ML051870003

Issuance of License Amendment 217, Surveillance Frequency Improvements

ML051870003
Person / Time
Site:	Pilgrim
Issue date:	08/29/2005
From:	James Shea NRC/NRR/DLPM/LPD1
To:	Kansler M Entergy Nuclear Operations
SHea J, 415-1388, NRR/DLPM
References
TAC MC5420
Download: ML051870003 (13)

Text

August 29, 2005 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:

SURVEILLANCE FREQUENCY IMPROVEMENTS (TAC NO. MC5420)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 217 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated December 14, 2004.

The requested amendment changes Technical Specifications (TSs) to reflect surveillance frequency improvements. Specifically, the amendment removes the additional requirement to perform functional testing of the average power range monitor (APRM) and anticipated transient without scram recirculation pump trip alternate rod insertion instrumentation on each startup, when the nominally-required quarterly testing is current. Additionally, performance of the APRM High Flux heat balance calibration is modified to apply only after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at > 25%

power. Additional editorial clarifications related to TS Tables 4.2.A through 4.2.G, Note 2 and associated Table references are also included.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Sincerely,

/RA/

James J. Shea, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosures:

1. Amendment No. 217 to License No. DPR-35

2. Safety Evaluation cc w/encls: See next page

Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:

SURVEILLANCE FREQUENCY IMPROVEMENTS (TAC NO. MC5420)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 217 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated December 14, 2004.

The requested amendment changes Technical Specifications (TSs) to reflect surveillance frequency improvements. Specifically, the amendment removes the additional requirement to perform functional testing of the average power range monitor (APRM) and anticipated transient without scram recirculation pump trip alternate rod insertion instrumentation on each startup, when the nominally-required quarterly testing is current. Additionally, performance of the APRM High Flux heat balance calibration is modified to apply only after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at > 25%

power. Additional editorial clarifications related to TS Tables 4.2.A through 4.2.G, Note 2 and associated Table references are also included.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Sincerely,

/RA/

James J. Shea, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosures:

1. Amendment No. 217 to License No. DPR-35

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

DRoberts CAnderson, RI OGC PUBLIC PDI-2 R/F CRaynor JShea GHill (2) ACRS MHart LBrown EForrest FAkstulewicz Accession Number: ML051870003 *SE provided OFFICE PDI-2/PM PDI-2/LA SRXB-A/SC* IROB-A/SC OGC PDI-2/SC NAME JShea CRaynor FAkstulewicz TBoyce SBrock DRoberts DATE 7/19/05 7/19/05 3/25/05 7/2105 7/27/05 8/15/05 OFFICIAL RECORD COPY

ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 217 License No. DPR-35

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Entergy Nuclear Operations, Inc. (the licensee) dated December 14, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-35 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 217, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Darrell J. Roberts, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 29, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 217 FACILITY OPERATING LICENSE NO. DPR-35 DOCKET NO. 50-293 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4.1-5 3/4.1-5 3/4.1-6 3/4.1-6 3/4.1-7 3/4.1-7 3/4.1-8 3/4.1-8 3/4.2-36 3/4.2-36 3/4.2-39 3/4.2-39 3/4.2-41 3/4.2-41

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 217 TO FACILITY OPERATING LICENSE NO. DPR-35 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.

PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

By letter dated December 14, 2004, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a request to the Nuclear Regulatory Commission (NRC or the Commission) for changes to the Pilgrim Nuclear Power Station (PNPS) Technical Specifications (TSs).

The requested amendment changes TSs to reflect surveillance frequency improvements.

Specifically, the amendment removes the additional requirement to perform functional testing of the average power range monitor (APRM) and anticipated transient without scram recirculation pump trip (RPT) alternate rod insertion (ARI) instrumentation on each startup, when the nominally-required quarterly testing is current. Additionally, performance of the APRM High Flux heat balance calibration is modified to apply only after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at > 25% power.

Additional editorial clarifications related to TS Tables 4.2.A through 4.2.G, Note 2 and associated Table references are also included.

2.0 REGULATORY EVALUATION

The proposed changes comply with Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.62 which requires ATWS-RPT/ARI to reduce risk from ATWS events, and are consistent with the requirements of General Design Criteria 13 relating to plant instrumentation and control.

