ML20057D757
| ML20057D757 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/28/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20057D756 | List: |
| References | |
| NUDOCS 9310050321 | |
| Download: ML20057D757 (7) | |
Text
4 nog I*t UNITED STATES
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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205G54K)01
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.149 TO FACILITY OPERATING LICENSE NO. DPR-35 bD3 TON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET N0. 50-293
1.0 INTRODUCTION
The licensee proposed changes to their Technical Specifications (TSs) in a [[letter::BECO-92-126, Application for Amend to License DPR-35,revising TS Sections 1.0,4.3,4.4,4.5,4.6,4.7 & Associated Bases to Conform SRs for ASME Code Class 1,2 & 3 Pumps & Valves to IST Program, Per 10CFR50.55a(g)(5)(ii)|letter dated October 30, 1992]], which included the following:
- 1) adding a new section in TS to specify limiting conditions for operation (LCO) and surveillance requirements for inservice testing (IST) of pumps and valves;
- 2) adding the definition of " Refueling Interval" to the TS definition section;
- 3) revising the definition of " Surveillance Interval" to allow the 25%
tolerance on the testing frequency allowed by the ASME Code to apply to the Pilgrim refueling interval of 24 months; 4) modifying the surveillance frequency for specific pumps and valves which are tested in the IST program from monthly to quarterly; and 5) making miscellaneous changes to the Pilgrim TS and Bases to match the TS requirements with the IST program.
In addition, by letters dated February 11, 1993 and March 29, 1993, changes were made to the Bases sections regarding core spray and LPCI system, and drywell temperature.
2.0 EVALUATION 2.1 Addition of TS Sections 3.13 and 4.13: Inservice Code Testina The licensee has proposed to add TS Sections 3.13 and 4.13 to define the LCO and surveillance requirements for IST of safety-related pumps and valves.
The proposed TS Sections 3.13 and 4.14 incorporate portions of TS Section 4.0.5 of the Standard TS for General Electric Boiling Water Reactors (BWR/S) which are j
contained in NUREG 0123, Revision 3, fall 1980.
i The proposed TS Sections 3.13.A.1 and 4.13.A.1 state that IST of safety-related pumps and valves shall be based on the facility commercial operation date and performed in accordance with ASME Section XI, Subsections IWP and IWV, except where specific relief has been granted by the NRC. The proposed addition defines the LC0 for IST such that all safety-related testing of pumps and valves at Pilgrim Nuclear Power Station shall be conducted in accordance l
with ASME Section XI, Subsections IWP and IWV. Any safety-related components not tested in accordance with TS Section 4.13.A.1 would violate the LCO.
Therefore, the proposed TS section additions are acceptable.
9310050321 930928 PDR ADOCK 05000293 P
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The proposed TS Section 4.13.A.2 contains a list of Code test frequencies in I
terms of days. The proposed TS section is similar to Section 4.0.5.b of the l
BWR/S Standard TS. Although Pilgrim is a BWR/3 vintage plant, the testing i
frequencies apply to IST of safety-related pumps and valves in all commercial-nuclear power plants. The testing frequencies defined by the licensee are consistent with the existing Code terminology. Therefore, the proposed TS section addition is acceptable.
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The proposed TS Section 4.13.A.3 states that the definitions in TS Section 1.0 l
for refueling interval, surveillance frequency, and surveillance interval are applicable to the frequencies defined in proposed TS Section 4.13.A.2.
The licensee's proposal to modify the definitions in TS Section 1.0 are evaluated j
in Section 2.2 of this safety evaluation (SE). The proposed TS Section j
addition is an enhancement to the TS because it provieles a specific reference i
to applicable TS definitions related to IST. Therefore, the proposed TS i
section addition is acceptable.
l The proposed TS Section 4.13.A.4 states that performance of Code testing shall l
be in addition to other specified surveillance requirements. This is virtually identical to Section 4.0.5.d of the BWR/5 Standard TS. Also, the proposed TS Section 4.13.A.5 is identical to Section 4.0.5.d of the.BWR/5 l
Standa:d TS and states that no Code testing shall supersede the TS. Although j
Pilgrim is a BWR/3 vintage plant, these proposed TS Sections apply to IST of safety-related pumps and valves in all commercial nuclear power plants.
l Therefore, the proposed TS section additions are acceptable.
