ML20203D485

Application for Amend to License DPR-35,to Change TS 3/4.5.B & Bases to Incorporate Ultimate Heat Sink Temperature 75 F, as Required by Amend 173.Request Fulfills Commitment to Submit TS Amend for UHS Temperature by First Quarter 1998

ML20203D485
Person / Time
Site:	Pilgrim
Issue date:	02/20/1998
From:	Olivier L BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20203D488	List: ML20203D485 ML20203D498
References
BECO-2.98.017, NUDOCS 9802260077
Download: ML20203D485 (6)

Text

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e g 10CFR50.90 Boston Edloon l Pilgrim Nuclear Power Station i 1

Rocky Hill Road Plymouth, Massachusotts 02360

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L.J. Olivier Vee President Nuclear and Station Director February 20, 1998 BECo 2.98. 017 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License DPR 35 Docket 50-293 Etoposed Chanoes to the Pilorim Nuclear Power Station Containment Coolino and Ultimate Heat Sink Technical Specifications

References:

1. Pilgrim Nuclear Power Station Operating License Amendment No.173, Conceming Ultimate Heat Sink Inlet Temperature, dated July 3, 1997.

2. Boston Edison - Pilgrim Nuclear Power Station Dose Reduction Strategy, Rev. O, dated September 11,1997.

Boston Edison Company hereby proposes changes to Pilgrim Nuclear Power Station Technical Specification (TS) 3/4.5.B and its Bases to incorporate the ultimate heat sink (UHS) temperature of 75 F, as required by Amendment No.173. This request fulfills our commitment to submit a technical specification amendment for the UHS temperature by the first quarter of 1998. Also, the introduction of a UHS temperature restriction requires new specifications, actions, and surveillances for the salt service water system.

Concurrently, we are proposing to leplace existing Specification 3.5.8 " Containment Cooling System" with new Specifications 3/4.5.B.1 " Residual Heat Removal (RHR) Suppression Pool Cooling", 3/4.5.B.2 " Residual Heat Removal (RHR) Containment Spray", 3/4.5.B.3 " Reactor Building Closed Cooling Water (RBCCW) System", and 3/4.5.B.4 " Salt Service Water (SSW)

System and Ultimate Heat Sink (UHS)". The proposed new subsections will more clearly define the various subsystems.that comprise the containment cooling system and the operating states in which they are applicable. The proposed changes also provide clarity with respect to f the application of limiting-conditions of operation (LCOs), actions, completion times, and j surveillances for the containment cooling subsystems. i

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Boston Edison Company Page 2/3 The proposed changes are presented in detail in the enclosed attachments. The copy of this letter sent to Alan Wang, the Pilgrim Project Manager, includes a computer disk with the files for Attachments B & C in Word Perfect format.

We have implemented a PNPS Dose Reduction Strategy (Ref. 2) that demonstrates continued compliance with 10 CFR 2R .Our dose reduction strategy calls for on-line chemical-decontamination of the RHR system to reduce radiological exposure during refueling outages and routine on-line maintenance activities in RHR quadrants. Decontamination of the RHR system would save approximately 40 man rem during refueling outages and 10 man rem per year for routine on lire maintenance activities. Decontamination scope of work is scheduled ,

for the first half of 1998. Decontamination of the RHR system requires isolation of RHR containment cooling subsystems and completion of the decontamination activities within the allowed outage times for the RHR subsystems. The existing specifications do not provide RHR containment cooling subsystem specific LCOs, actions, and surveillances, whereas the proposed specifications do. Accordingly, we request NRC approval of the proposed technical specification amendment in an expeditious manner to facilitate the decontamination of RHR 4- loops.-

Should you'have any questions regarding this submittal, please contact Walter Lobo at 508-830-7940.

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l J. Olivier \,t1  :.

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Then personally appeared before me, Leon J. Olivier, who being duly sworn, did state that he ,,

is Vice President - Nuclear / Station Director of Boston Edison Company and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My commission expires: OM0 /979 ~

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' DATE NOTARY PUBLIC l

Enclosure - Summary of Proposed Changes -

Attachment A - Markup of Cerrent Technical Specifications Attachment B Discussion of Changes Attachment C - Determination of No Significant Hazards Consideration Attachment D - Revised Technical Specifications Attachment E Revised Bases

' 4 Boston Edison Company "

Page 3/3

' cc: Mr. Alan Wang,: Project Manager Mr. Robert M.' Hallisey, Director Project Directorate 13 .

Radiation Control Program

- Office of Nuclear Reactor Regulation Center for Communicable Diseases  ;

Mail Stop: OWFN 14B2 Mass. Dept. of Public Health. i U. S. Nuclear Regulatory Commission 305 South Street -

1 White Flint North 11555 Jamaica Plain, MA 02130 =

Rockville Pike Rockville, MD 20852  ;

U.S. Nuclear Regulatory Commission Mr. Jim Muckerheide Mass. Emergency Management Agency

Region I '

- 475 Allendale Road 400 Worcester Road King of Prussia, PA 19406 P.O. Box 1496 Framingham, MA 01701 Senior NRC Resident inspector Mr. Peter LaPorte, Director Pilgrim Nuclear Power Station Mass Emergency Management Agency .

i 400 Worcester Road P.O. Box 1496 r Framingham, MA 01701 4

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ENCLOSURE Summary of Proposed Chances PROPOSED CHANGES Boston Edison Company (BECo) proposes changes to Technical Specification 3/4.5.8

