ML17262B119

Proposed Tech Specs Sections 3.2 & 3.3 Re Acid Storage Tank Boron Concentration Reduction Study

ML17262B119
Person / Time
Site:	Ginna
Issue date:	12/17/1992
From:	ROCHESTER GAS & ELECTRIC CORP.
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ML17262B116	List: ML17262B115 ML17262B117 ML17262B119 ML17262B120
References
NUDOCS 9212290176
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Text

ATTACHMENT A Revise the Technical Specification pages as follows:

Remove Insert 1-8 3 ~ 2 1

3 ~ 2 2

3 ~ 2 3

3.2-4 3 ~ 3 1

3 ~ 3 2

3 ~ 3 2a 3

3 3

3. 3-4 3.3-14

.3.3-14a 4.1-6 4.1-8 4.1-9 1-8 3 ~ 2 1

3 ~ 2 2

3.2.2a 3 ~ 2 3

3.2-4 3 ~ 3 1

3 ~ 3 2

3 ~ 3 3

3. 3-4

3. 3-14 3.3-14a 4.1-6 4.1-8 4'-9 92122'70176 921217 PDR ADOCK 05000244 P

PDR

1.18 Dose E uivalent I-131

1. 19 The dose equivalent I-131 shall be that concentration of I-131 which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134 and I-135 actually present.

The dose conversion factors used for this calculation shall be those for the adult thyroid dose via inhalation, contained in NRC Regulatory Guide 1.109 Rev.

1 October 1977.

Re ortable Event A Reportable Event shall be any of those conditions specified 1.20 in Section 50.73 to 10CFR Part 50.

Canisters Containin Consolidated Fuel Rods 1'1 Canisters containing consolidated fuel rods are stainless steel canisters containing the fuel rods of no more than two fuel assemblies which have decayed at least five years and are capable of being stored in a storage cell of the spent fuel pool.

,Shutdown Mar in Shutdown margin shall be the amount of reactivity by which the reactor is subcritical, or would be subcritical from its present condition assuming all rod cluster control assemblies (shutdown and control) are fully inserted except for the single rod cluster control assembly of highest reactivity worth which is assumed to be fully withdrawn, and assuming no changes in xenon or boron concentration.

Amendment No.12 1-8 Proposed

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3.2 Chemical and Volume Control S stem A licabilit Applies to the operational status of the chemical and volume control system.

To define those conditions of. the chemical and volume control system necessary to assure safe reactor operation.

S ecification 3.2.2 3.2.3 During cold shutdown or refueling with fuel in the reactor there shall be at least one flow path to the core for boric acid injection.

The minimum capability for boric acid injec-tion shall be equivalent to that supplied from the refueling water storage tank.

With this flow path unavailable, immediately suspend all operations involving core alterations or positive reactivity changes and return a flow path to operable status as soon as possible.

When the reactor is above cold shutdown, two boron injection flow paths shall be operable with one operable charging pump for each operable flow path, and one operable boric acid transfer pump for each operable flow path from the boric acid storage tank(s).

Xf required by specification 3.2.2

above, the Boric Acid Storage Tank(s) shall satisfy the concentration, minimum volume and solution temperature requirements of Table 3.2-1.

Amendment No.

33 302-1 Proposed

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3.2.4

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3.2.5 With only one of the required boron injection flow paths to the RCS operable, restore at least two boron injection flow paths to the RCS to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> be in at least hot shutdown and borated to a shutdown margin equivalent to at least 2.45% delta k/k at

cold, no xenon conditions.

If the requirements of 3.2.2 are not satisfied within an additional 7 days, then be in cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Whenever the RCS temperature is greater than 200'F and is being cooled by the RHR system and the over-pressure protec-tion system is not operable, at least one charging pump shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control switch is in the pull-stop posi-tion.

Amendment No.

