ML043560151

Technical Specifications Amendment Request to Revise Actions for Scram Discharge Volume (SDV) Vent and Drain Valves Consistent with Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404

ML043560151
Person / Time
Site:	Pilgrim
Issue date:	12/14/2004
From:	Balduzzi M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.04.105
Download: ML043560151 (11)

Text

Entergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Michael A. Balduzzi Site Vice President December 14, 2004 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 Technical Specifications Amendment Request to Revise Actions for Scram Discharge Volume (SDV) Vent and Drain Valves Consistent with Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404

REFERENCE:

Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404, Revision 0, "SDV Actions" LETTER NUMBER: 2.04.105

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations Inc. (Entergy) hereby proposes to amend its Facility Operating License, DPR-35. The proposed changes would revise the required action within Technical Specification (TS) 3.3.G, "Scram Discharge Volume' for the condition of having one or more SDV vent or drain lines with one valve inoperable. These changes are based on the Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404 (Revision 0), that has been approved generically for the BWR/4 Standard Technical Specifications, NUREG-1433. The availability of this TS improvement was announced in the Federal Registeron April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP). Entergy 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 the proposed amendment by December 30, 2005. Once approved, the amendment shall be implemented within 60 days.

There are no commitments contained in this letter.

)C) 2.04.105

Entergy Nuclear Operations, Inc. Letter Number: 2.04.105 Pilgrim Nuclear Power Station Page 2 If you have any questions or require additional information, please contact Bryan Ford at (508) 830-8403.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the December, 2004.

Sincerely, Michael A. Balduzzi ES/dm

Enclosure:

Evaluation of the proposed change - 2 pages Attachments: 1. Proposed Technical Specification and Bases Changes (mark-up) -4 pages cc: Mr. Robert Fretz, Project Manager Ms. Cristine McCombs, Director Office of Nuclear Reactor Regulation Mass. Emergency Management Mail Stop: 0-8B-1 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, Director Pilgrim Nuclear Power Station Massachusetts Department of Public Health Radiation Control Program 90 Washington Street Dorchester, MA 02121 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19408 2.04.105

ENCLOSURE EVALUATION OF THE PROPOSED CHANGE

ENCLOSURE Evaluation of the Proposed Change

Subject:

Technical Specifications Amendment Request to Revise Actions for Scram Discharge Volume (SDV) Vent and Drain Valves Consistent with Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404

1. DESCRIPTION

2. ASSESSMENT

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration 3.2 Verification and Commitment

4. ENVIRONMENTAL CONSIDERATION

5. REFERENCES

Letter 2.04.105 Enclosure Page 1 of 2

1. Description Entergy Nuclear Operations, Inc. (Entergy) is requesting to amend Operating License DPR-35 for Pilgrim Nuclear Power Station (PNPS). The proposed changes would revise the Operating License, Technical Specifications (TS) 3.3.G, "Scram Discharge Volume," for the condition of having one or more SDV vent or drain lines with one valve inoperable. These changes are based on Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404 (Revision 0) that has been approved generically for the BWR/4 Standard Technical Specifications (STS),

NUREG-1 433. The availability of this TS improvement was announced in the Federal Register on April 15, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

2. Assessment 2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (Entergy) has reviewed the model safety evaluation published on April 15, 2003 (68 FR 18294) as part of the CLIIP. This verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-404.

Entergy has concluded that the justifications presented in the TSTF proposal and the model safety evaluation prepared by the NRC staff are applicable to PNPS and justify this amendment for the incorporation of the changes into the PNPS Technical Specifications.

2.2 Optional Changes and Variations Entergy is not proposing any variations or deviations from the Technical Specification changes described in TSTF-404 or the model safety evaluation published on April 15, 2003.

3. Regulatory Analysis 3.1 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (Entergy) is proposing to modify the Pilgrim Nuclear Power Station (PNPS) Technical Specifications (TS) to adopt actions for inoperable scram discharge volume (SDV) vent and drain valves consistent with Technical Specifications Task Force (TSTF)

Change Traveler, TSTF-404, Revision 0, USDV Actions." Entergy has reviewed the proposed no significant hazards consideration determination published on April 15, 2003 as part of the CLIIP.

