ML20195J553

Safety Evaluation Supporting Amend 113 to License DPR-35

ML20195J553
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Site:	Pilgrim
Issue date:	01/21/1988
From:	Office of Nuclear Reactor Regulation
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NUDOCS 8801280536
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[ " *'4*k UNITED STATES l'

NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 113 TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 1.0 BACKGR0llND The NRC, by letter dated July 2,1984, requested the licensee (the Boston Edison Cenpany) to update the Pilgrin Technical Specifications (TS) related to Prinarv containment testing for comoliance with the requirements of Accendix J to 10 CFR 50 (Appendix J).

Ry letter dated June 21,1985, the licensee resporded by submitting a proposed amendment to Apperdix A of Operatina license No. DPR-35 to modify a cortion of the TS concerning primary containment tests. The staff reviewed the licensee's submittal and in a letter dated October 1,1985, recontrended approval of the TS chances except for the nroposed deletion c# Table 3.7-1 which lists ra.ior primary containment isolation valves.

As a result of the October 1, 1985 evaluation, the licensee reinstated Table 3.7-1 in the TS and also made additional changes to the TS to reflect amendments and plant modifications that had been nade to comply with NRC'S TMI Action Plan and Multi-Plant Action (MPA) B-24 requirenents.

The revised TS was subnitted by the licensee in a letter dated June 4,1987, which conpletely superseded the unaoproved portions of the licensee's submittal of June 21, 1985. Further s

revisions to the June 4, 1987 submittal were made in response to staff auestions by letter dated August 13, 1987.

In letters dated Septenber 21 and December 8, 1987, the licensee provided five corrected paces to TS pages submitted on August 13, 1987 These corrections, of a nontechnical nature, resolved typographical errors and made the text consistent with recently approved license amendments.

The licensee's proposed TS changes include (1) revising the definition of frequently used terms, (?) modifying Table 3.2-B to add instrumentation for the two new HPCI vacuum breakers, (3) revising containment isolation valve listing in Table 3.7-1, and (4) making editorial changes and addino clarifications to facilitate the interpretation of the TS. The chances to the TS sections are itemized below, followed by the staff's assessment of each change.

8801280536 880121y3 DR ADOCK O l

2.0 EVALUATION 2.1 TS pace 3, Definition M "Primary Containment Integrity":

The licensee proposes to add condition 5 in Definition it to further define containnent interity and rewrite condition 4 Condition 4 is revised by addina an additional statement to require that at least one valve on each line havina an inoperable valve shall be deactivated in the isolated condition.

The added condition 5 states that all containment isolation check valves are operable or at least one containment isolation valve in each line havina an inoperable valve is secured in the isolated position.

The staff finds the proposed revision to definition M acceptable since both conditions 4 and 5 further define containment integrity in considerino an inoperable valve in a line.

2.2 TS nage 5b, Definition EE "Automatic Primary Containnent Isolation Valves":

The licensee proposes to add Definition EE to the TS which states that automatic primary containment isolation valves are the isniatien valves which receive an automatic primary conatinment group isolation signal.

The staff finds the proposed definition acceptable since it defines the neanino of the automatic isolation valves.

P.3 TS page 48, Table 3.9-E "Instrumentation that Initiates or Controls the Core and Containrent Coolina Systems":

The licensee proposes to add to Table 3.?-B two instrument charnels per trip systen for closure of High Pressure Coolant In,iection (HPCI) vacuun breaker isolation valves due to HPCI modification.

The HPCI system modification added two new vacuum breakers and a vacuun relief line to the HPCI system turbine exhaust pipe during refueling outage No. 7 (during shutdown period which commenced April ', '186).

The new vacuum relief line was routed from the torus hydroce '^r umbiner tie-in pipe to the hiah point of the HPCI turbine exhaust pipe.

The new line includes two vacuun relief check valves and two normally open motor operated j

containment isolation valves.

