ML20210N884

Application for Rev 1 to Proposed Amend 126 to License DPR-54,changing Tech Specs 1.2.6 & 3.8.4 Re Boron Concentration & Shutdown Margin,Respectively,In Response to Inconsistencies Noted in Insp Rept 50-312/85-11

ML20210N884
Person / Time
Site:	Rancho Seco
Issue date:	04/30/1986
From:	Reinaldo Rodriguez SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML20210N890	List: ML20210N884 ML20210N892
References
RJR-86-174, NUDOCS 8605050303
Download: ML20210N884 (5)

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l esuun SACRAMENTO MUNICIPAL UTILITY DISTRICT 6201 S Sticet. P O Bom 15830, Sac ramento CA 98)H521830.191f,1452 3211 AN l.1 E C T HIC M S i f f.1 St HVINt i I t u HI AH I til ( Al li ' HiNI A RJR 86-174 April 30, 1986 DIRECTOR OF NUCLEAR REAC10R REGULATION ATTENTION FRANK J MIRAGLIA DIRECTOR PWR-B DIVISION U S NUCLEAR REGULATORY COMMISSION WASHINGTON DC 20555 DOCKET NO. 50-312 LICENSE N0. DPR-54 PROPOSED AMENDMFNT N0. 126, REV. 1 In accordance with 10CFR50.90, the Sacramento Municipal Utility District proposes to amend its Operating License DPR-54 for Rancho Seco Nuclear Generating Station Unit No. 1.

Proposed Amendment No. 126, Rev. 1, which supersedes Proposed Amendment No. 126, submitted 3/18/85, consists of administrative changes that cor-rect inconsistencies in the Technical Specifications noted by in-house reviews, and an NRC inspection (Inspection Report No. 50-312/85-11). De-tails of these inconsistencies and their corrections are discussed in Attachments I, II and III, omprising the Safety Analysis, "No Significant Hazards" Evaluation and the C'scription of Proposed Changes, respectively.

Pursuant to 10CFR50.91(b)(1), the Radiological Health Branch of the Califor-nia State Department of Health Services has been informed of this proposed amendment by mailed copy of this submittal.

The District has determined that no license fees are required with this revision since a check for $150.00 was sent to the Commission with the initial submittal of Proposed Amendment No. 126.

Should you require any further information with respect to this revised proposed amendment, please contact Mr. Ron W. Colombo at Rancho Seco Nuglear3 G enerating Station Unit 1.

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ATTACHMENT I SAFETY ANALYSIS Proposed Amendment No. 126, Rev. 1, consists of changes to the Rancho Seco Technical Specifications in three general areas as discussed below:

1. The first group of changes (to Specifications 1.2.6, 3.8.4 and the 3.8 Bases, respectively) are being made in response to NRC comments presented in Inspection Report 85-11, with respect to the initial submittal of Pro-posed Amendment No. 126. Specifically, the comments and the changes being proposed to resolve these comments are:

a. Technical Specification 3.8 assumes tne refueling boron con-centration will be sufficient to maintain a keff < 0.95. This assumption was identified in the Basis for the Technical Speci-fication but not in Technical Specification 3.8.3 itself, as it is the Standard Babcock and Wilcox (B&W) Technical Specifications.

b. The required boron concentration of 1936 ppm identified in the LER differed from the 1974 ppm concentration identified in Proposed Amendment No. 126 and did not appear to incorporate a 50 ppm conservative margin as did the Standard B&W Technical Specifications.

c. The one percent shutdown margin identified in Rancho Seco Technical Specification 1.2.6, which defines " Refueling Shutdown" is not con-sistent with the five percent shutdown margin assumed by Technical Specification 3.8.3.

The required boron concentration in Specification 3.8.4 is changed to

> 1800 ppm, but with the provision, "or at a concentration to ensure a lieff no greater than 0.95, whichever is the more restrictive." The wording of the definition in Specification 1.2.6 and in the 3.8 Bases are revised accordingly.

The value of > 1800 ppm, along with the stipulated < 0.95 keff is con-sidered adequate during all fuel loading and refueling conditions to ensure core subcriticality, and eliminates the need of amending boron concentration with each fuel cycle.

In revising Specification 1.2.6 and the 3.8 Bases, the words "all rods removed" have been deleted. Rod configuration is considered extraneous to the revised requirements of Specification 3.8.4 which assures core subcriticality in all fuel loading and refueling conditions.

The District has reviewed the corresponding Standard Technical Specifi-cations (STS) and chosen not to include in the Rancho Seco Technical Specifications the "added conservative allowance for uncertainties."

It is the opinion of the District that technical specifications should  ;

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ATTACHMENT 1 (Continued) Page 2 provide limits beyond which an " Action" is required, and that conserva-tive allowances are more appropriate to administrative controls. An example of this is presently in Operating Procedure B-8, Paragraph 3.30, which states:

At least once each day that fuel is handled, the Fuel Transfer Canal boron concentration shall be Ctermined. Minimum concentration is 2,025 ppmB, to assure that 1,974 ppmB, the level of TS 3.8.4, is not violated.