2.2 Chances to TS Definition Section 2.2.1 Refuelina Frecuencies l
The licensee has proposed to modify TS Section 1.0.P to be titled Refueling Frequencies, redesignate the definition of Refueling Outage to be TS N. tion 1.0.P.1, and add the definition of Refueling Interval as TS Section 1.0.P.2.
i The licensee stated that the Refueling Interval only applies to surveillance i
testing conducted in accordance with ASME Section XI and defines this interval as once every 24 months. This change specifically defines the testing frequency in the TS for components which can be tested only when the plant is shut down for refueling. Accordingly, the proposed TS section changes are acceptable.
2.2.2 Surveillance Interval The licensee has proposed to modify the definition of Surveillance Interval in TS Section 1.0.V to include that the Refueling Interval is 24 months and that the allowable extension of the Surveillance Interval, discussed in TS Section 1.0.U, also applies to the Refueling Interval. This addition clarifies that the 25% extension of the Code test interval also applies to the Refueling Interval, which is allowed by the Code, and therefore ensures consistency between the Code and the TS. Accordingly, the proposed TS section change is acceptable.
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2.3 Pumo Testina Frecuency The licensee has proposed to revise the pump testing frequency requirements of the following pumps from monthly to quarterly:
standby liquid control TS Section 4.4.A; core spray (CS), TS Section 4.5.A.I.b; low pressure co(SLC),
olant injection (LPCI), TS Section 4.5.A.3.b; reactor building component cooling water (RBCCW) and salt service water (SSW), TS Section 4.5.B.I.a; high pressure coolant injection (HPCI), TS Section 4.5.C.I.b; and reactor core isolation cooling (RCIC), TS Section 4.5.D.1.b.
These pumps are currently included in the licensee's IST program and are tested in the TS for operability on a monthly frequency. A pump flow test is conducted once every 3 months.
The proposed changes would delete the monthly test and specify the pump test be conducted in accordance with Code testing as specified in TS Section 3.13.
In addition, the licensee has proposed to modify each applicable TS section such that pump pressure (or head) and flow rate acceptance criteria are now verified in conjunction with the Code testing of Section 3.13.
The proposed TS Section 3.13 states that IST of safety-related pumps shall be conducted in accordance with the ASME Boiler and Pressure Vessel Code,Section XI (The Code). Paragraph IWP-3220 of the Code specifies that if a measured pump parameter enters the alert range, as defined in Table IWP-3100-2, then the testing frequency is doubled until the cause of the deviation is determined and the condition corrected. The pumps referenced in this TS change are currently tested monthly. Under the proposed TS change, if degradation occurs and a pump parameter falls into the alert range, the licensee would commence testing at an increased frequency until the problem is resolved.
Therefore, for pumps with a degraded condition, the proposed TS would require surveillance at a frequency similar to the current testing frequency.
Entering the Code-specified required action range would require the licensee to declare the pump inoperable.
This aspect is unchanged by the TS change.
In addition, NUREG 1366, " Improvements to Technical Specification Surveillance Requirements," issued December 1992, recommends that pump testing which is conducted more often than required by the Code be changed to a quarterly test frequency.
The staff believes that the Code quarterly-testing frequency, coupled with increased testing of pumps performing in the alert range, is adequate to detect and monitor pump condition. The NRC endorses the ASME Code,Section XI, and references this Code in 10 CFR 50.55a as the requirements of IST for pumps. Accordingly, the proposed TS changes are acceptable.
2.4 Valve Testina Chanaes 2.4.1 Motor Ooerated Valve (MOV) Testina Frecuency The licensee has proposed to revise the testing frequency of MOVs associated with the following systems: CS TS Section 4.5.A.I.c; LPCI, TS Section 4.5.A.3.c; RBCCW.and SSW, TS Section 4.5.B.I.b; HPCI, TS Section 4.5.C.I.c; and RCIC, TS Section 4.5.D.1.c.
These MOVs are currently being tested in the
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TS on a monthly frequency. ' The licensee's proposed revision removes the monthly requirement and states that the valves are to be tested as specified in Section 3.13 of the TS.
