ML20153B291

Safety Evaluation Supporting Amend 97 to License DPR-54

ML20153B291
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Site:	Rancho Seco
Issue date:	03/15/1988
From:	Office of Nuclear Reactor Regulation
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• %*****/ SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 97 TO FACILITY OPERATING LICENSE NO. DPR-54 SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO NUCLEAR GENERATING STATION 00LKET NO. 50-312 INTRODUCTION As part of an overall performance improvement program at Rancho Seco following an overcooling transient on December 26, 1985, and a subsequent extended shutdown, the NRC staff reviewed the Rancho Seco Technical Specifications (TS) to identify whether the differences between the existing Rancho Seco TS and the Babcock and Wilcox (BAW) Standard Technical Specifications (STS) were safety significant.

The current version, revision 4, of the BAW STS was issued in 1980 and contains significant differences when compared to the Rancho Seco TS which were compiled in the early 1970's.

The licensee, Sacramento Municipal Utility District (SMUD), initiated a parallel review of the TS differences with the NRC staff and a composite list of differences which were perceived to be safety significant by the two review groups was compiled and incorporated as a change to the Rancho Seco TS.

SMUD submitted the proposed changes in a letter dated October 1, 1987.

The NRC staff reviewed this submittal and recommended changes to the proposed specification to incorporate additional safety significant portions of the STS.

SMUD revised the initial submittal on two occasions, November 25 and December 3, 1987 to incorporate the NRC staff recommendations.

The two supplemental submittals (November 25, and December 3, 1987) were not referenced in the Federal Register notice published on December 16, 1987.

However, the supplemental submittals did not alter the description of the proposed change as noticed on December 16, 1987.

Each proposed TS modification or addition was designed to make the Rancho Seco TS more closely conform to the BAW STS (NUREG-0103, Rev. 4).

TS define the limits, operating conditions and other requirements under which a nuclear power plant can be safely operated.

In order to properly define these conditions, the TS must be based on the plant's safety analysis report (SAR) and the staff's safety evaluation report.

The TS must also be consistent with the as-built design of the plant.

The BAW STS have undergone staff review and have been approved to fulfill these requirements for a theoretical, commonly designed plant with a BAW nuclear supply system.

Moreover, the STS model TS are acceptable for plants and individual systems that match the common design upon which the STS are based. Therefore, in cases where the design of a plant matches the STS based design, the staff considers the plant TS to be acceptable if they are consistent with the STS.

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For many of the Rancho Seco TS changes addressed in this Safety Evaluation, the staff concludes that the changes are acceptable because they are consistent with the STS. These conclusions are based on the staff's underlying conclusion that the Rancho Seco design and safety analyses are consistent with the comon design andlyses upon which the STS are based.

In other cases, the evaluation will refer to the Rancho Seco USAR or unique aspects of the Rancho Seco design and analyses to support the acceptability of the TS changes.

Each proposed change is addressed and evaluated below.

EVALUATION The numerical references in this evaluation correspond to the section and subsection numbers of the existing Rancho Seco Technical Specifications.

1.

Table of Contents The changes to the Table of Contents are editorial in nature and necessary to incorporate many of the changes discussed below; therefore, they are acceptable.

2.

Section 1.2 The proposed change adds the definition of "Reactor Operating Conditions (Operational Mode or Mode)." This definition is editorial in nature and conforms to the wording of the Standard Technical Specification (STS);

therefore, it is acceptable.

Some of the Operational Modes at Rancho Seco are different from STS; however, taken as a whole, they contain all of the necessary items required for safe operation as described in the Rancho Seco Updated Safety Analysis Report (USAR).

3.

Section 1.2.1 The proposed change defines "Cold Shutdown" similar to Table 1.1 of the

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STS and is consistent with existing Rancho Seco procedures and the Rancho Seco USAR; therefore, the change is acceptable.

4.

Section 1.2.2 The proposed change defines the "Hot Shutdown" mode for Rancho Seco similar to STS Table 1.1 definition of "Hot Standby".

