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Application for Amend to License DPR-35,changing TS Re Reactivity Control by Incorporating Operating Requirements That Are Consistent with NEDO-21231, Banked Position Withdrawal Sequence
	ML20196D007
Person / Time
Site:	Pilgrim
Issue date:	06/16/1999
From:	Ted Sullivan; BOSTON EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196D012	List: ML20196D007; ML20196D024;
References
	BECO-2.99.061, NUDOCS 9906240173
	Download: ML20196D007 (8)
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1 10CFR50.90 9 Boston Edison A S C C E N E' R G Y C O M PA N Y June 16, 1999 T.A. Sullivan BECo Ltr. #2.99061 Vice President Nuclear and Station Director U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Docket No. 50-293 License No. DPR-35 Proposed Technical Soecification Chance in accordance with the requirements of 10CFR50.90, Boston Edison Company proposes changes to the Pilgrim Station Technical Specifications regarding reactivity control. These proposed changes incorporate the operating requirements that are consistent with NEDO-21231, " Banked Position Withdrawal Sequence," January 1977. This document is the design document for the current Pilgrim reactor core design process. This submittal includes changes to the control rod worth limits discussed in License Event Report (LER) 98-006-00 dated April 30,1998 (BECo letter 2.98.059), and its supplement LER 98-006-01 dated August 27,1998 (BECo letter 2.98.112).

The attachments to this letter include mark-ups of the current Technical Specification pages, discussions of the changes to the Technical Specifications, No Significant Hazards Considerations, and proposed final Technical Specification pages. These proposed changes have been reviewed by the Operations Review Committee and the station Nuclear Safety Review and Audit Committee.

Should you have any questions regarding this submittal, please contact Steve Brennion at 508-830-8674 or Marie Lenhart at 508-830-7937.

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'T. A. Sullivan TAS\MTL\techspec\reactts Commonwealth of Massachusetts)

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Then personally appeared before me, T. A. Sullivan, who being duly sworn, did state that he is Vice President - Nuclear of Boston Edison Company and that he is duly authorized to execute k !

and file the submittal contained herein in the name end on behalf of Boston Edison Company and that the statements in said submittal are true to le best of his knowledge and belief, My commission expires:js/im/thMho t- mb 6 d > .4 i

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I PILGRIM STATION Pr: posed Technical Specification Ch nge Page 2 Attachment A: Description of Proposed Changes Attachment B: Markups of Current Technical Specification Pages Attachment C: Discussion of Changes Attachment D: No Significant Hazards Discussion

' Attachment E: Proposed Final Technical Specification Pages and Bases cc:

Mr. Alan B. Wang, Project Manager Mr. Peter LaPorte, Director Project Directorate 1-3 Massachusetts Emergency Management Agency Office of Nuclear Reactor Regulation Office of Emergency Preparedness Mail Stop: OWFN 14B20 400 Worcester Road U. S. Nuclear Regulatory Commission P.O. Box 1495 1 White Flint North Framingham, MA 01701-0317 11555 Rockville Pike Rockville, MD ' 20852 l

U.S. Nuclear Regulatory Commission Mr. Jim Muckerheide l Region 1 400 Worcester Road 475 Allendale Road P.O. Box 1496 King of Prussia, PA 19406 Framingham, MA 01701-0317 Senior Resident inspector Mr. Robert Hallisey, Director !

Pi!qrim Nuclear Power Station Radiation Control Program Massachusetts Department of Public Health 305 South Street Jamaica Plain, MA 02130

Attachment A Summary of Proposed Changes

PILGRIM STATION

' Proposed Technical Specification Change Attachment A Summary of Proposed Changes Page 1 Summary of Chanaes Substantive changes proposed are:

. Action statements in Current Technical Specifications (CTS) in section require Cold Shutdown in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . These have been changed to Hot Shutdown in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or immediate shutdown (Mode Switch to Shutdown).

. CTS allow control rods that are fully inserted and disarmed not to be considered inoperable.

This allowance has been removed and these rods will be considered inoperable.

. The proposed specifications will allow determination of control rod position by means other ;

than the indicators on panel 905 (e.g., plant computer or moving the rod). i

. The proposed change reduces the time allowed for a loss of position indication and requires a rod to be declared inoperable if its position cannot be determined. !

. CTS require inoperable rods be separated by one operable rod at all times. The proposed TS j require inoperable rods to be separated by two operable rods only when reactor thermal power (RTP) is $20%.

. CTS allow a control rod with a scram time greater than that allowed to remain in position. The proposed change requires the rod to be inserted, disarmed, and declared inoperable within four hours.

