methodologies. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, Entergy concludes that this proposed license amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly a finding of "no significant hazards consideration" is justified.

6. ENVIRONMENTAL CONSIDERATIONS The proposed amendment does not Involve (i) a significant hazards consideration, (ii) a significant change in the types or significant change in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.2(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7. REFERENCES

1. BECo Letter No. 91-0005, Proposed Technical Specification APRM, RBM, and TS Improvement Program, dated January 22, 1991.

2. License Amendment 138, dated July 1, 1991

3. Entergy Letter No. 2.03.076, Core Operating Limits Report 15A, dated, May 13, 2003.

Page 4 of 4

ATTACHMENT 1 Proposed Technical Speclfication (mark-up) -1 page TS Page 3/4.2-22 203090.pdf

NOTES FOR TABLE 3.2.C-1

1. Deleted-

2. a. With one RBM Channel inoperable:

(1) restore the inoperable RBM channel to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; otherwise place one rod block monitor channel in the tripped condition within the next hour, and; (2) prior to control rod withdrawal, perform an instrument function test of the operable RBM channel.

b. With both RBM channels inoperable, place at least one inoperable rod block monitor channel in the tripped condition within one hour.

3. Deleted

4. Deleted

5. RBM operability Is required in the run mode in the presence of a limiting rod pattern with reactor power greater than the RBM low power setpoint (LPSP). A limiting rod pattern exists when:

MCPR < 1.41 for reactor power > 90%

MCPR < 1.72 for reactor power < 90%

The allowable value for the LPSP is < of rated core thermal power.

6. Deleted

7. With one or more Reactor Mode Switch - Shutdown Position channels inoperable, suspend control rod withdrawal and initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies immediately.

Amendment No. lE, 21 i-, _, "42 , 314.2-22