This change is consistent with current Rancho Seco operational procedures and with the USAR; therefore, it is acceptable.

5.

Section 1.2.3 The proposed change defines the "Reactor Critical" mode for Rancho Seco.

This change is consistent with current operating procedures at Rancho Seco and is consistent with the USAR; therefore, the change is acceptuble.

6.

Section 1.2.4 The proposed change defines the "Hot Standby" mode for Rancho Seco similar to the STS Table 1.1 definition of "Startup" mode.

This change is consistent with current operating procedures at Rancho Seco and is consistent with the USAR; therefore, the change is acceptable.

7.

Section 1.2.6 This proposed change, as supplemented by letter dated November 25, 1987, defines the "Refueling Shutdown" mode for Rancho Seco consistent with STS Table 1.1 and is more conservative than the previous definition; therefore, the change is acceptable.

8.

Section 1.2.12 This proposed change defines the "Heatup/Cooldown" mode for Rancho Seco similar to the STS Table 1.1 definition for "Hot Shutdown".

This change is consistent with current Rancho Seco operating procedures and USAR; therefore, it is acceptable.

9.

Section 1.2.13 The proposed change adds a definition of "Action" to the Rancho Seco Technical Specifications.

The definition as proposed and amended in the November 25, 1987 letter is consistent with standard industry practice and Generic Letter 87-09; therefore, the addition of Section 1.2.13 is acceptable.

10.

Section 1.2.14 The proposed change adds a definition of "Leakage" to the Rancho Seco Technical Specifications.

The proposed definition conforms to definitions found in STS sections 1.14,1.15,1.16 and 1.17; therefore, it is acceptable.

l 11.

Table 1.2-1 The proposed table defines in one place the Operational Modes for Rancho Seco.

The specific modes are defined elsewhere in the Rancho Seco Technical Specifications or are presented as part of this amendment.

Since this table is editorial in nature and the specific modes are l

addressed and found acceptable above, this change is acceptable.

12.

Section3J A new section 3.0 is proposed that provides for the "General Limiting Conditions for Operation" statements of STS to be added to the Rancho Seco Technical Specifications.

The proposed section is acceptable because it is consistent with Section 3.0 of STS and Generic Letter 87-09.

13.

Table 3.0-1 The proposed addition of Table 3.0-1 adds further clarification to the applicability of the "General Limiting Conditions for Operation" statement of Section 3.

It is consistent with the guidance of Generic Letter 87-09; therefore, it is acceptable, f

14.

Section 3.1 The proposed "Applicability" statement defines the Operational Modes in.thich LC0 3.1 aust be met. This change is acceptable because the defining conditions of the applicable modes are consistent with thre STS and the USAR.

15.

Section 3.1.1.1.D The proposed change would require that at least one reactor coolant pump (RCP) shall be in operation when reactor coolant temperature is equal to or greater than 280 F.

The proposed change would put an additional limiting condition of operation on the operation of the reactor coolant system.

Since this limitation is more conservative than the existing TS and is consistent with the STS and the USAR, it is acceptable.

16.

Seckion3.1.1.3 Action-The proposed Action subsection of this section requires action equivalent to that of STS if certain pressurizer code safety valves are inoperable; therefore, this proposed subsection is acceptable.

17.

Section 3.1.1.4.B The proposed change defines actions which must be taken should the pressurizer electromatic relief valve (EMOV) become inoperable in the Hot.

Standby or Power Operation modes.

The action proposed is acceptable as clarified in SMUD's November 25, 1987 letter since the proposed change is consistent with STS.

18.

Section 3.1.1.5.A This proposed change defines the operability status of the coolant loops for Decay Heat Removal.

Since two of the listed coolant loops must be operable with or' in operation, the staff concludes that adequate decay heat removal cos.ing will be available as defined in the USAR; therefore, this proposed change is acceptable. The clarifying letter of November 25, 1987 defined applicability during refueling operations.

Since this change is consistent with ine:ustry practices and equivalent to STS 3.9.8 and 3.9.8.2, the proposed change is acceptable.