3 '

2 Proposed

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Table 3.2-1 Boric Acid Storage Tank(s)

Minimum-Volume-Temperature-Concentration+

Concentration ppm boron Minimum Volume gale Minimum Solution Temperature

'F 4700 5000 6000 7000 8000 9000 10000 1'1000 12000 13000 14000 15000 16000 17000 18000 19000 20000 21000 22000 to less than to less than to less than to less than to less than to less than to less than to less.~than to less than to less than to less than to less than to less than to less than to less than to less than to less than to less than to less than 5000 6000 7000 8000 9000 10000 11000 12000 13000 14000 15000 16000 17000 18000 19000 20000 21000 22000 23000 8400 7800 6400 5400 4700 4200 3800 3500 3200 3000 2700 2500 2400 2200 2100 2000 1900 1800 1800 40 52 62 70 78 85 91 97 103 108 113 118 123 127 131 137 140 143 145 Amendment No.

3

~ 2 2a Proposed

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ye Basis The chemical and volume control system provides control of the reactor system boron inventory.+

This is normally accomplished by using one or more charging pumps in series with one of the two boric acid transfer pumps.

Above cold shutdown conditions, a minimum of two of four boron injection flowpaths are required to insure single functional capability-in the event that an assumed single active failure renders one of the flow paths inoperable.

The boration volume available through any flow path is sufficient to provide the required shutdown margin at cold conditions from any expected operating condition and to compensate for shrinkage of the primary coolant from the cooldown process.

The maximum volume requi'rement 'is ~associated with boration from just critical, hot zero

power, peak xenon with control rods at the insertion limit, to cold shutdown with single reactor coolant loop operation.

This requires 26,000+ gallons of 2000 ppm borated water from the refueling water storage tank or the concentrations and volumes of borated water specified in Table 3.2-1 from the boric acid storage tanks.

Two boric acid storage tanks are available.

One of the two tanks may be out of service provided the required volume of" boric acid is available to the operable flow paths.

(>)

Above cold

shutdown, two of the following four flow paths must be operable with one operable charging pump for each operable flow path, and one operable boric acid transfer pump for each operable flow path from the boric acid storage tanks.

(1)

Boric acid storage tanks via one boric acid transfer pump through the normal makeup (FCV 110A) flow path to -the suction of the charging pumps.

(2)

Boric acid, storage tanks via one boric acid transfer pump through the emergency boration flow path (MOV 350) to the suction of the charging pumps.

Refueling water storage tank via gravity feed through AOV 112B to the suction of the charging pumps.

Amendment No.

24 3 '

3 Proposed

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References:

UFSAR Section 9.3.4.2 (1)

(2)

RG&E Design Analysis DA-NS-92-133-00 "BAST Boron Concentration Reduction Technical Specification Values" dated Dec.

14, 1992 (3)

L.D. White, Jr. letter A.

Schwencer,

NRC,

Subject:

Reac-tor Vessel Overpressurization, dated February 24, 1977 Amendment No.

3.2-4 Proposed (4)

Refueling water storage tank via gravity feed through manual bypass valve 358 to the suction of the charging pumps.

Available flow paths from the charging pumps to the reactor coolant system include the following:

(1)

Charging flow path through AOV 392A to the RCS Loop B hot leg.

(2)

Charging flow path through AOV 294 to the RCS Loop B cold leg.

(3)

Seal injection flow path to the reactor coolant pumps.

The rate

.of,.boric,acid injection.,must

. be.sufficient,to...offset the maximum addition of positive reactivity from the decay of xenon after a trip from full power.

This can be accomplished through the operation of one charging pump at minimum speed with suction from the refueling water storage tank.

Also the time required for boric acid injection allows for the local alignment of manual valves to provide the necessary flow paths.

The quantity of boric acid specified in Table 3.2-1 for each concentra-tion is sufficient at any time in core life to borate the reactor coolant to'he required cold shutdown concentration and provide makeup to maintain RCS inventory during the cooldown.

The temperature limits specified on Table 3.2-1 are required to maintain solution solubility at the upper concentration in each range.

The temperatures listed on Table 3.2-1 are taken from Reference (4).

An arbitrary 5'F is added to the Reference (4) for margin.

Heat tracing may be used to maintain solution temperature at or above the Table 3.2-1 limits.

If the solution temperature of either the flow path or the borated water source is not maintained at or above the minimum temperature specified, the affected flow path must be declared inoperable and the appropriate actions specified in 3.2.4 followed.