The above changes are responses to NRC's comments in Inspection Report 85-11, Item B.a. through B.c., and are considered to be in accord with conservative reactivity control. Therefore, the above described pro-posed changes are judged to have no adverse effect on plant safety.

2. The second group of proposed changes are to Table 4.1-3 as explained below:

a. Amendment No. 53 revised the sampling requirements for the Waste Gas Decay Tank, Auxiliary Building Stack and Purge Vent by their incorporation in the standardized Radiological Effluent Technical Specifications. The above three items (Items 7, 8 and 10, respect-ively) should have be.en deleted from Table 4.1-3 at that time, but through oversight were not. Proposed Amendment No. 126, Rev. 1, deletes these items, and renumbers the remaining items and footnote as a result.

b. Sampling of the concentrated boric acid tank is not required during cold shutdown because the tank is not used under that plant condition.

Accordingly, Footnote 5 is added to Table 4.1-3 which states: "Not performed during cold shutdown except during refueling operations."

This proposed change is considered to be purely administrative and thus judged to have no effect on plant safety.

c. The List of Tables is revised by this proposed amendment by the addition of Tables 3.7-1 and 3.7-2, and the deletions of Tables 4.10-1 and 4.10-2. Previous amendments resulted in the above described additions and deletions of the actual tables, but through oversight, the corresponding changes to the List of Tables were not made. These proposed changes are also considered to be purely admin-istrative and therefore also judged to have no effect on plant safety.

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ATTACHMENT II "N0 SIGNIFICANT HAZARDS" EVALUATION Proposed Amendment No. 126, Rev. 1, consists of revisions to the reactivity control requirements for fuel handling and refueling as specified in Specifi-cations 1.2.6, 3.8.4 and in the 3.8 Bases. These changes are in response to NRC comments made in Inspection Report 85-11 with respect to the original submittal of Proposed Amendment No. 126 on March 18, 1985. In addition, revisions are made to the List of Tables and to Table 4.1-3 which resulted from previous amendments to specifications but, through oversight, not to the List of Tables or isble 4.1-3.

The District has reviewed these changes against the three factors in 10CFR50.92 for determining that no significant hazards are involved. As specifically discussed below, it has been concluded that *de proposed changes would not:

a. Involve a significant increase in the probability or consequences of an accident previously evaluated; or

b. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

c. Involve a significant reduction in a margin of safety.

Specifications 1.2.6, 3.8.4 and the Bases for Specification 3.8 presently state the reactivity control r(quirements for fuel handling or refueling, respectively as:

a. At least 1% A k/k even with all rods removed;

b. Boron concentration of 1850 ppm.

c. keff of 0.95 with all rods removed, and boron concentration of 1800 ppm, whichever is the more restrictive.

The proposed changes delete from the 3.8 Bases the wording "with all rods removed", and revises Specifications 1.2.6 and 3.8.4 with wording consistent with the remaining reac+1vity control requirements of the 3.8 Bases.

Except for the removal of the words "with all rods removed", the above prn-posed changes simply bring Specifications 1.2.6 and 3.8.4 into consistency with the 3.8 Bases. The District considers rod configuration extraneous to the more restrictive of boron concentration or keff. Accordingly, the District has determined that the proposed changes do not increase the probability or consequences of an accident; do not create the possibility of a new or different kind of accident from any previously evaluated; or effect any margin of safety.

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ATTACHMENT II (Continued) Page 2 The proposed changes to the List of Tables involve the addition of two tables (3.7-1 and 3.7-2), and the deletion of two tables (4.10-1 and 4.10-2). The actual additions and deletions of these tables occurred through previous amendments to the Technical Specifications, but through oversights, the List of Tables was not amended concurrently.

Similarly, the deletions made from Table 4.1-3 of the Waste Gas Tank, Auxiliary Building Stack and Purge Vent are the result of the sampling re-quirement of these components being deleted by Amendment No. 53 by their incorporation in the standardized Radiological Effluent Technical Specifi-cations. Again, through an oversight, these components were not removed from Table 4.1-3 at that time.

The final proposed change is the addition of Footnote 5 to Table 4.1-3, which excludes sampling requirements of the concentrated boric a-id tank during cold shutdown except durirg refueling operations. This ciange is in accord with the actual sampling procedure established by admiaistrative control.

The District has evaluated the above changes to the List of Tables and to Table 4.3-1, and concluded that they are purely administrative changes which do not increase the probability or consequences of an accident previously evaluated; do not create the possibility of a new or different kind of accident from any previously evaluated; or effect in any way the margins of safety.

Based on the considerations discussed above, the District further concluded that: (1) There is reasonable assurance that the health and safety of the Mblic will not be endangered by operation of the plant in the proposed manner, 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 defense and security or to the health and safety of the public.