. The proposed change adds a requirement that there shall be no more than three inoperable control rods in any one BPWS group of rods. 1

. CTS require rod coupling be certified when the rod is fully withdrawn the first time after each l refueling outage. The proposed TS requires this coupling check each time the rod is fully l withdrawn.

. The CTS requirement to verify maximum rod worth when RTP is 520% is proposed to be replaced by actions that ensure that when RTP is 520%, control rods are in compliance with BPWS.

. This proposed change adds a new surveillance requirement verifying the rod worth minimizer is not bypassed when the RTP is 520% every 24 months.

. CTS allow an unspecified number of control rod accumulators to be inoperable under certain conditions. The proposed change will impose more restrictive requirements. )

. CTS require the reactor to be shutdown if the reactivity anomaly limit is exceeded without j specifying a completion time. The proposed TS require a completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach ;

HOT SHUTDOWN. l

. CTS require the reactor to be in COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if any of the scram

- discharge volume drain or vent valves are made or found to be inoperable. The proposed change will reduce this time to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach HOT SHUTDOWN.

. CTS provide a discussion of how to determine a maximum scram insertion time. The proposed change relocates the details of the methods for timing control rods to the BASES.

. CTS require control rods that cannot be moved with control rod drive or scram pressure to be :

considered inoperable and the reactor be brought to a shutdown condition within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months unless the cause is determined to not be a failed collet housing. The proposed change will allow continued operation with one withdrawn control rod that cannot be moved with control rod drive or scram pressure, j

i PILGRIM STATION Proposed Technical Specification Change Attachment A Summary of Proposed Changes Page 2 CTS require all partially or fully withdrawn control rods be exercised at least once per week.

The proposed TS require control rods be inserted in lieu of the CTS requirement for

" exercising" The proposed TS will also differentiate between fully and partially withdravvn rods, i Fully withdrawn rods will be inserted one notch once per 31 days. Partially withdrawn rods will be inserted one notch once per 31 days.

. The CTS requirement to observe a discernible response of the nuclear instrumentation when a control rod is withdrawn the first time following a refueling or after maintenance is being deleted.

. CTS require observation that a control rod does not go to the overtravel position after maintenance without specifying the type of maintenance. The proposed TS will require observing the control rod does not go to the overtravel position after maintenance that could affect coupling integrity.

CTS does not allow control rod movement when the reactor is below 20% rated power except to shutdown the reactor, unless the Rod Worth Minimizer is operable. The proposed TS will l continue to require operability of the RWM; however, the requirements on control rod movement are being relaxed provided a second licensed operator or other qualified member of l the technical staff verifies movement of the control rod. l

. CTS require verifying the control rod sequence input to the RWM computer prior to control rod withdrawal for startup and prior to insertion to reduce power below 20%. The proposed TS will require this verification only once following loading the control rod sequence into the RWM computer.

. CTS require verification of core reactivity when the mode switch is in STARTUP and RUN and when the reactor is greater than 1% design power. This requirement is being revised to be performed only when the mode switch is in RUN.

The following matrix shows where each current Technical Specifications will be located in the proposed Technical Specifications.

CURRENT PNPS TECHNICAL SPECIFICATIONS i , ' REVISED PNPS TECHNICAL SPECIFICATIONS 3/4.3 Reactivity Control 3/4.3 REACTIVITY CONTROL 3 3.A.1 Reactivity Margin - core Loading LCO 3 3.A.1 Reactivity Margin - core Loading

3. 3.F 3.3.A-o do not apply when there is no fuel in vessel Applicability At all times when there is fuel in the reactor vessel 3.3.F Requirements of Specifications 3.3.A-D not met Action "A" Requirements of Lc0 33.A.1 not met Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RA "A.1" Hot Shutdown 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4.3.A.1 Demonstrate Margin SR 4.3.A.1 Demonstrate Margin 3.3 A.2 Reactivity Margin - Inoperable control rods Lco 3.3.B.1 control Rod OPERABILITY -

3.3.F 3.3.A-D do not apply when there is no fuel in vessel Applicability RUN AND ST ARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned 3.3.A.2.a STUCK Roo Action "A" one withdrawn rod stuck disarm. ensure separation, test all other rods Action "B" Two or more withdrawn rods stuck -

Hot Shutdown 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

PILGRIM STATION Proposed Technical Specification Change Attachment A Summary of Proposed Changes Page 3 MATRIX (continued)

' CURRENT PNPS TECHNICAL SPECIFICATIONS REVISED PNPS TECHNICAL SPECIFICATIONS '

3.3.A.2.b electncally disarm in position that meets LCO 3 3 A.1 Action "C" one or more rod' inoperable from reasons other than A or B

- fully insert and 'isarm 3 3 A 2.c Fully inserted & electncally disarmed-not inoperable inoperable Action "D" Two or inore rods not in compliance with BPWS Action "E" one or more groups with 4 or more inoperable control rods 3 3 A.2.d scram times >7 sec SR 4.3 B.1.4 Venfy Scram Times < 7 sec 3.3.A.2.e max # inoperable rods (8) Action "F" 9 or more snoperable rods !