Placing a charging pump in pull-stop whenever the reactor coolant system temperature is

>200'F and is being cooled by RHR without the over-pressure protection system operable will prevent inadvertent overpres-surization of the RHR system should letdown be terminated.@

(4)

Kerr-McGee Chemical Corp. Bulletin 0151 "Boric Acid Techni-cal Grades" dated 5/84 Amendment No.

3.2-5 Proposed

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Emer enc Core Coolin S stem Auxiliar Coolin S stems Air Recirculation Fan Coolers Containment S ra and Charcoal HEPA Filters To define those conditions for operation that are neces-sary:(1) to remove decay heat from the core in emergency or normal shutdown situations, (2) to remove heat from contain-ment in normal operating and emergency situations, (3) to remove airborne iodine from the containment atmosphere following a postulated Design Basis

Accident, and (4) to minimize containment leakage to the environment subsequent to a Design Basis Accident.

S ecification 3.3.1 Safet In'ection and Residual Heat Removal S stems 3.3.1.1 The reactor shall not be taken above the mode indicated unless the following conditions are met:

a ~

b.

Above cold. shutdown, the refueling water storage tank contains not less than 300,000 gallons of water, with a boron concentration of at least 2000 ppm.

Above a reactor coolant system pressure of 1600 psig, except during performance of RCS hydro

test, each accumulator is pressurized to at least 700 psig with an indicated level of at least 504 and a maximum of 82% with a boron concentration of at least 1800 ppm.'

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At or above a reactor coolant system temperature of 350'F, three safety injection pumps are'perable.

Amendment No.

24 3 '

1 Proposed

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At or above an RCS temperature of 350 F, two residual heat removal pumps are operable.

At or above an RCS temperature of 350'F, two residual heat removal heat exchangers are operable.

At: the conditions required.in a through

.e.above, all valves, interlocks and piping associated with the above components which are required to function during accident conditions are operable.

At or above an RCS temperature of 350 F, A.C. power shall be removed from the following valves with the valves in the'pen position: safety injection cold leg injection valves 878B and D.

A.C.

power shall be removed from safety injection hot leg injection valves 878A and C with the valves closed.

D.C. control power shall be removed from refueling water storage tank delivery valves

896A, 896B and 856 with the valves open.

At or above an RCS temperature of 350'F, check valves 853A, 853B, 867A, 867B,

878G, and 878J shall be operable with less than 5.0 gpm leakage each.

The leakage requirements of Technical Specification 3.1.5.2.1 are still applicable.

Above a reactor coolant system pressure of 1600 psig, except during performance of RCS hydro test, A.C. power) shall be removed from accumulator isolation valves 841 and 865 with the valves open.

At or above an RCS temperature of 350',

A.C.

power shall be removed from Safety Injection suction valves 825A and B with the valves in the open position, and from valves

826A, B,

C, D with the valves in the closed position.

Amendment No.

42 3 ~ 3 2

Proposed

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3.3.1.2 If the conditions of 3.3.1.1a are not met, then satisfy the

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condition 'within 1'hour or be at hot shutdown in the next 6

hours and at least cold shutdown within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

3.3.1.3 The requirements of 3.3.1.1b and 3.3.1.1i may be modified to allow one accumulator to be inoperable or isolated for up to one hour.

If the accumulator is not operable or is still isolated after one hour, the reactor shall be placed in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below a RCS pressure of 1600 psig within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3.3.1.4 The requirements of 3.3.1.1c may be modified to allow one safety injection pump to be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the pump is not operable after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the reactor shall be placed in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and below a

RCS temperature less than 350'F within an additional 6

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hours.

3.3.1.5 The requirements of 3.3.1.1d through h.

may be modified to allow components 'to be inoperable at any one time.

More than one component may be inoperable at any one time provided that one train of the ECCS is operable.

If the requirements of 3.3.1.1d through h. are not satisfied within the time period specified below, the reactor shall be placed in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350 F in an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

a.

One residual heat removal pump may be out of service provided the pump is restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Amendment No.

24 3 ~ 3 3

Proposed

e 4

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4

3.3. 1. 6 b.

One residual heat removal heat exchanger may be out of service for a period of no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

c.

Any valve, interlock, or piping -required for the func-tioning of one safety injection train and/or one low head safety injection train (RHR) may be inoperable provided repairs are completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (except as speci-fied in e. below).

d.

