ML040060622

Application for Technical Specification (TS) Improvement to Delete the TS Requirements for the Hydrogen Analyzers Using the Consolidated Line Item Improvement Process

ML040060622
Person / Time
Site:	Pilgrim
Issue date:	12/24/2003
From:	Balduzzi M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ENO Ltr.2.03.138
Download: ML040060622 (18)

Text

'Entergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Michael A. Balduzzi Site Vice President December 24, 2003 ENO Ltr. 2.03.138 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D. C. 20555-0001

SUBJECT:

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 APPLICATION FOR TECHNICAL SPECIFICATION (TS)

IMPROVEMENT TO DELETE THE TS REQUIREMENTS FOR THE HYDROGEN ANALYZERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

Dear Sir:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) hereby requests an amendment to the Technical Specifications (TS) for the Pilgrim Nuclear Power Station.

The proposed amendment will delete the Pilgrim TS requirements related to the hydrogen analyzers. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Registeron September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

Attachment 1 provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications and commitments.

Attachment 2 provides the existing TS pages marked-up to show the proposed changes and associated bases changes. The bases changes are provided for information only.

Attachment 3 provides revised, clean TS pages.

ENO requests approval of the proposed License Amendment by June 30, 2004, with the amendment being implemented within 60 days from the date of approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Massachusetts Officials.

AV1

ENO Ltr. 2.03.138 Page 2 The commitments made in this letter are contained in Attachment 4. If you have any questions, 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. 24th day of December 2003 Sincerely, Michael A. Balduzzi Attachments: As stated cc: Mr. Travis Tate, Project Manager Mr. Steve McGrail, Director Office of Nuclear Reactor Regulation Mass. Emergency Mail Stop: 0-8B-1 Management Agency U.S. Nuclear Regulatory Commission 400 Worcester Road 1 White Flint North Framingham, MA 01702 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector Mr. Robert Walker Pilgrim Nuclear Power Station Radiation Control Program Commonwealth of Massachusetts Exec Offices of Health & Human Services 174 Portland Street Boston, MA 02114 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19408

ATTACHMENT 1 (3 pages)

APPLICATION FOR TECHNICAL SPECIFICATION (TS)

IMPROVEMENT TO DELETE THE TS REQUIREMENTS FOR THE HYDROGEN ANALYZERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS DESCRIPTION AND ASSESSMENT ENTERGY NUCLEAR OPERATIONS, INC PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

Attachment 1 to ENO Ltr. 2.03.138 Docket No. 50-293 Page 1 of 3 ATTACHMENT 1 Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes references to the hydrogen analyzers in Technical Specification (TS) sections 3.7.A.7.c and 4.7.A.7.c. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC approved Revision 1 of TSTF-447, the proposed TS changes consist of deleting sections 3.7.A.7.c and 4.7.A.7.c of the Pilgrim TS, which relate to the hydrogen analyzers. The TS Bases changes are provided for information only. The Pilgrim custom TS contain specifications that are different than the model TS changes contained in the CLIIP. The model TS are based on the Improved Standard TS. The differences between the Pilgrim custom TS and the CLIIP model TS are primarily in the area of TS that exist in the CLIIP Model TS that do not exist in the Pilgrim TS. Pilgrim does not have hydrogen recombiners, therefore that part of the CLIIP is not being addressed. In addition, while Pilgim has oxygen analyzers, they are not addressed in the current custom TSs. Therefore, a TS change is also not required for the oxygen analyzers. The commitments for hydrogen and oxygen monitors contained in the CLIIP, are addressed in Section 6.0 below.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Rev. 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

Attachment 1 to ENO Ltr. 2.03.138 Docket No. 50-293 Page 2 of 3 4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Rev. 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

ENO has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staff's SE, as well as the supporting information provided to support TSTF-447, Rev. 1. ENO has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Pilgrim and justify this amendment for the incorporation of the changes to the Pilgrim TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25 (68 FR 55416), TSTF-447, Rev. 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, ENO is making the following verifications and regulatory commitments:

1. ENO has verified that a hydrogen monitoring system (hydrogen analyzers) capable of diagnosing beyond design-basis accidents is installed at Pilgrim and is making a regulatory commitment to maintain that capability (at least to the level of Reg. Guide 1.97, Category 3). The hydrogen monitors are described in section 10.19 of the Updated FSAR. This section will be revised to reflect the license amendment within 60 days from the date of the approval of this proposed amendment.