" Containment Cooling Systems" to comply with Amendment No.173 that requires incorporating a UHS temperature restriction of 75*F. In addition, TS 3/4.5.8 is revised to provide specifications for containment cooling subsystems: residual heat removal (RHR) suppression rool cooling and containment spray, reactor building closed cooling water (RBCCW), and salt service water (SSW) systems. Accordingly, Specification 3/4.5.8 is completely revised. The current Specifications 3.5.B.1, 2, and 3 are replaced by adding new specifications for containment cooling subsystem as follows:

New 3.5.B.1 - Residual Heat Removal (RHR) Suppression Pool Cooling New 3.5.B.2 - Residual Heat Removal (RHR) Containment Spray New 3.5.B.3 Reactor Building Closed Cooling Water (RBCCW) System New 3.5.B.4 Salt Service Water (SSW) System and Ultimate Heat Sink (UHS)

Collectively, the above proposed changes provide specifications for the containment cooling system functions as before, but now, include the availability and operability of supporting subsystem and ultimate heat sink functions. The revised subsystem level specifications add clarity to the specifications by providing LCOs, actions, completion times, and surveillances.

The Bases 83/4.5.B is revised to reflect the containment cooling subsystem specifications and Amendment No.173.

REASON FOR CHANGE License Amendment No.173 involved NRC review of the PNPS 75*F UHS temperature containment analysis. This Amendment requires the introduction of appropriate specifications, actions, completion times, and surveillances for the 75*F UHS temperature restriction. These proposed specifications fall within the scope of TS 3.5.B, " Containment Cooling Systems".

Also, TS 3.5.B does not provide specific LCOs, actions, completion times, and surveillances ,

for the RHR containment cooling subsystems. Subsystem level specifications are necessary i to provide clarity, actions, and surveillances, and to introduce a UHS temperature specification and its associated surveillances. Accordingly, we have proposed changes to TS 3/4.5.B to include specifications for each containment cooling subsystem and the UHS.

- LUSTIFICATION

1. Containment Coolina Subsystem Specifications i i

The proposed specifications 3/4.5.B.1, 2, 3, and 4 collectively provide specifications for containment cooling systems, subsystems, supporting systems, and the UHS. The proposed  !

specifications improve the existing specifications, even though overall more restrictive, by providing clarity, LCOs, actions, completion times, and surveillances. In addition to complying with Amendment No.173, the proposed changes result in technical specifications that are more readable and understandable by plant operatora and other users.

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2. Allowed Outane Timms (AOTs)

The existing AOTs from Specifications 3.5.A.4 and 3.5.8.2 are carried forward for containment cooling subsystems, supporting systems and UHS, as follows.

TS 3.5.A.4 specifies a 7-day AOT for the LPCI system provided the containment cooling system with 2 LPCI pumps is operable. This AOT forms the basis for the new specifications (3.5.B.1.A.1 and 3.5.B.2.A.1) that address RHR suppression pool cooling and containment spray functions of the containment cooling system. The same pumps are used for both LPCI and containment cooling modes of operation, whereas the piping and valve alignments are different.

The basis for the 7 day AOT, as applicable to the core cooling and other RHR functions, should be the same (i.e., desqn basis LOCA). The LPCI injection and other RHR modes of operation are designed to mitigate transients and design basis accidents, and additionally, to provide RHR shutdown cooling using the same pumps. Therefore, the selection of AOTs for RHR modes of operation should be consistent. Accordingly, we have carried forward a 7 day AOT for the RHR containment cooling functions from that which currently exists in TS 3.5.A.4 for LPCI.

The existing 3.5.8.2 specifies a 72-hour AOT (Amendment No.135) for containment cooling loops. This AOT is carried forth into the proposed new specifications (3.5.B 3.B.1 and 3.5.B.4.A.1) for RBCCW and SSW subsystems with no changes.

A new 7-day AOT is proposed in 3.5.B.3.A.1 for one required RBCCW pump inoperable. With one required RBCCW pump inoperable, the remaining pump in the affected loop is sufficient to handle the normal operation heat loads, and the reinaining OPERABLE loop is sufficient to meet the requirements of Specification 3/4.5.B.1, "RHR Suppression Pool Cooling" and 3/4.5.B.2, "RHR Containment Spray". The 7-day AOT is consistent with the AOT for one inoperable loop of suppression pool cooling or containment spray system, which follows the existing AOT in TS 3.5.A.4.

3. Cnanaes to TS Bases 83.5.B The Bases for the containment cooling system are revised to address the proposed changes and the Amendment No.173 condition for adding a UHS temperature restriction by adding functional descriptions from the FSAR.

4. Safety Assessment Amendment No.173 requires changes to the containment cooling specifications to include UHS temperature and associated surveillances applicable to UHS by introducing specifications for the salt service water system. A detailed functional analysis of the SSW system is included in the FSAR, and this proposed change is in accordance with that functional analysis. This proposed specification change is more restrictive and provides for continued safe operation of Pilgrim Station by ensuring the ultimate heat sink is available within its design bases function.

The containment cooling systems, subsystems, supporting systems and associated functions are described in the FSAR. The limiting conditions for operation of these systems are derived from the station nuclear safety analysis (FSAR, Appendix G), and a detailed functional analysis of these systems is provided in FSAR Sections 10.5,10.7 and 14.5. The existing specifications for containment cooling systems are revised by adding specifications for

- subsystems. The subsystem level specifications overall are more restrictive and provide clarity.

The new specifications are derived using design bases information and operational functions currently described in the FSAR, and assure compliance with 10 CFR 50.46 limits for design bases accident conditions. Thus, the proposed changes are within the design and licensing bases of the plant.

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O SCHEDjlLE OF CHANGEi This change, including the training of operators, will be effective within 90 days of receipt of approval from the NRC. Because this change implements the requirements of Amendment No.173 and would assist us in the chemical decontamination of RHR system to comply with 10 CFR 20, we request an expeditious review and approval of this proposed change.

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