Power may be restored to any valve referenced in 3.3.1.1g for the purposes of valve testing provided no more than

=-": one. such valve has power restored and provided testing is completed and power removed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

e.

Those check valves specified in 3.3.1:1h may be inopera-ble (greater than 5.0 gpm leakage) provided the inline MOVs are de-energized closed and repairs are completed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Deleted Amendment No. 24, 33 3.3-4 Proposed

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that the mass addition from the inadvertent operation of safety injection will not result in RHR system pressure exceeding design limits.

The limitation on no safety injection pumps operable and the discharge lines isolated when overpressure protection is provided by the pressur-izer PORV's removes mass.injection from inadvertent safety injection-as an event for which this. configuration of overpressure protection must be designed to protect.

Inoperability of a safety injection pump may be verified from the main control board with the pump control switch in pull stop, or the pump breaker in the test racked out position such that the pump could not start from an inadvertent safety injection signal.

Isolation of a

safety injection pump discharge path to the RCS may be verified from the main control board by the discharge MOV switch position indicating closed, or the discharge valve closed with A.C;.power

removed, or a manual discharge path isolation valve closed such that operation of the associated safety injection pump would not result in mass injection to the RCS.

High concentration boric acid is not needed to mitigate the consequences of a design basis accident.

Reference (10) demonstrates that the design basis accidents can be mitigated by safety injection flow of RWST concentration.

Therefore, SI pump suction is taken from the RWST.

Requiring that the safety injection suction valves (825A and B,

826A, B,

C and D) are aligned with A.C.

power removed insures that the safety injection system would not be exposed to high concentration boric acid and the assumptions of the accident analysis are satisfied.

Amendment No.

48 3.3-14 Proposed

References (1)

Deleted (2)

UFSAR Section 6.3.3.1 (3)

UFSAR Section 6.2.2.1 (4)

UFSAR Section 15.6.4.3 (5)

UFSAR Section 9.2.2.4 (6)

UFSAR Section 9.2.2.4 (7)

Deleted (8)

UFSAR Section 9.2.1.2 (9)

UFSAR Section 6.2.1.1 (Containment Integrity) and UFSAR Section 6.4 (CR Emergency Air Treatment)

(10) Westinghouse

Report, "R.E. Ginna Boric Acid Storage Tank Boron Concentration Reduction Study" dated Nov.

1992 by C.J.

McHugh and J.J.

Spryshak Amendment No.

48 3.3.14a Proposed

Channel Descri tion TABLE 4.1-1 (Continued)

Check Calibrate Test Remarks 10.

Rod Position Bank Counters Steam Generator Level S(1,2)

N.A.

N.A. 1) With rod position indication

2) Log rod position indications each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when rod deviation monitor is out of service

12. Charging Flow N.A.

N.A.

13.

14.

Residual Heat Removal Pump Flow Boric Acid Storage Tank Level N.A.

D N.A.

N.A.

Note 4

15. Refueling Water Storage Tank Level N.A.

N.A.

16. Volume Control Tank Level N.A.

N.A.

17. Reactor Containment Pressure D

M(1)

1) Isolation Valve signal 18.

19.

Radiation Monitoring System Boric Acid Control D

N.A.

N.A.

Area Monitors R1 to R9, System Monitor R17 20 'ontainment Drain Sump Level N.A.

N.A.

21 ~ Valve Temperature Interlocks N.A.

N. A.

22.

23

'ump-Valve Interlock Turbine.Trip Set-Point N.A.

N.A.

N.A.

M(1)

1) Block Trip 24 'ccumulator Level and Pressure N.A.

Amendment No.

22

4. 1-6 Proposed

Channel Descri tion TABLE 4.1-1 (Continued)

Check Calibrate Test Remarks 39.

Reactor Trip Breakers N.A N.A.

M Function test Includes independent testing of both undervoltage and shunt trip attachment of reactor trip breakers.

Each of the two reactor trip breakers will be tested on alternate months.

40.

Manual Trip Reactor N.A.

N.A.

R Includes independent testing'of both undervoltage and shunt trip circ-uits.

The test shall also verify the operability of the bypass break-er.

41a.

Reactor Trip Bypass Breaker N.A.

41.b Reactor Trip Bypass Breaker N.A.

