ML20003D185

Proposed Tech Spec Changes Per TMI Category a Lessons Learned (NUREG-0578).New Provisions Added for Operation & Surveillance Requirements for Safety & Relief Valve Positioning Monitoring Instrumentation.Table 6.2-1 Revised

ML20003D185
Person / Time
Site:	Pilgrim
Issue date:	03/16/1981
From:	BOSTON EDISON CO.
To:
Shared Package
ML20003D183	List: ML20003D182 ML20003D185
References
RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 8103190533
Download: ML20003D185 (6)

Text

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g ATTACINENT A Proposed Technical Specification changes Concerning TMI Cat. "A" Lessons Learned

. Proposed Change Reference is made to Pilgrim Station Operating License No. DPR-35 Appendix A.

New provisions would be added to provide operation and surveillance requirements for safety and relief valve position monitoring instrumentation, and Table 6.2-1 would be revised to include the shift technical advisor into the minimum shift crew composition. (Affected Page Nr,s. - 58, 59,66, 73, 211)

Reason For Change NUREG 0578 Section 2.1.3.a requires that the reactor system relief and safety valves be provided with a positive indication in the control room, derived from a reliable valve position detection device or a reliable indication of flow in the discharge pipe. To accomplish this, all spring safety and safety / relief valves at Pilgrim Station were equipped with acoustic monitoring devices to in-sure that operations personnel have a positive indication of flow in the discharge line or tail pipe assembly. Additional back-up indication is provided by tempera-ture monitoring with thermocouples installed on each discharge or tail pipe.

These proposed changes provide for instrumentation tables, operation and surveillance requirements relative to the above installed equipment.

Section 2.2.1.b requires the addition to each shift, a qualified person with a bachelor's degree or equivalent in science or engineering discipline with specific training in the plant response to off-normal events and in accident analysis of the plant. As a result, the shift technical advisor position was impicnented and this change incorporates that position into the technical specifications.

Safety Considerations Item 2.1.3.a- Although not required for the safe operation of the plant, these modifications provide the operator with an added parameter of diagnostic aid in determining valve position. The installation of these modifications has not diminished the ability of any safety system to perform its required safety func-tion nor increased the probability of occurrence or consequences of an accident or malfunction of equipment important to safety.

Item 2.2.1.b-- Since this proposed change af fects only the Adninistrative Control Section of the Technical Specifications there are no safety-related changes involved.

These changes have been reviewed'by the Nuclear Safety Review and Audit Committee and have been reviewed and approved by the Operations Review Committee Pursuant to 10 CFR 170.22 footnote 2 which exempts license amendment fees resulting from Commission Orders, Boston Edison Company proposes that no fee is required, as these changes are part of our impicmentation of the Commission's January 2, 1980 Confirmatory Order (NUREG 0578).

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PNPS TABLE 3.2.F SURVEILLANCE INSTRUMENTATION Minimum # of Type Indication Operable Instrument- and Range Notes Channels Instrument # Instrument 2 640-29A & B Reactor Water Level Indicator 0-60" (1) (2) (3)

-2 640-25A & B Reactor Pressure Indicator 0-1200 psig (1) (2) (3) 2' TRU-9044 Drywell Pressure Recorder 0-80 psia (1) (2) (3)

TRU-9045 2 TRU-9044 Drywell Temperature Recorder, Indicator (1) (2) (3)

TI-9019 0-400 F 2 TRU-9045 Suppression Chamber Air Recorder, Indicator (1) (2) (3)

TI-9018 Temperature 0-4000F 2 LR-5038 Suppression Chamber Water Level Recorder 0-32" (1) (2) (3)

LR-5049 Control Rod Position 28 Volt Indicating )

1- NA Lights )

) (1) (2) (3) (4)

NA Neutron Monitoring SRM, IRM, LPRM )

1 O to 100% power )

'2 TI-5047 Suppression Chamber Water Indicator 50-150 F (1) (2) (3)

TI-5048 Temperature PI-5021 Drywell/ Torus Diff. Pressure Indicator .25-*3.0 psid (1) (2) (3) (4) 1 Drywell Pressure Indicator 1

(IPI-5067A .25-*3.0 psig [(1)

Indica: cr -1.0-*+2.0 ) (2) (3) (4)

PI-5067B Torus Pressure PsiR a) Primary Safety / Relief Valve Position a) Acoustic monitor (5) 1/ Valve b) Thermocouple or (5) Indi cato r b) Backup Safety Valve Position Indicator a) Acoustic monitor ( 5) 1/ Valve a) Primary b) Thermocouple or (5) b) Backup

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l NOTES FOR TABLE 3.2.F (1) From and after the date that one of these parameters is reduced to one indication, continued operation is permissible during the succeeding thirty days unless such instrumentation is sooner made operable.

• (2), From and after the date that one of these parameters is not indi-cated in the control room, continued operation is permissible during the succeeding seven days unless such instrumentation is sooner made operable.