2. Pilgrim has an inerted containment. ENO has verified that an oxygen monitoring system (oxygen analyzers) capable of verifying the status of the inerted containment is installed at Pilgrim and is making a regulatory commitment to maintain that capability (at least to the level of Reg. Guide 1.97, Category 2). The oxygen monitors are described in section 10.19 of the Updated FSAR. This section will be revised to reflect the license amendment within 60 days from the date of approval of this proposed amendment.

Attachment 1 to ENO Ltr. 2.03.138 Docket No. 50-293 Page 3 of 3 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION ENO has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to Pilgrim and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to Pilgrim and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. ENO is not proposing variations or deviations from the TS changes described in TSTF-447, Rev. 1, or the NRC staff's model SE, published on September 25,2003 (68 FR 55416).

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

ATTACHMENT 2 (4 pages)

APPLICATION FOR TECHNICAL SPECIFICATION (TS)

IMPROVEMENT TO DELETE THE TS REQUIREMENTS FOR THE HYDROGEN ANALYZERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS TECHNICAL SPECIFICATION MARKED-UP PAGES TS PAGES 3/4.7-10 3/4.7-11 BASES PAGES B314.7-8 B3/4.7-9 ENTERGY NUCLEAR OPERATIONS, INC PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREHENTS 3.7 CONTAINMENT SYSTEMS (Cont) 4.7 CONTAINMENT SYSTEMS (Cont)

A. Prinarv Containment (Cont) A. Primary Containment (Cont)

7. Containment Atmosphere Dilution 7. Containment Atmosnnere Dilution

a. Within the 24-hour period a. The post-LOCA containment after placing the reactor in atmosphere dilution system the Run Mode the Post-LOCA shall be functionally tested Containment Atmosphere once per operating cycle.

Dilution System must be operable and capable of b. The level in the liquid N, supplying nitrogen to the stora-e tank shall e containment for atmosphere recorded weekly.

dilution. If this specification cannot be met, the system must be restored to an operable condition within 30 days or the reactor must be at least in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. d. Once per month each manual or power operated valve in

b. Within the 24-hour period the CAD system flow path not after placing the reactor in locked, sealed or other-wise the Run Mode, the Nitrogen secured in position shall be-Storage Tank shall contain a observed and recorded to be minimum of 1500 gallons of . in its correct position.

liquid N2 . If this specification cannot be met the minimum volume will be restored within 30 days or the reactor must be in at least Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d. Thre ae 2 H2 alyserS a aila e o seve he/

dryweL.

With on y 1 2 ana zer-erab e, r actor oper tion is al owe for u to days..

If e i perab ar lyze.

is ot de f ly erable w hin days, th reac or all e in le Ho hutdwnwihin hen at hour.

Amendment No. 53 3/E. 7cia

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7 CONTAINMENT SYSTEMS (Cont.) 4.7 CONTAINMENT SYSTEMS (Cont.)