19.

Section 3.1.1.5.B This proposed change is editorial in nature and is, therefore, acceptable.

20.

Section 3.1.2.2 The proposed change to this section would aad a requirement to determine heatup/cooldown rates every 30 minutes. This is an enhancement to the RSTS and is consistent with STS; therefore, it is acceptable.

The proposed change would also provide for specific action should heatup/

cooldown rates be exceeded.

The provision to return heatup/cooldown rates to acceptable values within 30 minutes as defined in the supplemental information letter of November 25, 1987 is acceptable since 30 minutes is acceptable industry practice and conforms to the STS.

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Section 3.1.3.3 This proposed change would require action to restore the Shutdown Margin and is an enhancement to the existing RSTS to make the RSTS conform to the USAR; therefore, it is acceptable.

22.

Section 3.1.3.4 This proposed change would require actions to restore the needed Shutdown Margin and is an enhancement to the existing RSTS to make the RSTS conform to the USAR; therefore, it is acceptable.

23.

Section 3.1.4.1 The proposed changes clarify the section to more clearly state the actual conditions for monitoring of Reactor Coolant System Activity. The changes are consistent with the USAR; therefore, they are acceptable.

24.

Section 3.1.6 (RCS Leakage) "Applicability" The proposed change specifies when Section 3.1.6 is applicable.

Since all operating modes from Power Operation through Hot Shutdown are specified which is consistent with the STS, this proposed change is acceptable.

25.

Section 3.1.6.1 This proposed change defines RCS leakage limits and actions to be taken should the Reactor Coolant System leakage be greater than allowed. The RCS leakage limits are consistent with those specified in the STS and are the allowable leakage limits which have been analyzed in the USAR; therefore, the proposed change is acceptable.

26. Section 3.1.6.1 Bases This proposed change more clearly defines the basis of 3.1.6.1; therefore, it is acceptable.

27.

Section 3.1.7 This proposed change defines the Applicable Mode and appropriate action to be taken if the LCO is not met.

Since the propose change is consistent with the STS, it is acceptable.

28.

Section 3.1.9 This propose change defines the Applicable Mode and appropriate action to be taken if the LCO is not met. This change is consistent with the STS'and is acceptable.

6-29.

Section 3.3, 3.3.1C, 3.3.1 Action, 3.3.10, E and F These proposed changes define the Applicable Operation Modes and Actions and are consistent with the STS; therefore, they are acceptable.

Section 3.3.1E defines Ultimate Heat Sink levels and temperature and is acceptable since the levels and temperatures are those used in the USAR analysis.

The change as amended via the December 3, 1987 letter combines Sections 3.3.1.E and F.

This is consistent with STS (Section 3.7.4) and with the existing RSTS Section 3.3.2.D; therefore, it is acceptable.

30.

Section 3.3 Bases This proposed change "See USAR paragraph 9.4.2.3(m)... Nuclear Service spray ponds at 95'F" more clearly defines the basis for 3.3 and is acceptable.

31. Table 3.5.1-1 This proposed change added a surveillance requirement to insure that the Shutdown Margin is adequate.

This is consistent with Rancho Seco operating procedures and the USAR.

It is an enhancement to the RSTS and is acceptable.

32.

Section 3.5.2 This proposed chang adds an Action statement to this section for Control Rod Group and Power Distribution Lim'its. This Action statement is consistent with STS; therefore, it is acceptable.

33.

Section 3.5.4 This proposed change provides an Applicability statement for incore instrumentation which is consistent with STS; therefore, it is acceptable.

Other editorial changes are also made and are acceptable.

34.

Section 3.5.7 This proposed change provides a new Applicability Section for Emergency Shutdown Instrumentation.

Applicability includes all modes which is consistent with the STS; therefore, this change is acceptable.

35. Table 3.5.7-1 This proposed addition provides a listing of the "Emergency Shutdown Instrumentation" that has previously been approved during the staff's Cc,ntrol. Room Habitability review for Rancho Seco.