3.0 TECHNICAL EVALUATION

3.1 APRM High Flux Minimum Frequency The licensee proposes the following change:

TS Table 4.1.1, page 3/4.1-5, APRM High Flux, Minimum Frequency, delete reference to Note (7) and delete Note 7 in the Notes for Table 4.1.1, page 3/4.1-6. Table 4.1.1 presentation of Deleted Note 6 is also editorially removed.

Evaluation:

TS Table 4.1.1, Note 7, is applied to APRM High Flux, minimum frequency of every three months for the functional test and requires additional testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after entering RUN mode, if not performed within the previous seven days. The normal periodic frequency is accepted for routine operations, but Note 7 also imposes an additional performance within a brief window during, or prior to, a plant startup, often on startup critical path.

The proposed change eliminates the requirement that functional testing be performed within a brief window associated with a plant startup. This will allow the verifications to continue to be performed at their normal periodic frequency. This change is acceptable because the operability requirements for APRM instruments are unchanged and the normal periodic testing frequency provides reasonable assurance that the affected equipment is functioning properly.

If any surveillance has not been performed within its normal required interval, startup may not commence. This provides reasonable assurance that the affected equipment is functioning properly prior to, and during, startup.

Furthermore, Amendment No. 147 to the PNPS TSs was approved on March 25, 1993, which, in part, extended channel functional test intervals for the APRM channels from one month to three months. The technical basis for this change was General Electric Topical Report NEDC-30851P, Technical Specification Improvement Analysis for BWR [boiling-water reactor]

Reactor Protection Systems. The surveillance frequency assumed for these evaluations did not assume the functional testing of within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after entering RUN mode, if not performed within the previous seven days. As such, that analysis continues to bound the testing frequency after the deletion of the requirement that functional testing be performed within a brief window associated with a plant startup.

The corresponding channel functional test surveillance requirement (SR) in NUREG-1433 is SR 3.3.1.1.7 for the APRM High Flux channels. This SR requires only a normal periodic frequency of three months, and does not include a startup related situational surveillance frequency. The NRC staff has determined that the removal of the situational surveillance frequencies, as described above, will have a negligible impact on safety and, therefore, are acceptable.

3.2 APRM Start-up Calibration The licensee proposes the following change:

TS Table 4.1.2, page 3/4.1-7, APRM High Flux Output Signal, Calibration Test, Heat Balance, add a reference to Note (8) and in the Notes for Table 4.1.2, page 3/4.1-8, add Note 8 stating: Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after thermal power is

> 25% rated thermal power.

Evaluation:

The APRM channels receive input signals from the local power range monitors (LPRMs) within the reactor core to provide an indication of the power distribution and local power changes. The APRM channels average these LPRM signals to provide a continuous indication of average reactor power from a few percent to greater than rated thermal power. To ensure that the

APRMs are accurately indicating the true core average power, the APRMs are calibrated to the reactor power calculated from a heat balance, as required by TS Table 4.1.2 for the APRM High Flux channels.

However, at low reactor power levels LPRM sensitivity and the averaging of these readings does not allow for consistent or accurate representations of absolute power level readings.

Furthermore, at low power levels the plant parameter readings used to perform the heat balance are indicating at the low end of the associated scale where inherent inaccuracies introduce greater resultant uncertainties, and thus do not provide a high degree of accuracy on which to base calibrations. Additionally, having the main turbine offline and extraction steam not providing the appropriate feedwater heating (the turbine is generally placed online between 15% and 25% power) also introduces large inaccuracies. Because it is difficult to accurately maintain APRM indication of core thermal power consistent with a heat balance at these low power levels, this calibration is not required for the APRM High Flux (15%) trip. When less than 15% power, PNPS TSs currently accept that the APRM accuracy is adequately maintained by its last at-power calibration adjustment. The staff guidance in standard technical specifications (STSs) has recognized an allowance to apply the heat balance calibration only when > 25% power. As such, an exception, similar to the STSs, is proposed for the PNPS TSs to require the heat balance calibration only at $ 25% rated thermal power. TS Table 4.1.2, APRM High Flux Output Signal, Calibration Test, adds a reference to Note (8) to the Heat Balance requirement, and in the Notes for Table 4.1.2, adds Note 8 stating: Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after thermal power is > 25% rated thermal power.