' Pri a y ontai ent ( ont.

th no an yzer era ere or ppera on is lowed or up 48 ours If one f the i opera e an yzer is no ma fu oper le wit n 48 ours he rq ctor/

s all be* at let Hothut wn thin e ext hours B. Standby Gas Treatment System and B. Standbv Gas Treatment System and Control Room High Efficiency Air Control Room High Efficiencv Air Filtration Filtration System System

1. Standby Gas Treatment System 1. Standby Gas Treatment System

a. Except as specified in 3.7.B.1.c or a. 1. At least once per operating cycle, 3.7.B.1.e below, both trains of the it shall be demonstrated that standby gas treatment shall be pressure drop across the operable when in the Run, Startup, combined high efficiency filters and and Hot Shutdown MODES, during charcoal adsorber banks is less movement of irradiated fuel than 8 inches of water at 4000 cfm.

assemblies in the secondary 2. At least once per operating cycle, containment, and during movement demonstrate that the inlet heaters of new fuel over the spent fuel pool, on each train are operable and are and during CORE ALTERATIONS, capable of an output of at least 20(

and during operations with a kW.

potential for draining the reactor vessel (OPDRVs), 3. The tests and analysis of Specification 3.7.B.1.b. shall be performed at least once per or operating cycle or following painting, fire or chemical release in the reactor shall be in cold any ventilation zone shutdown within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. communicating with the system while the system is operating that

b. 1. The results of the in-place cold could contaminate the HEPA filters DOP tests on HEPA filters shall or charcoal adsorbers.

show >99% DOP removal. The results of halogenated 4. At least once per operating cycle, hydrocarbon tests on charcoal automatic initiation of adsorber banks shall show

>99.9%.halogenated hydrocarbon removal.

Amendment No.15,142,50,51, 5,114,111,151,161, 170,4187,1947 3/4.7-1 1

BASES:

1/4.7 CONTAINMENT SYSTEMS (Cont)

/... Primary Containment (Cont) wetwell pressure differential to keep the suppression chamber downcomer legs clear of water significantly reduced suppression chamber post LOCA hydrodynamic loads. A pressure of 1.17 psid is required to sufficiently clear the water legs of the downcomers without bubbling nitrogen into the suppression chamber at the 3.00 ft. downcomer submergence which corresponds to approximately 84,000 ft.3 of water. Maximum downcomer submergence is 3.25 ft.

at operating suppression chamber water level. The above pressure differential and submergence number are used in the Pilgrim I Plant Unique Analysis.

Post LOCA Atmosphere Dilution In order to ensure that the containment atmosphere remains inerted, i.e. the oxygen-hydrogen mixture below the flammable limit, the capability to inject nitrogen into the containment after a LOCA is provided. A minimum of 1500 gallons of liquid N2 in the storage tank assures that a three-day supply of N2 for post-LOCA containment inerting is available. Since the inerting makeup system is continually functioning, no periodic testing of the system is required.

The Post-LOCA Containment Atmospheric Dilution (CAD) System is designed to meet the requirements of AEC Regulatory Guides 1.3, 1.7 and 1.29, ASME Section III, Class 2 (except for code stamping) and seismic Class I as defined in the PNPS FSAR.

In summary, the limiting criteria are:

1. Maintain hydrogen concentration in the containment during post-LOCA conditions to less than 4%.

2. Limit the buildup in the containment pressure due to nitrogen addition to less than 28 psig.

3. To limit the offsite dose due to containment venting (for pressure control) to less than 300 Rem to the thyroid.

By maintaining at least a 3-day supply of N2 on site there will be sufficient time after the occurrence of a LOCA for obtaining additional nitrogen supply from local commercial sources.(') The system design contains sufficient redundancy to ensure its reliability. Thus, it is sufficient to test the operability of the whole system once per operating cycle. he H anal er$

wit pr ide eduncancy f r the rywe i.e. there /are tw H2 alyz s or t e Un . per tting/reacto oper on r 7 ds with one f th twc H2 Analy rs i ioper le, rundan y of nalyz g cap ility sill e mai taied while/not mposiA g an i ediae intrrupti n in p ant op ratio Mth (1) As listed in Pilgrim Nuclear Power Station Procedure No. 5.4.6 "Post Accident Venting".