N.A.

N.A.

M Using test switches in the reactor protection rack manually trip the reactor trip bypass breaker using the shunt trip coil.

R Automatically trip the undervoltage trip attachment.

NOTE 1:

Logic trains will be tested on alternate months corresponding to the reactor trip breaker testing.

Monthly logic testing will verify the operability of all sets of reactor trip logic actuating contacts on that train (See Note 3).

Refueling shutdown testing will verify the operability of all sets of reactor trip actuating contacts on both trains.

In testing, operation of one set of contacts willresult in a reactor trip breaker tripp the operation of all other sets of contacts will be verified by the use of indication circuitry.

NOTE 2 NOTE 3 Testing shall be performed monthly, unless the reactor trip breakers are open or shall be performed prior to startup if testing has not bee performed within the last 30 days.

The source range trip logic may be excluded from monthly testing provided it is tested within 30 days prior to startup.

NOTE 4:

When BAST is required to be operable.

Amendment No.

34 4.1-7a Proposed

TABLE 4.1-2 MINIMUM FRE UENCIES FOR E UIPMENT AND SAMPLING TESTS 1.

Reactor Coolant Chemistry Samples 2.

Reactor Coolant Boron Test Chloride and Fluoride Oxygen Boron Concentration FrecrFue~c r

3 times/week and at least every third day 5 times/week and at least every second day except when below 2504F Weekly 3.

Refueling Water Storage Tank Water Sample Boron Concentration Weekly 4 ~

Boric Acid Storage Boron Concentration Tank Twice/Week'"

5.

Control Rods 6a. Full Length Control Rod 6b. Full Length Control Rod 7.

Pressurizer Safety Valves 8.

Main Steam Safety Valves 9.

Containment Isolation Trip

10. Refueling System Interlocks Rod drop times of all full length rods Move any rod not fully inserted a suffi.cient number of steps in any one direction to cause a

change of position as indicated by the rod position indication system Move each rod through its full length to verify that the rod position indication system transitions occur Set point Set point Functioning Functioning After vessel head removal and at least once per 18 months (1)

Monthly Each Refueling Shutdown Each Refueling Shutdown Each Refueling Shutdown Each Refueling Shutdown Prior to Refueling Operations Amendment No.

22 4 ~ 1-8 Proposed

C i(

1.

Service Water System 12.

Fire Protection Pump and Power Supply 13.

Spray Additive Tank 14.

Accumulator 15.

Primary System Leakage Test Functioning Functioning NaOH Concent Boron Concentration Evaluate PreqFuenc Each Refueling Shutdown Monthly Monthly Bi-Monthly Daily 17.

Spent Fuel Pit 18.

Secondary Coolant Samples Boron Concentration Gross Activity 16.

Diesel Fuel Supply Fuel Inventory Daily Monthly 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (2)

(3) 19.

Circulating Water Calibrate Flood Protection Equipment Each Refueling Shutdown otes:

Also required for specifically affected individual rods following any maintenance on or modification to the control rod drive system which could affect the drop time of those specific rods.

(2)

(3)

Not required during a cold or refueling shutdown.

An isotopic analysis for I-131 equivalent activity is required at least monthly whenever the gross activity determination indicates iodine concentration greater than 10>

of the allowable limit but only once per 6 months whenever the gross activity determination indicates iodine concentration below 10% of the allowable limit.

(4)

When BAST is required to be operable.

Amendment No.

22 4.1-9 Proposed

e q14 44( j jl

ATTACHMENT B The boric acid storage tanks (BASTs) are part of the Chemical and Volume Control System (CVCS) and provide-a source of concentrated boric acid to the safety injection (SI) system.

Currently a concentration of 20,000 ppm boron is maintained in the BASTs.

This requires heat tracing to prevent boron precipitation.

Maintaining the high boron concentration and operability of the heat tracing is time consuming and costly. If the boron concentration in the BASTs could be reduced from 20,000 ppm to 2,000 ppm the heat tracing

-;,.- could be'removed=.resulting in reduced maintenance requirements and operation-al flexibility.

e affect of a reduction in boron concentration on the accident analysis was 0evaluated.

The limiting accident is the steamline break.

Because the steamline break effects the core and the containment responses, these were considered in the boron concentration reduction analysis.