Entergy has concluded that the proposed determination presented in the notice is applicable to PNPS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments There are no new regulatory commitments associated with this proposed change.

4. Environmental Evaluation Entergy Nuclear Operations, Inc. (Entergy) has reviewed the environmental evaluation included in the model safety evaluation published on April 15, 2003 as part of the CLIIP. Entergy has concluded that the NRC staff's findings presented in that evaluation are applicable to PNPS and the evaluation is hereby incorporated by reference for this application.

Letter 2.04.105 Enclosure Page 2 of 2

5. References

1. Technical Specifications Task Force (TSTF) Change Traveler, TSTF-404, Revision 0, "SDV Actions."

2. Federal Register on April 15, 2003 (68 FR 18294).

ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION AND BASES CHANGES (MARK-UP)

TABLE OF CONTENTS 1.0 DEFINITIONS 1-1 2.0 SAFETY LIMITS 2-1 2.1 Safety Limits 2-1 2.2 Safety Limit Violation 2-1 BASES B2-1 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.0 LIMITING CONDITION FOR OPERATION 4.0 3/4.0-1 (LCO) APPLICABILITY 3.1 REACTOR PROTECTION SYSTEM 4.1 3/4.1-1 BASES B3/4.1 -1 3.2 PROTECTIVE INSTRUMENTATION 4.2 3/4.2-1 A. Primary Containment Isolation Functions A 3/4.2-1 B. Core and Containment Cooling Systems B 3/4.2-1 C. Control Rod Block Actuation C 3/4.2-2 D. Radiation Monitoring Systems D 3/4.2-2 E. Drywell Leak Detection E 3/4.2-3 F. Surveillance Information Readouts F 3/4.2-3 G. Recirculation Pump Trip/ Alternate Rod Insertion G 3/4.2-4 H. Drywell Temperature H 3/4.2-5 BASES B3/4.2-1 3.3 REACTIVITY CONTROL 4.3 3/4.3-1 A. Reactivity Margin - Core Loading A 3/4.3-1 B. Control Rod Operability B 3/4.3-2 C. Scram Insertion Times C 3/4.3-7 D. Control Rod Accumulators D 3/4.3-8 E. Reactivity Anomalies E 3/4.3-10 F. Rod Worth Minimizer (RWM _ F 3/4.3-11 G. Scram Discharge Volume((S V)) G 3/4.3-12 H. Rod Pattern Control H 3/4.3-13 BASES B3/4.3-1 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 3/4.4-1 BASES B3/4.4-1 3.5 CORE AND CONTAINMENT COOLING 4.5 3/4.5-1 SYSTEMS A. Core Spray and LPCI Systems A 3/4.5-1 B. Containment Cooling System B 3/4.5-3 C. HPCI System C 3/4.5-7 D. Reactor Core Isolation Cooling (RCIC) System D 3/4.5-8 E. Automatic Depressurization System (ADS) E 3/4.5-9 F. Minimum Low Pressure Cooling and Diesel F Generator Availability 3/4.5-10 G. (Deleted) G 3/4.5-11 H. Maintenance of Filled Discharge Pipe H 3/4.5-12 BASES B3/4.5-1 Amendment 4-6,--Q9S

LllUMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3 REACTIVITY CONTROL (continued) 4.3 REACTIVITY CONTROL (continued)

G. Scram Dichare Voume LCO 3.3.G G. Scram Dlscharae Volume-As The scram discharge volume drain & SR 4.3-G-1 ventvalves shall be OPERABLE.

Verify scram discharge volume drain APPLICABILITY: and vent valves open at least once per month.

RUN and STARTUP MODES; REFUEL MODE when the reactor SR 4.3.G,2,.

vessel head Is fully tensioned.

Test scram discharge volume drain and vent valves as specified In 4.13. These valves may be closed intermittently for testing under administrative control.

• R 4.3.G:A During each REFUELING INTERVAL verify the scram discharge volume drain Y

V and vent valves.

A a Close within 30'seconds after receipt of a reactor scram signal.

'--NOE-ACTIONS may be applied independently to AO each vent or drain line. . b Open when the scrami is reset.