The newly installed containment isolation valves have control and indication in the main control roon, and are automatically closed on a combination of hiah drywell pressure and low reactor pressure signal (Group 7 isolation condition).

The purpose of the HPCI modification is to reduce hydrodynamic transients (water hammer) in the HPCI turbine exhaust pipe.

Steam left in the exhaust pipe cools and condenses, thereby creating a vacuum in the pipe.

The vacuum draws water from the torus into the exhaust line. When the HPCI turbine is restarted, a water slug travels down the pipe to the torus causing the water hammer transient.

Implementation of vacuum 4

breaker will correct the problem by not allowina sianificant vacuum (with respect to torus air pressure) to be developed in the HPCI turbine exhaust lino.

The licensee has previously submitted information to the NRC on desion and installation of the HPCI vacuum breakers.

. The staff has reviewed available information on the HPCI vacuum breaker modification, and discussed this modification with the licensee. The staff finds that the autonatic closure trip systen is needed to automatically close the vacuum breaker isolation valves. Consequently, the proposed revision to Table 3.2-B is acceptable.

2.4 TS pages 155, 155a, and 157a, Section 3.7 A "Primary Containment":

The licensee proposes to rewrite Subsection 3.7.A.? by addina Subsections 3.7. A.?.a and 3.7. A.2.b, and revise Subsections 3.7. A.5 and 3.7. A.6.

Subsection 3.7.A.2.a entitled "Primary Containment Integrity", is a revision of Subsection 3.7.A.2 with the additional five conditions added to define containnent intearity.

These conditions are (1) all manual isolation valves, which are not required to be open during accident conditions, are closed; (?) at least one door in each airlock is closed and sealed; (3) all blind flances and manways are closed; (4) all automatic isolation valves and instrument line flow check valves are operable; and (5) all containment isolation check valves are operable or at least one containment isolation valve in each line havina an inoperable valve is secured in the isolatien position.

The staff finds that the proposed Subsection 3.7. A.2.a provides the minimun requirements on containment isolation to naintain containnant integrity which comply with the requirenents specified in the Standard TS for BLRs, and therefore, is acceptable.

(However, the condition for airlock isolation with one door is only applicable to limiting condition for operation when the airlock is beine used for nornal transit entry and exit throuah the containment.)

Subsection 3.7.A.2.b, entitled "Primary Containment Isolation Valves", is added to Section 3.7.A.? by moving the existing TS Section 3.7.A.D.2 with additional recuirements on valve deactivation in the isolation condition that nust be applied ir any line having an inoperable isolation valve.

The subsection also specifies that closed isolation valves may be reopened on l

an intermittent basis under Operations Review Cornittee (ORC) administrative controls. The staff finds the proposed Subsection 3.7.A.2.b acceptable since it is a relocation of Subsection 3.7,0.2 with additional limitations and restrictions on the inoperable isolation valves which are not currently included in the TS.

The existing Subsection 3.7.5b is renumbered to Subsection 3.7.A 5b, and the existing Subsection 3.7.6 is renumbered to 3.7.A.6.

The staff finds the proposed Subsections 3.7.A.5b and 3.7.A.6 acceptable since the changes are editorial to make the TS consistent.

2.5 TS paces 155 and 155a, Section 4.7. A "Primary Containment Integrity":

The licensee proposes to rewrite Subsection 4.7. A.2 for surveillance reouirenents by adding paragraphs 2.a, P.b.1, 2.b.7, 2.c, 2.d and deleting leakrate testing methods A and B which were related to tests prior to initial unit operation.

. Paragraph d.7.A.2.a. entitled "Primary Containment", is added to the Subsection.

It requires that the primary containment be leakrate tested in accordance with Appendix J, with exceptions as apornved by the NRC.

The paragraph also addresses total leakage rates for: (1) double gasketed seals, (2) all testable penetrations and isolation valves, (3) any one penetration or isolation valve, and (4) any one main steam line isolaticn valve. These leakage criteria were relocated fron the existing Subsection 4.7.A.f to the proposed Paragraph 4.7.A.2.a.