(3) If the requirements of notes (1) and (2) cannot be met, an orderly shutdown shall be initiated and the reactor shall be in a Cold Shutdown Condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(4) These surveillance instruments are considered to be redundant to each other.

(5) At a minimum, the primary ir back-up parameters shall be operable for each valve when the valves are required to be operable. With both prinary and backup instrument channels inoperable either return one (1) channel to operable status within 31 days or be in a shutdown code within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The following instruments are associated with the safety / relief & safety

. valves:

Prima ry Secondary y,7y, Acoustic Monitor Tail Pipe Temperature Therncouple 203-3A ZT-203-3A TE6271-B 203-3B ZT-20 3-3B TE6272-B 203-3C ZT -203-3C TE6273-B 203-3D- ZT-20 3-3D TE6276-B 203-4A ZT-203-4A TE6274-B 203-4B ZT-20 3-4B TE6275-B O

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. - .. . n. . . , ..- . . .

PNPS TABLE 4.2.F MINIMUM TEST AND CALIBRATION FREQUENCY FOR SURVEILLANCE INSTRUMENTATION Instrument Channel Calibration Frequency Instrument Check 1)' Reactor Level Once/6 months Each Shift

2) Reactor Pressure Once/6 months Each Shift

3) Drywell Pressure Once/6 months Each Shift

4) Drywell Temperature- Once/6 months Each Shift

5) Suppression Chamber Temperature Once/6 months Each Shift

6) Suppression Chamber Water Level Once/6 months Each Shift

7) Control Rod Position NA Each Shift

8) . Neutron Monitoring (2) Each Shift

9) Drywell/ Torus Differential Pressure Once/6 months Each Shift

'10) Drywell Pressure 'Once/6 months Each Shift Torus Pressure Once/6 months i

11) Safety / Relief Valve Each refueling once each day Position Indicator outage (Primary / Secondary)

S 12) Safety Valve Position Each refueling Once each day Indicator (Primary / outage Secondary)

,,..i 3.2 8ASES (Cont'd)

For most parameters monitored, as listed in Table 3.2.F, there are two (2) channels of instrumentation. By comparing readings between these two (2) channels, a near continuous surveillance of instrument performance is available. Meaningful deviation in comparative readings of these instru-ments will initiate an early recalibration, thereby maintaining the quality of the instrument readings.

The Safety - Safety / Relief Valve position indication instrumentation provides the operator with information on selected plant parameters to monitor and assess these variables during and following an accident.

The recirculation pump trip / alternate rod insertion systems are consistent with the "Monticello RPT/AR1" design described in NEDO 25016 (Reference 1) as referenced by the NRC as an acceptable design (Reference 2) for RPT. Reference The 1 provides both pump trip is system provided descriptions and perforr.ance analyses. -

to minimize reactor pressure in the highly unlikely event of a plant transient coincident with the failure of all control rods to scram. The rapid flow reduction increases core widing providing a High pressure sensors and low water level negative reactivity feedback.The recirculation pump trip is only sensors initiate the trip.

required at high reactor power levels, where the safety / relief valves have insufficient capacity to relieve the steamRequiring which continues the to be generated in this unlikely postulated event.

trip to be operable only when in the RUN code is therefore conserva-tive. The low water level trip function includes a time delay of nine (9) seconds 1 one (1) second to avoid increasing the consequences of a postulated LOCA. This delay has an insignificant effect on ATVS consequences.

Alternate rod insertion utilizes the same initiation logic and l

functions as RPT and provides a diverse means of initiating a reactof s, cram. ARI uses sensor diverse from the reactor protection system to depressurize the scram pi, lot air header, which in turn causes all control rods to be inserted.

References

1. NEDO-25016 " Evaluation of Anticipated Transients Without Scram for the Monticello Nuclear Generating Plant," September 1976.

2. NUREG 0460, Volume 3, December 1978.

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l P00RORGNAL L

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.;- c PILGRIM NUCLEAR POWER STATION MINIMLH SHIFT CREW COMPOSITION TECHNICAL SPECIFICATION TABLE 6.2-1 STATION CONDITION ,

• CREW MINIMLM NUMBER ON DLTl OPERATING Licensed Senior Reactor Operator 1 Licensed Reactor Operator 2 Unlicensed Operator 2 l Shif t Technical Advisor ** 1 COLD SHUTDOWN Licensed Senior Reactor Operator 1 and Licensed Reactor Operator 1 REFUELING Unlicensed Operator 1 Shif t Technical Advisor ** Sone Required i

• Higher grade licensed operators may take the place of lower grade licensed or unlicensed personnel.

• • _Provides an on-shift -technical advisor, with college level education in engineering and science subjects and specific training in the response and analysis of the plant for transients and accidents. The Shift Technical Advisor position is considered temporary and will remain in ef fect only until such time as the above characteristics are attained by the Licensed Senior Reactor Operator. - The licensed Senior Reactor

. ,0perator and the Shif t Technical Advisor position nay be fulfilled by one person possessing the qualifications of both.

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