All instrumentation that is required for shutdown and maintenance of Hot Shutdown is listed.

Therefore, this addition is acceptable.

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Section 3.6 The proposed change to define Applicability specifies all Operating Modes, Heatup-Cooldown through Power Operation.

This is consistent with the STS.

In addition, Rancho Seco has reviewed and upgraded procedures to assure adequate containment integrity during all Operating Modes, Heatup-Cooldown through Power Operation.

Since containment integrity will be assured for all conditions where it is required for the accident calculations in the USAR, this change is acceptable.

37.

Section 3.9 The proposed changes to this section ar.e editorial ir, nature and are consistent with tne RS USAR with regard to the depth of water over the spent fuel.

Therefore, the changes are acceptable.

38.

Section 3.10 Specification The purpose of this propased change is to define the amount of radioactivity that is allowed in the w. ster on the secondary side of the steam generator.

The stated limits are consistent with the accident calculations in the USAk; therefore, they are acceptable.

39.

Section 4.0 Applicability The proposed change, as amended in the November 25, 1987 letter, makes General Surveillance Requirements applicable in the Operational Modes, Power Operation through HeabJp/Cooldown inclusive.

This is consistent with current industry practice and with the STS; therefore, the change is acceptable.

40.

Section 4.1.1 This change, as amended by the November 25, 1987 letter, sets the minimum frequency and type of surveillance required for certain systems to be applicable when the reactor is in the Operational Modes, Power Operation through Heatup/Cooldown inclusive.

This is common practice throughout the industry and is consistent with the STS; therefore, it is acceptable.

41. Table 4.1-1 and Tatle 4.1-2 The proposed changes to the "Instrument Surveillance Requirements" table and the "Minimum Equipment Test Frequency" table are editorial to reflect the changes to the individual RSTS approved in this amendment; therefore, they are acceptable.

42.

Section 4.2.3.1 The changes, as amended by the November 25, 1987 letter, to this section def he the surveillance that wili be utilized to measure system leakage.

These changes are in accordance with industry practice and consistent with the STS; therefore, they are acceptable.

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43. Section 4.4.1.1.1 and 4.4.1.1._4 This proposed change, 's amended by the November 25, 1987 letter, defines measurement methods for containment leakage rates.

The defined method of measuring containment leakage rates is consistent with the STS; therefore, it is acceptable.

44.

Section 4.4 1.2.1 This change adds some additional locations where local leak rate shall be measured.

Since these are additional points that were missed in previous amendments, they are acceptable.

45.

Sections 4.4.1.2.2 and 4.4.1.2.3 These are only editorial changes to the RSTS which do not affect the technical requirements; therefore, they are acceptable.

46.

Section 4.6.4 This is an addition to existing RSTS to make them comply more closely with STS; therefore, the changes are acceptable.

47.

Section 6.9 The proposed changes are administrative in nature and comply with the STS; therefore, they are acceptable.

48. Section 4.10.1.E.2 and Table 1.1.1 This change clarifies that a chlorine (toxic gas) monitor is required only when the quantity of gaseous chlorine in the restricted area exceeds 100 pounds. This clarification is in accordance with Regulahry Guide 1.95.

ENVIRONMENTAL CONSIDERATION l

f This amendment involves changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

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 not significant This increase in individual or cumulative occupational radiation exposure.

i amendment also relates to changes in recordkeeping, reporting or administrative The Commission has previously issued a proposed procedures or requirements.that this amendment involves no significant hazards consider finding there has been no public comment on such finding.

Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Pursuant to 10 CFR 51.22 (b), no environmental 51.22(c)(9) and 51.22(c)(10).

htsmenT. or environmental assessment need be prepared in connection impact i with the issuance of this amendment.

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e tw g CONCLUSION Wehaveconcluded,basedontheconsiderationsdiscusseda$ove,that(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (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 common defense and security or to the health and safety of the public.

Principal Contributor:

James Miller Dated: March 15, 1988 O

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