1 The proposed TS Section 3.13 states that IST of safety-related valves shall be conducted in accordance with the ASME Boiler and Pressure Vessel Code,Section XI (The Code). With some exceptions, Paragraph IWV-3411 of the Code specifies that Category A and B valves shall be tested every 3 months.
If a valve i
stroke time exceeds the previous stroke-time test as specified in IWV-3417a, j
then the valve testing frequency is increased to once per month until the problem has been corrected. Therefore, for valves with a degraded condition, t
the proposed TS would require surveillance at a frequency identical to that -
i required by the current TS for MOVs tested monthly.
If an MOV stroke time exceeds the licensee-specified limiting value, the valve will be declared
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This aspect is unchanged by the TS change.
The NRC endorses the ASME Code,Section XI, and incorporates by reference this I
Code in 10 CFR 50.55a as the requirements of IST for valves. Accordingly, the i
proposed TS changes are acceptable.
2.4.2 Safety and Relief Valves (SRVs)
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The licensee has proposed to replace the testing currently specified in TS l
Section 4.6.D.1 with a reference stating that SRVs shall be tested in accordance with TS Section 3.13.
TS Section 3.13 states that IST.of safety-related valves shall be conducted in accordance with ASME Section XI. The Pilgrim IST program currently is administered in accordance with the 1986.
Edition of ASME Section XI. Paragraph IWV-3510 of this Edition specifies that testing of SRVs shall be conducted in accordance with ANSI /ASME OM-1-1981 (OM-1). Although testing in accordance with OH-1 may result in fewer SRVs tested during each refueling interval, OM-1 has been approved by the NRC for IST of SRVs. Therefore, the proposed TS change is acceptable.
i 2.4.3 Primary Containment Isolation Valves (CIVs)
The licensee has proposed to delete the requirements in TS Sections 4.7. A.2.b.1.b.1 and.2 and insert requirements that the primary CIVs and main l
steam isolation valves (MSIVs) will be tested as specified in TS Section 3.13.
All of the valves referenced in this TS change are tested in the licensee's l
IST program as currently specified in the TS. The TS revision does not change i
the testing frequency of these valves. Accordingly, the proposed TS section.
changes are acceptable.
The licensee has proposed to delete the requirements of TS Section 4.7.A.2.b.1.d and insert requirements that the reactor coolant system instrument line flow check valves will be tested as specified in TS Section 3.13.
Relief Request RV-22 in the IST program was granted by the NRC'to conduct testing of these valves once every refueling interval (reference NRC c
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letter dated April 22,1991). The testing frequency is changed from once per operating cycle to once per refueling interval. However, the refueling interval is specifically defined and these valves can'only be tested when the
-' plant is shut down for refueling.
Therefore, the proposed TS changes are acceptable.
2.4.4 Reactor Buildina-Vacuum Breakers The licensee has proposed to delete the requirements for the pressure suppression chamber reactor building vacuum breakers from TS Section 4.7.A.3.a and add a reference that the pressure suppression chamber reactor building vacuum breakers be tested as specified in TS Section 3.13.
In addition, the licensee has proposed to relocate the' requirements for the associated instrumentation previously contained in TS Section 4.7.A.3.a to TS Section 4.7.A 3.b.
Testing of the vacuum breakers and their associated instrumentation is currently conducted in accordance with the TS every 3 months.
The pressure suppression chamber reactor building vacuum breakers are currently tested in the licensee's IST program at a quarterly frequency.
This testing consists of stroking the vacuum breaker open and verifying that the valve recloses. The testing frequency contained within the IST. program-is identical to the test frequency requirements currently specified in TS Section 4.7.A.3.a.
The proposed TS changes do not change the test frequency or method-and are, therefore, acceptable.
2.4.5 Scram Discharoe Volume (SDV) Vent and Drain Valves The licensee has proposed to delete the open verification and cycle requirements contained in TS Section 4.3.G.1 and add two new TS Sections, 4.3.G.1.a and 4.3.G.I.b.
The proposed TS Section 4.3.G.I'.a contains the requirement previously contained in TS Section 4.3.G.1 which states that the SDV vent and drain valves will be verified open at least once per month.