At low power levels, a high degree of accuracy is unnecessary because of the large, inherent margin to fuel thermal limits. Once operating at $ 25% power, the heat balance calibration is required to have been satisfactorily performed every three days. Note 8 allows initially deferring the calibration until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reaching or exceeding 25% power. Twelve hours is based on industry operating experience and in consideration of providing a reasonable time in which to complete the SR. This allowance is consistent with STSs (NUREG-1433), SR 3.3.1.1.2, with the exception that STS SR 3.3.1.1.2 is required only once every seven days; whereas, PNPS TS SR is once every three days (more conservative). The proposed change is, therefore, acceptable.

3.3 Instrument Check Editorial Change The licensee proposes the following change:

TS Table 4.2.D, page 3/4.2-36, Instrument Check, delete reference to Note (2).

Evaluation:

Note 2 for Tables 4.2.A through 4.2.G specifies, in part: instrument checks shall be performed at least once per day during those periods when the instruments are required to be operable.

The Instrument Check column for TS Table 4.2.D requires a once/day frequency, as well as being annotated with Note 2. As such, the Note 2 reference is repetitive for specifying the required instrument check frequency. The definition of SURVEILLANCE INTERVAL encompasses the allowance that SRs are only required during those periods when the instruments are required to be operable. Therefore, eliminating reference to Note 2 in Table 4.2.D has no impact on requirements and is an editorial change only.

3.4 Start-up Functional Testing for ATWS PRT/ARI The licensee proposes the following change:

TS Table 4.2.G, page 3/4.2-39, delete each of three references to Note (2).

Evaluation:

TS Table 4.2.G, Instrument Functional Test, requirements for ATWS RPT/ARI apply both Note 1 and Note 2. Note 1 requires test intervals not less than one month nor more than three months; while Note 2 requires that Functional tests shall be performed before each startup with a required frequency not to exceed once per week. The normal periodic frequency of Note 1 is accepted for routine operations, but Note 2 also imposes an additional performance within a brief window during, or prior to, a plant startup, often on startup critical path.

The proposed changes eliminate the requirement that functional testing be performed within a brief window associated with a plant startup. This will allow the verifications to continue to be performed at their normal periodic frequency. This change is acceptable because the operability requirements for APRM and for ATWS RPT/ARI instruments are unchanged and the normal periodic testing frequency provides reasonable assurance that the affected equipment is functioning properly. If any surveillance has not been performed within its normal required interval, startup may not commence. This provides reasonable assurance that the affected equipment is functioning properly prior to and during startup.

The corresponding channel functional test SR in NUREG-1433 is SR 3.3.4.2.2 for the ATWS channels. This SR requires only a normal periodic frequency, and does not include a startup related situational surveillance frequency. Removal of the situational surveillance frequencies, such as these cases, will have a negligible impact on safety, and therefore, are acceptable.

TS Table 4.2.G Calibration requirements for ATWS RPT/ARI apply both Note 7 and Note 2.

Note 7 requires test intervals each refueling outage. Note 2 contains only calibration information for the intermediate range monitors (IRMs) and source range monitors (SRMs), and has no impact on ATWS RPT/ARI testing.

TS Table 4.2.G Instrument Check requires a once/day frequency, as well as being annotated with Note 2. The Note 2 reference is repetitive for specifying the required instrument check frequency. The definition of SURVEILLANCE INTERVAL encompasses the allowance that SRs are only required during those periods when the instruments are required to be operable.

Therefore, eliminating the reference to Note 2 in Table 4.2.G has no impact on testing requirements and reflects an editorial change only and, therefore, is acceptable.

3.5 Note 2 Editorial Change The licensee proposes the following change:

Notes for Tables 4.2.A [t]hrough 4.2.G, page 3/4.2-41, delete the first two sentences and the last sentence of Note 2, such that Note 2 reads: Calibration of IRMs and SRMs shall be performed during each startup or during controlled shutdowns with a frequency not to exceed once per week.