Revision 77 Ame et No. 5S,-ll3 B3/4.7-8

3/4.7 CONTAINMENT SYSTEMS (Cont) testi g of th analzer usin H2 ill b ade at to e sur the. yst 's adi es; be use of he sig. Si e th ana zer areor ly got in ope tio ther wj belittle d erio tio due 'us. In 9ider o d erm e con entr tionthe

'nalyze mu be arm dup ho spr toputtj g ose ice. Thi tim fr e is acc tabl for ccide t Co dito be us a 4 H2 evel I nt be rea e in the ywell ntil 6 ho rs fol owin the ci nt- Due o nitrogen addition, the pressure in the containment after a LOCA will increase with timt. Under the worst expected conditions the containment pressure will reach 28 psig in approximately 45 days. If and when that pressure is reached, venting from the containment shall be manually initiated per the requirements of 10CFR50.44. The venting path will be through the Standby Gas Treatment system in order to minimize the off site dose.

B.1 Standby Gas Treatment System The Standby Gas Treatment System is designed to filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions. Upon containment isolation, both standby gas treatment fans are designed to start to bring the reactor.building pressure negative so that all leakage should be in leakage. After a preset time delay, the standby fan automatically shuts down so the reactor building pressure is maintained approximately 1/4 inch of water negative. Should one system fail to start, the redundant system is designed to start automatically. Each of the two trains has 100% capacity.

High Efficiency Particulate Air (HEPA) filters are installed before and after the charcoal adsorbers to minimize potential release of particulates to the environment and to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment. The in-place test results should indicate a system leak tightness of less than 1 percent bypass leakage for the charcoal adsorbers and a HEPA filter efficiency of at least 99 percent removal of cold DOP particulates. The laboratory carbon sample test results should indicate a methyl iodide removal efficiency of at least 95 percent for expected accident conditions. The specified efficiencies for the charcoal and particulate filters is sufficient to preclude exceeding 10CFR100 guidelines for the accidents analyzed. The analysis of the loss of coolant accident assumed a charcoal adsorber efficiency of 95% and TID 14844 fission product source terms, hence, installing two banks of adsorbers and filters in each train provides adequate margin. A 20 kW heater maintains relative humidity below 70% in order to ensure the efficient removal of methyl iodide on the impregnated charcoal adsorbers.

Considering the relative simplicity of the heating circuit, the test frequency of once/operating cycle is adequate to demonstrate operability.

Air flow through the-filters and charcoal adsorbers for 15 minutes each month assures operability of the system. Since the system heaters are automatically controlled, the air flowing through the filters and adsorbers will be 70% relative bumidity and will have the desired drying effect.

Revisios 7, 4-3, 226

<Anendment No 4 4 4 1., 194 B3/4.7-9

ATTACHMENT 3 (4 pages)

APPLICATION FOR TECHNICAL SPECIFICATION (TS)

IMPROVEMENT TO DELETE THE TS REQUIREMENTS FOR THE HYDROGEN ANALYZERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS TECHNICAL SPECIFICATION PAGES TS PAGES 3/4.7-10 3/4.7-11 BASES PAGES 83/4.7-8 6314.7-9 ENTERGY NUCLEAR OPERATIONS, INC PILGRIM NUCLEAR POWER STATION

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7 CONTAINMENT SYSTEMS (Cont) 4.7 CONTAINMENT SYSTEMS (Cont)

A. Primary Containment (Cont) A. Primary Containment (Cont)

7. Containment Atmosphere Dilution 7. Containment Atmosphere Dilution

a. Within the 24-hour period after a. The post-LOCA containment placing the reactor in the Run Mode atmosphere dilution system shall be the Post - LOCA Containment functionally tested once per operating Atmosphere Dilution System must cycle.

be operable and capable of b. The level in the liquid N2 storage tank supplying nitrogen to the shall be recorded weekly.

containment for atmosphere dilution. If this specification cannot c. Not used.

be met, the system must be d. Once per month each manual or I

restored to an operable condition power operated valve in the CAD within 30 days or the reactor must system flow path not locked, sealed be at least in Hot Shutdown within or otherwise secured in position shall 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. be observed and recorded to be in its

b. Within the 24-hour period after correct position.

placing the reactor in the Run Mode, the Nitrogen Storage Tank shall contain a minimum of 1500 gallons of liquid N2. If this specification cannot be met the minimum volume will be restored within 30 days or the reactor must be in at least Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Amendment No. 55 314.7-10

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7 CONTAINMENT SYSTEMS (Cont.) 4.7 CONTAINMENT SYSTEMS (Cont.)