13F Requirements of Specifications 3.3 A-D not met Action "F" Required actions and completion times j of A. C D, and E not met i Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RA "A.1" Hot Shutdown 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4 3.A.2 Control rod exercise SR 4.3 B.1.1 Control rod exercise (fully withdrawn)

SR 4.3 B.1.2 Control rod exercise (partially withdrawn) 3 3 B.1 Control Rod coupling SR 4.3 B.1.3 Venfy rod does not go to overtravel 4.3 B.1.b coupling integnty - overtravel SR 4 3.B.1.3 Venfy rod does not go to overtravel Tables 3.2.F. Control rod position SR 4.3 B.1.5 Determine position of each control rod 4 2.F 3 3 B.2 housing support LCO 3.3 8 2 housing support 3.3 F Requirements of Specifications 3.3.A-D not met Action "A" Requirements of LCO 3.3.B.2 not met l Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RA "A.1" Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 4.3.B.2 housing support inspection SR 4.3 8 2 housing support inspection 3 3.B 3.a Rod Worth Minimizer (RWM) LCO 3.3.F Rod Worth Minimizer (RWM) 3 3 B 3 b (1) rod worth below 20% design power LCO 3.3 H Compliance with BPWS l

3.3.B.3 b.(2) rod worth above 20% design power NA 4.3 8 3.a sequence input to RWM SR 4.3 F.3 Sequence input to RWM l 4.3 B.3 b RWM diagnostic test SR 4.3.F.1 Instrument Functional 4.3 B.3.c selection error annunciation test 4.3.B.3 d RWM rod block function

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SR 4.3 F.2 Venfy RWM not bypassed 5 20%

3.3 B.4 Minimum SRM count rate LCO 3.3.B.3 Minimum SRM count rate 3.3 F 3.3.A-D do not apply when there is no fuel in vessel Applicability Pnor to withdrawing control rods for startup Requirements of Specifications 3.3.A-D not met Action "A" LCO 3.3 B.3 not met Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RA *A.1" Place mode switch in shutdown immediately 4.3.B 4 SRM observed count rate SR 4.3.B.3 SRM observed count rate 3.3.C Scram insertion Times LCO 3.3. C Control Rod Scram Times 3.3.C.1 Average Scram insertion Time LCO 3.3. C.1 Average Scrarr Insertion Time 3.3.C.2 Average Scram insertion Time (3 fastest dnves) LCO 3.3. C.2 Average Scram insertion Time (3 fastest dnves) 3.3.C.3 Max scram time SR 4.3 B.1.4 Venfy scram time $ 7 seconds 3.3.F 3.3.A-D do not apply when there is no fuel in vessel Applicability RUN AND STARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned Requirements of Specifications 3.3.A-D not met Action "A" Requirements not met Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RA "A.1" Hot Shutdown 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

PILGRIM STATION Proposed Technical Specification Change l Attachment A Summary of Proposed Changes Page 4 MATRIX (continued)

' CURRENT PNPS TECHNICAL SPECIFICATIONS

' REVISED PNPS TECHNICAL SPECIFICATIONS 4 3 C.1 Scram testing following extended outage SR 4.3.C.1 Each Control rod Scram time within hmits l