Attachment C

documents the analyses which support a reduction in the boron concentration to 2,000 ppm.

Therefore, for licensing basis accident analyses a minimum boron concentration of 2,000 ppm is sufficient.

The SI pumps will take suction from the refueling water storage tank (RWST).

This will be accomplished by removing A.C. power from Safety Injection suction valves 825A and B with the values in the open position and from valves

826A, B,

C, and D

with the valves in the closed position.

The BASTs will be used in conjunction with the CVCS for boron concentration changes and will serve as a

source of concentrated boric acid for maintenance of long term sub-iticality.

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i Technical Specifications on BAST volume and boron concentration ensure that

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two flow paths and associated sources of borated water are available to intain long term subcriticality.

The specified volume is sufficient to provide.reactivity to cold shutdown plus volume to compensate for shrinkage of the primary coolant.

The.minimum temperature

" requirement 'provides protection against boron precipitation.

.Because of the proximity, of the I

. temperatures., to the ambient,auxiliary.,building.temperature Technical Specifications for heat tracing are not necessary.

Should the solution temperature drop below the specified value the flow path or the borated water source must be called inoperable and appropriate actions specified in specification 3.2.4 taken.

Consideration was given to the concern that decreasing the boron concentration in the BASTs could affect emergency boration.

A reduction in

~

e concentration reduces the rate at which reactivity can be added to the primary system.

The design bases for the boration flow is that it be sufficient to follow the burnout rate of. Xenon.

Calculations show that the normal and emergency boration flow path from the BAST and either flow path from the RWST are capable of meeting this requirement.

Section 9.3.4.1.2 of the UFSAR states that boric acid can be injected to shutdown the reactor in 15 minutes.

The 15 minute value is not a design basis requirement, but rather a statement of system capability. If the BASTs are not the chosen path (Specification 3.2.2) boration would be from the RWST through a charging pump to the RCS.

Charging at the maximum rate of 60 gpm

gpm, for the typical core at beginning of life would require approximately 81 min.

o go from full power to shutdown.

This increase in time is considered ceptable because there is no requirement on boration

time, just a

requirement on the rate of negative reactivity addition.

The requirement is

~4 0

I

. that, the rate of reactivity insertion must be greater than the reactivity added by Xenon decay.

This requirement is satisfied by minimum charging flow th 2000 ppm boron.

-Existing Specification 3.2.1 will be complemented by.- the addition of a

proposed action statement, i.e.,

3.2.1.1.

The proposed action 3.2.1.1.e ensures that no operations involving, core alterations or positive reactivity changes are being performed with no flow path to the core for -boric acid injection during cold shutdown or refueling.

This proposed action is H

consistent with the action described in Specification 3.1.2.1 of NUREG-0452, Revision 4.

(Ref.

a)

Proposed Item 1.21 under Section 1.0 of Ginna Technical Specifications will be included to address the use of the term "Shutdown Margin".

This proposed finition is consistent with NUREG-0452; however, it has been modified to be site specific.

This proposed addition is considered to be administrative in nature inasmuch as it promotes clarity.

Proposed changes to Specifications 3.3.1.1c is consistent with standard practice at Ginna relative to performance of an RCS hydro test.

Specification Section 3.5.1 of NUREG-0452, requires accumulators to be operable at or above 350'F and 1000 psig.

Essentially, the accumulator must be isolated below this pressure.

At Ginna the RCS hydro test is performed below 350'F.

Therefore, proposed changes to delete RCS hydro test exception to Specification 3.3.1.lc is considered to be consistent with NUREG-0452 and current practices at Ginna.

e proposed amendment will remove the 1600 psig pressure related operability requirement associated with the availability of the safety injection pumps to

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Specifically, Technical Specifica-tions 3.3.1.1c and 3.3.1.4 currently establishes availability or operability

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quirements.in terms of a pressure and temperature relationship of 1600 psig an'd '350'F.

Proposed changes to Ginna Specification 3.3.1.1c are consistent with NUREG-0452 Specification 3.5.2b.

Proposed changes to Ginna Specification 3.3.1.4 complement Specification 3.3.1.1c and therefore promotes consistency.