B. Standby Gas Treatment System and B. Standby Gas Treatment System and Control Room High Efficiency Air Control Room High Efficiency Air Filtration Filtration System System

1. Standby Gas Treatment System 1. Standby Gas Treatment System

a. Except as specified in 3.7.B.1.c or a. 1. At least once per operating cycle, 3.7.B.1.e below, both trains of the it shall be demonstrated that standby gas treatment shall be pressure drop across the operable when in the Run, Startup, combined high efficiency filters and and Hot Shutdown MODES, during charcoal adsorber banks is less movement of irradiated fuel than 8 inches of water at 4000 cfm.

assemblies in the secondary containment, and during movement 2. At least once per operating cycle, of new fuel over the spent fuel pool, demonstrate that the inlet heaters and during CORE ALTERATIONS, on each train are operable and are and during operations with a capable of an output of at least 20 potential for draining the reactor kW.

vessel (OPDRVs), 3. The tests and analysis of or Specification 3.7.B.1.b. shall be performed at least once per operating cycle or following the reactor shall be in cold painting, fire or chemical release in shutdown within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. any ventilation zone

b. 1. The results of the in-place cold communicating with the system DOP tests on HEPA filters shall while the system is operating that show >99% DOP removal. The could contaminate the HEPA filters results of halogenated or charcoal adsorbers.

hydrocarbon tests on charcoal 4. At least once per operating cycle, adsorber banks shall show automatic initiation of

> 99.9% halogenated hydrocarbon removal.

Amendment No.15, 142, 50, 51, 52,112, 111, 151, 161, 170, 187, 34 3/4.7-11

BASES:

3/4.7 CONTAINMENT SYSTEMS (Cont)

A. Primary Containment (Cont) wetwell pressure differential to keep the suppression chamber downcomer legs clear of water significantly reduced suppression chamber post LOCA hydrodynamic loads. A pressure of 1.17 psid is required to sufficiently clear the water legs of the downcomers without bubbling nitrogen into the suppression chamber at the 3.00 ft.

downcomer submergence which corresponds to approximately 84,000 ft.3 of water.

Maximum downcomer submergence is 3.25 ft. at operating suppression chamber water level. The above pressure differential and submergence number are used in the Pilgrim I Plant Unique Analysis.

Post LOCA Atmosphere Dilution In order to ensure that the containment atmosphere remains inerted, i.e. the oxygen-hydrogen mixture below the flammable limit, the capability to inject nitrogen into the containment after a LOCA is provided. A minimum of 1500 gallons of liquid N2 in the storage tank assures that a three-day supply of N2 for post-LOCA containment inerting is available. Since the inerting makeup system is continually functioning, no periodic testing of the system is required.

The Post-LOCA Containment Atmospheric Dilution (CAD) System is designed to meet the requirements of AEC Regulatory Guides 1.3, 1.7 and 1.29, ASME Section ll, Class 2 (except for code stamping) and seismic Class I as defined in the PNPS FSAR.

In summary, the limiting criteria are:

1. Maintain hydrogen concentration in the containment during post-LOCA conditions to less than 4%.

2. Limit the buildup in the containment pressure due to nitrogen addition to less than 28 psig.

3. To limit the offsite dose due to containment venting (for pressure control) to less than 300 Rem to the thyroid.

By maintaining at least a 3-day supply of N2 on site there will be sufficient time after the occurrence of a LOCA for obtaining additional nitrogen supply from local commercial sources. () The system design contains sufficient redundancy to ensure its reliability. Thus, it is sufficient to test the operability of the whole system once per operating cycle.