The staff finds the proposed paracraph 4.7.A.P.a acceptable since the chances are editorial for clarity and consistency. Certain leakrate test provisions, such as main stean line isolation valve and personnel airlock testina at reduced pressures, were previously approved by the NRC in a Setter dated July 2, 1984 Paragrcph 4.7.A.P.b, entitled "Primary Containment Isolation Valves",

is added to the Subsection by using the content of existina Section 4.7.D. The new Subsection has two paracraphs, i.e., 2.b.1 and 2.b.2.

Paraaraph 2.b.1 uses the wording in Subsection 4.7.D.1, which addresses prinary containnent isolation vsive surveillance requirements.

Paragraph 2.b.? uses the wording in Subsection 4.7.D.2, which recuires that the position of the automatic isolation valve in each line havino an inoperable valve be recorded daily.

The staff finds the proposed Subsection 4.7.A.2.b acceptable since the chances are editorial to make the TS consistent.

Paracraph 4.7. A.?.c, entitled "Continuous Leakrate tionitors", is added to the Subsection by usino the content in existing Subsection 4.7.A.2.g, which requires the primary containment to be continuously monitored fnr cross leakage while inerted.

The chance is editorial in nature for consistency, and there# ore, is acceptable.

Paragraph 4.7.A.2.d, entitled "Drywell Surfaces", is added to the Subsection by using the content in existing Subsection 4.7.A.2.h which reauires the interior of the drywell and torus above the water lina to be visually inspected every refueling outage. The chance is editorial in nature for consistency, and therefore, is acceptable.

2.6 TS paces 160 thru 164, Table 3.7-1 "Primary Containment and Reactor I

I Vessel Isolation Valves":

l The licensee has revised Table 3.7-1 to include all the changes resultino from previous staff reviews and plant modifications.

The staff's assessment is addressed in each of the changes.

(1) The licensee proposes to change the title of the table from "Prinary Containment Isolation Valves" to "Primary Containment and Reacent Vessel Isolation Valves". The licensee stated that certain valves in the table are also used to isolate the reactor vessel boundary lines.

The staff finds the chanae clarifies the content of the table, and therefore, is acceptable, i

. (2) The licensee proposes to add "valve number", "penetration number", and "system description" to the table identifications.

The staff finds these added columns of information to the table acceptable since it makes the table nore complete.

(3) The licensee proposes to change valve position for the reactor water sample velves (M0-220-44/451 from normally closed to normally open.

The safety function of these valves is to isolate the line upon receipt of Group 1 containment isolation signal.

This line is used for continuous sanpling of reactor coolant for crack arrest verification (intergranular stress corrosion crackina) and should stay open durina modes 1, 2, and 3.

The isolation sianal for these valves durina accident conditions remains unchanged.

The staff finds the proonsed change to valve position acceptable since the chance would ensure the operability of the reactor water sampling systen durina norral coeration and would net impact the operabilitv of these isolation valves.

(4) The licensee proposes to chance maximum closino time for valves A0-5035A/B (drywell purge makeuo), A0-5036A/B (torus purge inlet),

A0-5042A/B (torus nain exhaust), and A0-9044A/P (drywell purge exhaust) from 15 seconds to 5 seconds.

The prooosed chance of the valve closina time is due to a purce and vent system modification made during refuelina outace No. 6 (1984).

The original Durae and vant system was redesigned to comply with the requirerents of NUREG-0737, Item II.E.4.2 and the guidance developed as part of the MPA B-24 concernina containment isolation dependability.

The chanae of valve closina time reflects the nodified purae and vent system design.

The oriainal 20-inch Rockwell butterfly valves have been replaced by the 8-inch Clow tricentric valve since the Clow valves can close ecainst the buildup of containment pressure in the event of a LOCA.