Nith respect to existing Specification 3.3.1.1c, operability requirements are established "at or above a

reactor coolant system (RCS) pressure and

,~'temperature'of<-1600- psig and 350'F."

This requirement is ambiguous for mode entry considerations, inasmuch as

1) the statement "at a RCS pressure and temperature of 1600 psig and 350'F cannot be established during normal eration (1600 psig requires an RCS temperature of approximately 450 F) and

)

the statement "above a

RCS pressure and temperature of 1600 psig and'50'F" alleviates the importance of the temperature related operability requirement.

The proposed change to retain only the 350 F temperature requirement is consistent with NUREG-0452.

Action statement 3.3.1.2 will be revised to provide a reasonable allowable outage time (AOT) to restore parameters to an operable status.

Specification 3.5.5 of NUREG-0452, provides an.action statement which allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for restoration of parameters in question.

Existing Specification 3.2.3d will be renumbered to be proposed Specification

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3.2.4.

Proposed changes to proposed Specification 3.2.4 will include:

Increase the allowable outage time (AOT) from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 2) a provision to borate to a concentration that maintains a shutdown margin

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, equivalent to 2.454 delta k/k at cold shutdown conditions with no xenon.

oposed AOT changes to proposed Specification 3.2.4 are consistent with NUREG-0452, action statement 3.1.2.2.

The proposed requirement to borate to a shutdown margin equivalent to at least 2.45% delta k/k with no.xenon at cold shutdown conditions compensates for long term xenon decay and temperature reduction.

Figure;3;10.2:of-Ginna.Technical"Specifications was used to determine the required shutdown margin for a single loop operating at end-of-life (EOL) conditions, i.e., 2.454 delta k/k.

Therefore, by requiring a boron concentration equivalent to a 2.454 delta k/k at cold conditions (68 F),

no xenon, adequate shutdown margin is maintained for all modes of

<<operation down to--and including cold shutdown.

This proposed change is also consistent with NUREG-0452, action statement 3.1.2.2.

Existing Technical Specification 3.2.4 has been renumbered to 3.2.5.

able 1 depicts the specific Technical Specification change.

Attachment E

provides a

comparison between the existing and proposed Technical Specification.

In accordance with 10CFR50.91, this change to the Technical Specification has been evaluated to determine if the operation of the facility in accordance with the proposed amendment would:

1.

involve a significant increase in the probability or consequences-of an accident previously evaluated; or 2.

create the possibility of a new or different kind of accident from any

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accident previously evaluated; or

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e reduction in the boron concentration of the BASTs will not affect the

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probability of an accident because reducing the concentration will not cause P

a design basis accident to occur.

The consequences of previously evaluated accidents has been evaluated in Attachment C.

Since all criteria have been satisfied the consequences of any accident have.not'increased.-

The change to Technical Specifications allows the injection of 2000 ppm boric acid vs.

124.

SZ pump suction would be from the RWST.

This eliminates the necessity of switching from the BASTs to the RWST, reducing the complexity of

.the operation.

Since,.the pumps remain connected to the RWST throughout the injection phase there is no possibility of a

new or different kind of accident.

he reduction in the concentration of boric acid injected into the primary system for accident mitigation has been analyzed in Attachment C.

Attachment C concludes that all applicable criteria are satisfied.

Since all criteria are satisfied there is no reduction in the margin of safety.

The proposed change to include an action statement when no flow paths are available during core alterations or positive reactivity changes minimizes the potential for reactivity excursions without compensating measures available for reactivity control.

This proposed change is also consistent with the action described in NUREG-0452.

he proposed change Specification 3.3.1.2 to include a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> completion to store the RWST water volume is consistent with NUREG-0452 and considered reasonable.

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~ proposed increase in the allowable outage times (AOTs) from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is based on the low probability of a Design Basis Accident occurring

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ring this period. of inoperability and is consistent with NUREG-0452.

The NRC'valuation, described in an NRC memorandum to V. Stello, Jr.

from R. L.

Baer "Recommended Interim Revisions to LCOs for ECCS Components,"

December 1,

1975, concluded that an AOT of 72 -hours has only a slight impact on the system. average unreliability. and is considered negligible.

.The..proposed change to borate to a shutdown margin of at least 2.45~~ delta. k/k with no xenon at cold shutdown conditions compensates for long term xenon decay and temperature reduction.