Evaluation:

Based on the above changes, Note 2 for Tables 4.2.A through 4.2.G remains applicable only to the calibration frequency for the neutron monitoring channels in Table 4.2.F. The first two sentences and the last sentence of Note 2 address function tests and instruments checks, not calibrations. The first sentence of Note 2 provides an exception for testing when instruments are not required to be operable or are tripped. However, the definition of SURVEILLANCE INTERVAL encompasses these exceptions in that SRs are only required during those periods when the instruments are required to be operable. Therefore, eliminating the first two sentences and the last sentence of Note 2 has no impact on the neutron monitoring calibration requirements in Table 4.2.F, and reflects an editorial change only. This change, therefore, is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (70 FR 9991). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: M. Razzaque Date: August 29, 2005 Pilgrim Nuclear Power Station

cc:

Regional Administrator, Region I One Ashburton Place U. S. Nuclear Regulatory Commission Boston, MA 02108 475 Allendale Road King of Prussia, PA 19406-1415 Director, Massachusetts Emergency Management Agency Senior Resident Inspector Attn: James Muckerheide U. S. Nuclear Regulatory Commission 400 Worcester Road Pilgrim Nuclear Power Station Framingham, MA 01702-5399 Post Office Box 867 Plymouth, MA 02360 Mr. William D. Meinert Nuclear Engineer Chairman, Board of Selectmen Massachusetts Municipal Wholesale 11 Lincoln Street Electric Company Plymouth, MA 02360 P.O. Box 426 Ludlow, MA 01056-0426 Chairman Nuclear Matters Committee Mr. Michael A. Balduzzi Town Hall Site Vice President 11 Lincoln Street Entergy Nuclear Operations, Inc.

Plymouth, MA 02360 Pilgrim Nuclear Power Station 600 Rocky Hill Road Chairman, Duxbury Board of Selectmen Plymouth, MA 02360-5508 Town Hall 878 Tremont Street Mr. Stephen J. Bethay Duxbury, MA 02332 Director, Nuclear Assessment Entergy Nuclear Operations, Inc.

Office of the Commissioner Pilgrim Nuclear Power Station Massachusetts Department of 600 Rocky Hill Road Environmental Protection Plymouth, MA 02360-5508 One Winter Street Boston, MA 02108 Mr. Bryan S. Ford Manager, Licensing Office of the Attorney General Entergy Nuclear Operations, Inc.

One Ashburton Place Pilgrim Nuclear Power Station 20th Floor 600 Rocky Hill Road Boston, MA 02108 Plymouth, MA 02360-5508 Director, Radiation Control Program Mr. David F. Tarantino Commonwealth of Massachusetts Nuclear Information Manager Executive Offices of Health and Pilgrim Nuclear Power Station Human Services 600 Rocky Hill Road 174 Portland Street Plymouth, MA 02360-5508 Boston, MA 02114 Secretary of Public Safety Executive Office of Public Safety

Pilgrim Nuclear Power Station cc:

Mr. Gary J. Taylor Chief Executive Officer Mr. John M. Fulton Entergy Operations Assistant General Counsel 1340 Echelon Parkway Entergy Nuclear Operations, Inc.

Jackson, MS 39213 440 Hamilton Avenue White Plains, NY 10601 Mr. John T. Herron Sr. VP and Chief Operating Officer Ms. Stacey Lousteau Entergy Nuclear Operations, Inc. Treasury Department 440 Hamilton Avenue Entergy Services, Inc.

White Plains, NY 10601 639 Loyola Avenue New Orleans, LA 70113 Mr. Oscar Limpias Vice President, Engineering Mr. James Sniezek Entergy Nuclear Operations, Inc. 5486 Nithsdale Drive 440 Hamilton Avenue Salisbury, MD 21801 White Plains, NY 10601 Mr. Kenneth L. Graesser Mr. Brian OGrady 38832 N. Ashley Drive Vice President, Operations Support Lake Villa, IL 60046 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Mr. Ronald Toole White Plains, NY 10601 1282 Valley of Lakes Box R-10 Mr. John F. McCann Hazelton, PA 18202 Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc. Ms. Deb Katz, Executive Director 440 Hamilton Avenue Nuclear Security Coalition White Plains, NY 10601 c/o Citizens Awareness Network Box 83 Ms. Charlene D. Faison Shelburne Falls, MA 01370 Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601