A. With one or more SDV vent or drain lines with one valve inoperable, isolatebthe associated line within 7 days.

B. One or more SDV vent or drain lines with both valves inoperable, isolate

• the associated line within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

C. Otherwise, be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(*) An isolated line may be unisolated under A administrative control to allow draining and

- i-AgVTiVn-24

,nps-p- 3/4.3-12 Amendment No.,-e

Scram Discharge Volume Vent and Drain Valves B 3/4.3.G B 3/4.3 REACTIVITY CONTROL BASES LCO The OPERABILITY of all SDV vent and drain valves ensures that the SDV vent and drain valves will close during a scram to contain reactor water discharged to the SDV piping. Since the vent and drain lines are provided with two valves in series, the single failure of one valve in the open position will not impair the isolation function of the system. Additionally, the valves are required to open on a scram reset to ensure that a path is available for the SDV piping to drain freely at other times.

Ai,,

APPLICABILITY In the RUN and STARTUP MODES, scram may be required; therefore, the SDV vent and drain valves must be OPERABLE. In the HOT SHUTDOWN and COLD SHUTDOWN MODES, control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod OPERABILITY during these conditions.

CTS 3/4.10, "CORE ALTERATIONS", provides requirements to ensure that core reactivity is within the capability of the control rods and to prevent criticality during refueling conditions.

ACTIONS A.1 _

If any scram di charge vent or dr in valve becomes operable the, the plant must b brought to a conition in which the L 0 does not pply. To achieve his status, the pi t must be broughto at least T SHUTDOWN ithin 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. T e allowed Compl ion Time cA 12 urs is reasonab based on opera ng experience, t reach HOT UTDOWN fro ull power conditi ns in an orderly anner and with t challenging plant systems.

SURVEILLANCE SR 4.3.G.1 and SR 4.3.G.2 REQUIREMENTS -

During normal operation, the SDV vent and drain valves should be in the open position (except when performing SR 4.3.G.2) to allow for drainage of the SDV piping. Verifying that each valve is in the open position (SR 4.3.G.1) ensures that the SDV vent and drain valves will perform their intended functions during normal operation. This SR does not require any testing or valve manipulation; rather, it involves verification that the valves are in the correct position.

The 31 day frequency is based on engineering judgment and is consistent with the procedural controls governing valve operation, which ensure correct valve positions.

Revision 2NE!)

_ _P--J- B 3/4.3-34 BmentNo18' 3/4.3-34 el",

N INSERT for Bases Page B 314.3-34 The ACTIONS are modified by a Note indicating that the ACTIONS may be independently applied for each SDV vent and drain line. This is acceptable, since the ACTIONS for each condition provide appropriate compensatory actions for each inoperable SDV line. Complying with the ACTIONS may allow for continued operation, and subsequent inoperable SDV lines are governed by subsequent ACTION entry.

When a line is isolated, the potential for an inadvertent scram due to high SDV level is Increased. During these periods, Footnote

• allows for the line to be unisolated under administrative control. This allows any accumulated water in the line to be drained, to preclude a reactor scram on SDV high level. This is acceptable since the administrative controls ensure the valve can be closed quickly, by a dedicated operator, if a scram occurs with the valve open.

A When one SDV vent or drain valve is Inoperable In one or more lines, the associated line must be isolated to contain the reactor coolant during a scram. The 7 day Completion Time is reasonable, given the level of redundancy in the lines and the low probability of a scram occurring while the valve(s) are inoperable and the line Is not isolated. The SDV is still isolable since the redundant valve in the affected line Is OPERABLE. During these periods, the single failure criterion may not be preserved, and a higher risk exists to allow reactor water out of the primary system during a scram.

B If both valves In a line are Inoperable, the line must be isolated to contain the reactor coolant during a scram. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time to Isolate the line Is based on the low probability of a scram occurring while the line is not Isolated and unlikelihood of significant CRD seal leakage.

C If any Required Action and associated Completion Time is not met, the plant must be brought to a condition In which the LCO does not apply. To achieve this status, the plant must be brought to 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 />. The allowed Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, based on operating experience, to reach HOT SHUTDOWN from full power conditions in an orderly manner and without challenging plant systems.