The closure time was 15 seconds for the 20-inch valves and is seconds for the new 8-inch valves.

The purge and vent system modification was previously reviewed and approved by the NRC in a letter dated September 24, 1984 In accordance with SRP 6.2.4, Branch Technical Position (BTP) 6.4, purge l

valve closure time should not exceed 5 seconds to assure compliance with 10 CFR 100 reaarding offsite radioloaical consequences.

Consequently, the staff finds the proposed change to the TS acceptable since the reduction of purge valve closure time meets the cuidance of SRP 6.2.4, RTP 6.4 Furthermore, the faster closure feature of the valve to avoid debris causing improper valve closing would improve containment isolation reliability during accident conditions.

(5) The licensee proposes to change valve position for valve A0-5033B, A0-5035B, AND A0-5036A/B fron normally open to normally closed.

The chance corrects errors in the current description of the normal valve positions and will not affect the operability of these valves.

Therefore, tna change is acceptable.

(6) The licensee proposes to add a total of 26 containment isolation valves (SV-5065-11A thru SV-5065-86, and CV-5065-91/92) to the H2/0? system, post-accident saroling system (PASS), and leak detection systen.

These valves were installed to the systens during refueling outage No. 6 (1984) to meet THI Action Plant (NUREG-0737) requirements.

O

. The H7/02 system was designed to comply with the reouirerents of NUREG-0737, Iten II.F.l(6) to provide the capability for "on-line" nonitering of the hydrogen and oxygen concentrations within the inerted primary contairment atmosphere, and for potential combustion cas mixture l

monitoring within the containment following a LOCA.

The PASS wrs desianed to comply with the requirements of NUREG-0737, Iten II.R.3 to provide the capability of collecting diluted or undiluted liquid reactor coolant and gaseous grab samples from RHR and,iet pumps.

These systen nodifications include a reduction in the total number of primary containment isolation valves (several penetrations were cut and capped).

The original 16 valves in the oxygen analyzer systen were removed and deleted from the TS.

The system modifications installed 24 faster closing solenoid globe valves to the PASS and H2/02 system.

The leak detection system uses the existing penetration and valves. All these valves will close upon receiving Group 2 containment isolation sional.

The implementation and design of the post-accident samplina, monitoring, and analysis systems were previously reviewed by the NRC against the criteria identified in Item II.B.3 of NUREG-0737, and were aporoved by the staff in a letter dated July 1, 19M.

The system installations were inspected by the NP.C (Inspection Report No. 50-293/85-27, dated November 13, 1985).

The staff has reviewed available docurents on these system redifications and finds the ?6 isol3 tion valvec acceotable. Because some of these valves are upgraded replacements o' the original gate valves that were accepted by the NRC during the licensina review whose isolation signal to close the valve remains unchanged, and some are the new solenoid valves that receive the sane isolation sional, the use of higher quality solenoid globe valvss vculd improve containment isolation dependability.

(7) The licensee proposes to list four Traveling Incore Probe (TIP) system ball valves (solenoid valves-A,B,C,D) in Table 3.7-1 These are the existinc valves in the TIP systen but have never been listed in the TS.

The licensee had previously requested to exempt these ball valves from Type C test requirements but the request was denied by the staff in a letter (NRC/FCR SER) dated July 2, 1984. The staff finds the proposed TS change acceptable since the inclusion of these valves in the table would avoid missed TS surveillance requirements on these valves.

(8) The license 2 proposes to add two vacuum breaker isolation valves (MO-2301-33/34) to the table to reflect the HPCI system modifications.

The vacuum breaker modification was recommended by General Electric Company (gel for all BWR plants (SIL No. 30, October 31, 1973), and has been the sub,iect of NRC safety system functional inspection report 50-293/85-30, dated January 28, 1986 which identified tha need for this modification.

