ML20070F122

Safety Evaluation Supporting Amend 135 to License DPR-35

ML20070F122
Person / Time
Site:	Pilgrim
Issue date:	03/04/1991
From:	Office of Nuclear Reactor Regulation
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ML20070F116	List: ML20070F114 ML20070F122
References
NUDOCS 9103080121
Download: ML20070F122 (3)

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[om atog'o UNITED STATES 8

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.135 TO FACILITY OPERATlHG LICENSE NO. DPR-35 BOSTON EDISON COMPANY l

PILGRIM NUCLEAR POWER STAT 10t!

DOCKET N0. 50-?93 INTRODUCTION By letter dated March 15, 1990, the Boston Edison Company (the licensee) requested an amendment to facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. The proposed amendment would change the Technical Specifications (TS)to1)removetheneedforsurveillancetestingonthe operational train of the Core and Containment Cooling Systems when the redundant train is inoperable; 2) to reduce the allowed out of service period for the Containment Cooling System and the Diesel-Generators from 7 days to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />;

3) to eliminate the.30 day out of service time for the inoperability of the-one Low Pressure Cooling Injection (LPCI) pump';with "LPCI system" throughoutand 4) to changes by replacing the word "LPCI subsystem this section of the TS and removing an-expired footnote from section 3.5.B.

The licensee changed the Pilgrim Nuclear Power Station's Bases for TS Section 3.4 & 4.4. A standby Liquid Control System'(SLCS) and 3.6.F and 4.6.F Jet Pump Flow Mismatch in a letter dated September ?7, 1990.

EVALUATION For the Containment and Core Cooling Systems, the current TS require the immediate and daily demonstration of the operability of the redundant train when the alternate train-is placed or foxd in an inoperable condition. The purpose of this testing is to demonstrate that both trains have not been incapacitated due to a common mode failure. The imediate and daily testing requirements result in ec.cessive surveillance testing and unnecessary equipment wear.- This increase of equipment wear offset any gain in assurance of equip-ment availability due to the increased likelihood of the equipment being lef t in the testing mode (inoperable) through operator error.

-Daily-surveillance _ testing,-in addition to the regularly scheduled surveillance test, is excessive since the regularly scheduled surveillance test adequately demonstrates operability without significantly diminishing _the equipment reli-

-ability due to unnecessary wear on components -and increased potential of operator _ errors. Since regularly scheduled surveillance tests are planned to provide assurance that equipment will be available during the interim periods between regularly scheduled surveillances, daily testing is counter-productive.

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These proposed TS changes bring this section of the TS into conformance with the Standard Technical Specifications (STS)_ by removing the need to place redundant systems in daily testing arrangements during periods without system redundancy, by reducing potential system failures due to improper system align-ment after excessive testing and by reducing wear on com>onents caused by r

excessive surveillance testing. Since this portion _of tie TS change results in improved overall system availability.the NRC staff concludes that the removal-of the daily testing requirement during time periods without system redundancy is acceptable.

Reducing the allowed Out of Service (005) period from seven days to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the Containment Cooling System (CCS) and-the Diesel Generators (DGs) and eliminating the 30 day 005 period for a single LPCI pump increases the avail-ability of safety equipment during power operation.

Furthermore, these changes to the TS-result in making the Pilgrim TS more consistent with the STS.

The reference to 1. M Jacob's " APED-5736: Guidelines for Determining Safe Test Intervals and Re Company, April,1969) pair Times for Engineered Safeguards" (Ger,eral Electric is also-deleted.from the Bases. ~ References to APED-5736 is being deleted from the Bases.since it no longer forms the basis for_the DOS times and the redundant testing requirements that are being changed by this proposed TS amendment.

Changing the term LPCI subsystem to LPCI system in the text and basis is an editorial change which does not impact plant safety. Likewise, incorporating this editorial change for the Containment Cooling System, Core Spray System, HPCI, and RCIC-also wili not influence the safety of the-plant.

- An' administrative change is reade to Section 4.5.A.1.d to include _a surveillance frequency of "once/3 months for the core. spray-pump flow rate test. This

- proposed administrative change restores the frequency which was inadvertently deleted by Amendment #42 to Pilgrim's TS.

Removing the footnote which granted _ conditional relief to_the requirements of

_section 3.5.B is acceptable because the footnote has expired and no longer-has any impact on TS 3.5.B.

During the review of'the TS amendment, the staff observed a deletion from the-TS that was-not justified in the licen:;ee's submittal. This deletion involved

. the: removal of the requirement for immediate and daily _ testing of'the opera-tional diesel generator when'the redundant diesel generator is inoperable.

This part of the proposed TS change-is not acceptable, and-the-licensee should

- maintain the requirement for the immediate and-daily testing of the operational diesel generator-in the TS.

L The Bases change for the SLCS has been revised to correct the minimum boron concentration calculated to occur in the reactor vessel upon SLCS injection.

The correct boron concentration in the reactor at the cold shutdown consid-

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eration is equivalent-to-675 ppm of natural boron. This concentration results o

in a shutdown margin of 4.01% WL for the current cycle, which exceeds the minimum required shutdown margin of 3% Wk. This correction only affects Technical Specification Bases Pages 100 and does not reduce the margin of safety defined by the 3% Wk minimum required shutdown margin.

The Technical Specification Bases for jet pump flow mismatch have also been revised on Page 148 to add further justification for the restriction based on core flow coastdown concerns. These bases changes do not alter Technical Specification 3.6.F because additional justification is provided for the existing specification.

The staff has reviewed the changes to the Bases for Sections 3.4 & 4.4.A and 3.6.F and 4.6.F and offers no objection.

ENY1RONMENTAL CONSIDERATION This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements. The 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 Comission has previously published a proposed finding that the amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, this 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 this amendment.

CONCLtJSION The Comission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Register (55 FR 18408) on May 2, 1990 and consulted with the Commonwealth of Massachusetts.

Mr. Joseph Kriesberg, Director, Massachusetts Citizens for Safe Energy, Boston, Massachusetts responded to this notice in the form of three questions on the Core and Containment Cooling System surveillance.

HRC responded to Mr. Kriesberg's inquiry by letter, dated August 9,1990, in question and answer format. The Commonwealth of Massachusetts was. consulted and did not have any comments.

The staff has concluded, based on the considerations discussed above, that:

(1) there 'is reasonabic assurance that the health and safety -f the public will not be endangered by operation in the proposed manner, and (2) su a activities will be conducted in compliance with the Comission's regulations, rnd (3) the issuance of this amendment will not be inimical to the common deferse and security or to the health and safety of tb s blic.

u Principal Contributor:

Peter Hearn Dated: March 4, 1991

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