,- Therefore, Rochester Gas.and Electric submits that the issues associated with this Amendment request are outside the criteria of 10CFR50.91; and a

no significant hazards finding is warranted.

eference (a):

NUREG-0452, Rev.

4 "Standard Technical Specifications for Westinghouse Pressurized Water Reactors"

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TABLE PROPOSED PAGE 1-8 3

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3 '-1 3.2-1 and 3

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CHANGE Provided a definition for the term "Shutdown Margin".

Provided additional wording relative to reactor operating modes, i.e., cold shutdown or refueling.

Provided action statement to complement Specification 3.2.1.

Changed Specification 3.2.2 and 3.2.3 to new Specification 3.2.2, 3.2.3 and 3.2.4.

Renumbered existing Specification 3.2.3d to proposed Specification 3.2.4.

Proposed Specification 3.2.4 change includes 1) an increase of the allowable outage time (AOT) from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 2) a provision to borate to a concentration that maintains a shutdown, margin equivalent to delta k/k at cold shutdown conditions with no xenon.

REASON FOR CHANGE Definition provided to avoid repeating and/or misinterpreting information relative to the term.

To clearly define operational status relative to limiting condition for. operation..

The proposed action statement 3.2.1.1 ensures that no operations involving core alterations or positive reactivity changes are being performed with no flow path to the core for boric acid.

This proposed action is consistent with the action described in Specification 3.1.2.1 of NUREG-0452, Revision 4.

BASTs no longer used as source for Safety Injection.

Administrative change Proposed AOT change are consistent with NUREG-0452, Revision 4.

Further, additional provision to borate to a shutdown margin equivalent to at least 2.45% delta k/k with no xenon at cold shutdown conditions compensates for long term xenon decay and temperature reduction.

Therefore, by requiring.a boron concentration equivalent to a 2.45% delta k/k at cold conditions (68'F),

no xenon, adequate shutdown margin is maintained for all modes of operation down to and including cold shutdown.

This proposed change is also consistent with NUREG-0452, Revision 4, action statement 3.1.2.2.

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I PROPOSED PAGE 3 ~ 2 2

3.2-2a 3.2-3 and 3.2-4 3.2-4 3.2-5 3 ~ 3 1

CHANGE Existing Specification 3.2.4 will be renumbered to be 3.2.5.

New Table 3.2-1 New Basis References corrected.

Additional reference

included, Specification 3.3.1.1b RCS hydro test exception added.

Specification 3.3.1.1c operability requirement of 1600.psig and RCS hydro test exception will be deleted.

REASON FOR CHANGE Administrative change Requirements for operability of BASTs.

Describe basis for BASTs.

Administrative change.

Administrative The proposed changes will ensure consistency with standard practice at Ginna relative to performance of an RCS hydro test.

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Section 3.3.1.1i RCS hydro test exception added.

The proposed change will ensure consistency with standard practice at Ginna relative to performance of RCS hydro test.

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3.3-4 3.3-14 Section 3.3.1.1j replaced with requirements for Safety Injection suction valves.

Existing Specification 3.3.1.2 revised to include an additional 1

hour allowance.

Existing Specification 3.3.1.4 will be revised to delete 1600 psig inoperability condition.

Specification 3.3.1.6 d l ted Added Basis for Safety Injection suction source.

BASTs no longer used as source for Safety Injection.

Proposed change provides a

reasonable outage time (AOT) to restore parameters to an operable status.

Specification 3.5.5 of NUREG-0452, Revision 4 provides an actions statement which allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for restoration of parameters, in question.

To ensure consistency with proposed Specification 3.3.1.1c.

BASTs no longer used as source for Safety Injection.

BASTs no longer used as source for Safety Injection.

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PROPOSED PAGE 3.3-14a 4: 1-6 4.1-7a, 4.1-8 and 4.1-9 4.1-8 and 4.1-9 CHANGE Revised Reference 10.

Revised remarks to-Note 4

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Added Note 4.

Removed UFSAR References.

REASON FOR CHANGE New Containment Integrity Analysis.

Instrument only needed when tank is operable.

Instrument only needed when tank is operable.

Administrative change consistency with other tables.

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