The system isolation loaic was recommended by GE in Study EDE DRF #E41-00018-3, dated October 31, 1986, and is similar to the systens at other BWR olants. The proposed vacuum relief line and valves were approved by GE (GE letter G-HK-6-100, dated April 9, 1986). The two new motor operated containment isolation valves are normally open and will close within 30 seconds upon receiving a Group 7 isolation sianal.

The licensee stated that the closure time was assigned in considering line

size, class of the valve, and comparison with similar valves. Reopening the valve after isolation will reauire operator action from the control room. The staff has reviewed the available infornation on the vacuum breaker isolation valves and finds that the desian of these valves meets the reouirements of General Design Criterion (GDC) 55 and SRP Section 6.2.4. As required by GDC 55, these valves are both automatic isolation valves, and are located just outside containment. They reet the instrumentation, control, environmental, seismic and quality criteria appropriate to containment isolation valves. Therefore, these valves are acceptable.

(9) The licensee proposes to remove the two HPCI torus suction isolation valves (f10-2301-35/36) from Table 3.7-1 because the line they isolate terminates below the free water surface of the suppression pooi and will remain so throughout the duration cf any accident. The staff previously approved the licensee's reouest to exempt these valves from Type C testina (NRC letter of April 28, 1981).

Consecuentiv, the sta'f finds the proposed deleting of the HPCI torus suction isoletion valves from the table acceptable.

(10) The licensee proposes to modify the notes of the table to separate Grcup 1 isolation condition 5 (main steam line low pressure or reactor vessel high water level) into condition 5 (main stean line low pressure) and condition 6 (reactor high water level).

The staff finds that the proposed change (into cenitions 5 and 6) is editorial to avoid misinterpretation of Grcup 1 isolation signal, and is acceptable.

(11) The licensee proposes to modify the notes by adding Group 7 isolation condition (high drywel' pressure and low reactor pressure).

The added Group 7 isolation cord 1 tion is due to the HPCI vacuum breaker nodification, which has been addressed in Section 2.3 and 2.6.(8) of this safety evaluation. Therefore, the proposed Group 7 isolation condition is acceptable.

(12) The licensee proposes to add footnotes No. 1 thru No. 6 at the end of the table.

These added footnotes are for clarity of the table, and therefore, are acceptable.

2.7

SUMMARY

The staff has completed its review of the licensee proposed TS chanaes pertainina to containment systems.

In the updated submittal, the licensee has revised or reinstated certain items in response to staff questions made during this review.

Based on the review of the licensee's submittals and supporting documents, the staff has concluded that the proposed TS chances are acceptable.

3.0 ENVIRONMENTAL CONSIDERATI0fS This anendrent involves a change in the installation or use of facility cenpanents located within the restricted area es defined in 10 CFR Part 20 The sta#f has determined that the amendment involves no signficant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no sianificant increase in

individual or cumulative occupational radiation exposure.

The Commission has previously published a proposed findine that the anendment invclves no significant hazards consideration and there has been no public comment on such findino. Accordingly, the amendment neets the eli for categorical exclusion set forth in 10 CFR 451.22(c)gibility criteria (9).

Pursuant to 10 CFR 451.22(b), no environnental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

4.0 CONCLUSION

We have 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 nanner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the common de'ense and security or to the health and safaty of the public.

Principal Contributor:

J. Guo Dated: Jan'>ary 21, 1988 Y

AMENDMENT NO 113 TO FACILITY OPERATING LICENSE DPR-3F PIL GR U' NUCLEAR P01'ER STATION 9:STRIBilTION: w/ enclosures:

Docket No. 50 793 k NRC PDR Local PDR NSIC PDI-3 r/f PDI-3 A/D RIfessman FRushbrook OGC-Bethesda TRarnhart (4)

FJordan DHaaan LHarnor BGrimer ACRS (10)

EButcher W. lone s OPA LFM8 NThoreson SVarga BRoger JCraig JGuo, SPLB - P-932 RBlough, RI JJOVCe WHodaes RLasky