The proposed TS Section 4.3.G.I.b states that the valves will be tested as specified in TS Section 3.13.
In addition, TS Section 4.3.G.I.b adds the requirement previously contained in TS Section 4.3.G.1 that the valves may be closed intermittently under administrative control.
The SDV vent and drain valves are currently tested in the licensee's IST t
program at a quarterly frequency. This testing consists of cycling the solenoid valves without measuring individual valve stroke times. The testing contained within the IST program is identical to~ the testing requirements currently specified in TS Section 4.3.G.I.
The proposed TS changes do not change the testing frequency or method and are, therefore, acceptable.
m 2.5 Standby Liouid Control (SLC) System 2.5.1 Pumo Testina The licensee has proposed to replace the surveillance requirement listed in Section 4.4.A.2.b to test the SLC system monthly by manually initiating the SLC system and recirculating boron solution back to the solution tank. The proposed quarterly test exceeds the current requirement because the test method used verifies the pump flow, system head, and the recirculation flow path, thus, satisfying the current once-per-cycle surveillance on a quarterly basis.
The licensee is also proposing to change the once-per-cycle requirement to manually initiate the SLC system and pump demineralized water into the reactor vessel to perform this testing once per refueling interval.
This test checks for proper operation of the explosive valves and proper operation of the pumps and valves. The licensee stated that quarterly testing of the pumps and refueling outage testing of the pumps and the explosive valves will be in accordance with the methods and frequencies prescribed in the Code. Therefore, the proposed changes are acceptable.
2.5.2 SLC Pumo Relief Valve Testina The licensee has prcposed to replace the surveillance requirement currently contained in TS Section 4.4.A.2.a with a testing requirement that the each SLC pump relief valve set point shall be 1425 psig i 43 psig during testing in accordance with TS Section 3.13 every refueling outage. This change establishes a tighter tolerance on the relief valve set point than the previous TS. The proposed set point criteria are consistent with current Code requirements.
Accordingly, the proposed TS change is acceptable.
2.5.3 Miscellaneous Chances to SLC System T1 The licensee nas proposed to change the phrase contained in the proposed TS Section 4.4.A.2.b from " pump operability" to " pump capacity." The licensee states that this change will more accurately describe the purpose of the test.
TS Section 4.4.A currently states that the operability of the SLC system shall be verified, in part, by the performance of the test in the proposed TS Section 4.4.A.2.b.
Therefore, substitution of the word " capacity" for
" operability" will not change the requirements for the SLC pump. Accordingly, the proposed TS change is acceptable.
2.6 Miscellaneous TS Chances The licensee is proposing to modify several TS Bases sections to be consistent with the proposed changes and additions. The affected bases sections include Section 3.4.A for the SLC system, Section 3.5.B for containment cooling, and i
Section 4.5 for core and containment cooling systems surveillance frequencies.
The licensee proposes adding a Bases section for TS Sections 3.13 and 4.14 for inservice code testing. The proposed changes and additions to the TS Bases explain and support the changes in the TS. Accordingly, the proposed TS i
changes and additions are acceptable.
. t The licensee has proposed to delete TS Section 4.6.D.5 which requires SRVs that have been in service to be tested in the as-found condition during both Cycles 6 and 7.
Pilgrim is currently in operating Cycle 10. This TS section is obsolete. Therefore, the licensee's proposed change is acceptable.
The licensee has proposed to change the term " refueling outage" to " refueling interval" in TS Sections 4.7.A.4.b, 4.7.A.4.b.(3), 4.3.G.2, and proposed TS Section 4.4.A.2.c, to establish a specific testing frequency of 24 months for the applicable surveillance. The change is for clarification and consistency with the new definitions. Therefore, the proposed changes to the TS sections i
are acceptable.
The licensee has proposed to renumber several TS subsections within TS Sections 4.4.A, 4.5.A, 4.5.B, 4.5.C, and 4.5.0 that were either deleted or relocated as a result of this TS change submittal. These proposed changes are editorial changes which do not affect the TS requirements and are, therefore, acceptable.
3.0 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.
4.0 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 surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant cFange 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 (57 FR 61108). 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.
5.0 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 Contributor: Joseph Colaccino Date: September 28, 1993 l
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