(1) As listed in Pilgrim Nuclear Power Station Procedure No. 5.4.6 "Post Accident Venting".

Revision B3/4.7-8

BASES:

3/4.7 CONTAINMENT SYSTEMS (Cont)

Due to nitrogen addition, the pressure in the containment after a LOCA will increase with time. Under the worst expected conditions the containment pressure will reach 28 psig in approximately 45 days. If and when that pressure is reached, venting from the containment shall be manually initiated per the requirements of 10CFR50.44. The venting path will be through the Standby Gas Treatment system in order to minimize the off site dose.

B.1 Standby Gas Treatment System The Standby Gas Treatment System is designed to filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions. Upon containment isolation, both standby gas treatment fans are designed to start to bring the reactor building pressure negative so that all leakage should be in leakage. After a preset time delay, the standby fan automatically shuts down so the reactor building pressure is maintained approximately 1/4 inch of water negative. Should one system fail to start, the redundant system is designed to start automatically. Each of the two trains has 100%

capacity.

High Efficiency Particulate Air (HEPA) filters are installed before and after the charcoal adsorbers to minimize potential release of particulates to the environment and to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment. The in-place test results should indicate a system leak tightness of less than 1 percent bypass leakage for the charcoal adsorbers and a HEPA filter efficiency of at least 99 percent removal of cold DOP particulates. The laboratory carbon sample test results should indicate a methyl iodide removal efficiency of at least 95 percent for expected accident conditions. The specified efficiencies for the charcoal and particulate filters is sufficient to preclude exceeding 10CFR100 guidelines for the accidents analyzed. The analysis of the loss of coolant accident assumed a charcoal adsorber efficiency of 95% and TID 14844 fission product source terms, hence, installing two banks of adsorbers and filters in each train provides adequate margin. A 20 kW heater maintains relative humidity below 70% in order to ensure the efficient removal of methyl iodide on the impregnated charcoal adsorbers.

Considering the relative simplicity of the heating circuit, the test frequency of once/operating cycle is adequate to demonstrate operability.

Air flow through the filters and charcoal adsorbers for 15 minutes each month assures operability of the system. Since the system heaters are automatically controlled, the air flowing through the filters and adsorbers will be <70% relative humidity and will have the desired drying effect.

Revision 133/4.7-9

DOCKET NO. 50-293 ATTACHMENT 4 (1 page)

APPLICATION FOR TECHNICAL SPECIFICATION (TS)

IMPROVEMENT TO DELETE THE TS REQUIREMENTS FOR THE HYDROGEN ANALYZERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

SUMMARY

OF REGULATORY COMMITMENTS ENTERGY NUCLEAR OPERATIONS, INC

Attachment 4 to ENO Ltr. 2.03.138 Docket No. 50-293 Page 1 of 1 ATTACHMENT 4

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies those actions committed to by ENO in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Bryan Ford at (508) 830-8403.

Commitments Description Completion Schedule The hydrogen monitoring system This regulatory (hydrogen analyzers) will maintain the commitment will be capability of diagnosing beyond design- implemented within 60 basis accidents (at least to the level of days from the date of Reg. Guide 1.97, Category 3). approval of the proposed amendment.

2 The hydrogen monitors (hydrogen This regulatory analyzers) are described in section 10.19 commitment will be of the Updated FSAR and it will be revised implemented within 60 to reflect the license amendment. days from the date of approval of the proposed amendment.

3 The oxygen monitoring system (oxygen This regulatory analyzers) will maintain the capability of commitment will be verifying the status of the inerted implemented within 60 containment (at least to the level of Reg. days from the date of Guide 1.97, Category 2). approval of the proposed amendment.

4 The oxygen monitors (oxygen analyzers) This regulatory are described in section 10.19 of the commitment will be Updated FSAR and it will be revised to implemented within 60 reflect the license amendment. days from the date of approval of the proposed amendment.