4.3.C.2 scram testing 10% every 120 days SR 4.3 C.2 Representative sample of Scram times within hmits 3.3 D Control Rod Accumulators LCO 3.3 D Control Rod Scram Accumulators 3.3.F 3.3.A D do not apply when there is no fuel in vessel Applicabihty RUN AND sTARTUP MODES; REFUEL MODE when the reactor vessel head is fully tensioned 3.3 D a rod accumulator may be inoperable provided Action "A" Accumulator (s) Inoperable 1950 psg Action "B" Accumulator (s) inoperable > 950 psg or < 20% RTP Action "C" Two or more Accumulator inoperable 3 950 psg with low charging press Action "D" Two or more Accumulator inoperable < 950 psg with low charging press Action "E" Requirements of C or D not met 4.3.D Control Rod Accumulator alarm check SR 4.3.D Control Rod Accumulator alarm check 3.3.E Reactivity Anomahes LCO 3.3.5 Reactivity Anomahes Apphcabikty Dunng power operations Apphcability RUN MODE Action if hmit exceeded, shutdown Action "A" Required action not met RA "A.1" Hot shutdown 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4.3 E Cntical to expected Rod Companson SR 4.3.E Venfy core reactivity difference 3.3. F failure to meet conditions A-D incorporated into individual LCO(s) or replaced with more appropriate actions 3.3 G Scram Discharge Volume 3.3.G Scram Discharge Volume (SDV) Vent and Drain Valves 3.3 G.1 Vent and Drain Valve OPERABILITY LCO 3.3.G Scram Discharge Volume (SDV) Vent and Drain Valves Apphcabikty When ever there is more than one control rod Applicabikty RUN AND STARTUP MODES; REFUEL MODE when the withdrawn reactor vessel head is fully tensioned 3.3.G.2 Actions for inoperable vent and drain valve Action "A" One or More vent or drain hnes valve (S) inoperable Cold Shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RA "A.1" Hot Shutdown 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4.3.G,1.a Open vent & drain valves monthly SR 4.3.G.1 Venfy open 4.3.G.1.b vent & drain valves IST requirements SR 4.3.G.2 Cycle each valve 4.3.G 2 a Venfy vent & drain valves close after scram SR 4.3.G.3 Venfy vent & drain valves close after scram

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4 3.G.2.b Venfy vent & drain vatves open after scram reset SR 4.3.G.3 Venfy vent & drain valves open after scram reset Discussion:

On March 31,1998, PNPS personnel discovered the control rod withdrawal sequence developed by General Electric (GE) did not explicitly verify compliance with Pilgrim's Technical Specification (TS) limit on control rod worth (TS 3.3.B.3.b.1 and 3.3.B.3.b.2).

Pilgrim TS 3.3.B.3.b.1 limits control rod worth to less than 0.01 delta K when the reactor is below 20% power to ensure fuel enthalpy is less than 280 cal /g following a postulated rod drop accident.

GE's control rod withdrawal sequence for Pilgrim is also designed to limit fuel enthalpy to

<280 cal /g by utilizing the Banked Position Withdrawal Sequence (BPWS) below 20% power

PILGRIM STATION Proposed Technical Specification Change Attachment A Summary of Proposed Changes Page 5 (NEDO-21231). The GE analysis does not verify, however, the withdrawal sequences also satisfy Pilgrim's TS requirements for maximum control rod worth. Thus, compliance with the BPWS ensures compliance with the 280 cal /g but not with the 0.01 delta K limit.

Pilgrim TS 3.3.B.3.b.2 limits control rod worth of any control rod to less than 0.02 delta K when the reactor is above 20% power to ensure fuel enthalpy is less than 280 cal /g following a rod drop accident. Like TS 3.3.B.3.b.1, the GE analysis does not verify that the withdrawal sequences satisfy Pilgrim's TS requirements for maximum control rod worth because, at >20% rated power, inherent feedback mechanisms, primarily in the form of steam voids, limit control rod worth to such an extent that the control rod drop accident (CRDA) need not be considered.

This was previously reported to the NRC in License Event Report (LER) 98-006-00 and its supplement LER 98-006-01. Subsequent to these LERs, it was determined that modifying the Pilgrim Technical Specifications only for control rod worth would not meet the spirit and intent of the General Electric NEDO-21231, " Banked Position Withdrawal Sequence," January 1977, Therefore, the scope of this proposed Technical Specification has been expanded from that discussed in the LER.

References:

The following documents are referenced in this submittal. They are not included with this submittal because they have been previously docketed with the NRC.

NEDE-24011-P-A-13-US, " General Electric Application for Reload Fuel", Supplement for United States, August 1996 NEDO-21231, " Banked Position Withdrawal Sequence," January 1977.

NEDO-21778 A, " Transient Pressure Rises Affected Fracture Toughness Requirements for

Boiling Water Reactors," December 1978.

NRC SER, " Acceptance of Referencing of Licensing Topical Report NEDE-24011-P-A,"

" General Electric Standard Application for Reactor Fuel, Revision 8, Amendment 17,"

December 27,1987.

NUREG-0803," Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping," August 1981.

Schedule of Chanoe:

Expeditious review and approval of this proposed Technical Specification change is requested. A 60 day implementation period is also requested to allow for training of the station operators and revisions to affected procedures.

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ML20196D007

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