ML20236U978

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Safety Evaluation Supporting Amend 176 to License DPR-35
ML20236U978
Person / Time
Site: Pilgrim
Issue date: 07/28/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236U976 List:
References
NUDOCS 9807310212
Download: ML20236U978 (7)
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.176 TO FACILITY OPERATING LICENSE NO. DDR-l BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION I

DOCKET NO. 50-293

1.0 INTRODUCTION

By letter dated February 20,1998, as supplemented by letter dated July 10,1998, the Boston Edison Company (BECo or the licensee) submitted a request to modify the Pilgrim Nuclear Power Station Technical Specifications (TS). The requested changes would modify the Pilgnm Nuclear Power Station TS 3/4.5.8 and its Bases to incorporate the ultimate heat sink (UHS) temperature of 75'F, as required by Amendment No.173. The introduction of a UHS temperature restriction requires new specifications, actions, and surveillance for the salt service water system. The amendment will also replace existing specification 3.5.8

i Building Closed Cooling Water (RBCCW) System", and 3/4.5.B.4

System and Ultimate Heat Sink (UHS)*. The proposed new subsections will more clearty define the various systems that comprise the containment cooling function and the operating states in which they are applicable. The proposed changes also provide clarity.th respect to the l

application of limiting conditions of operation (LCO's), actions, completion times, and surveillance for the containtnent cooling subsystems. The information dated on July 10,1998, 1,

did not affect the original no significant hazards determination. The staff has noted to the l

licensee that as part of the conversion to the improved standard TS (STS)in NUREG-1433,

" Standard Technical Specifications for General Electric (GE) BWR/4 Plants,' all sections of the TS will be reevaluated. While the staff has reviewed this amendment, it is not considered part of the conversion process to the improved STS.

I 2.0 EVALUATION l

License Amendment No.173 involved NRC review and approval of the PNPS 75 'F UHS temperature containment analysis. This amendment required BECo to add appropriate specifications, actions, completion times, and surveillance for the 75'F UHS temperature restriction. New TS 3 5.B.4, ' Salt Service Water (SSW) System and Ultimate Heat Sink (UHS)J provides the required UHS temperature TS restrictions. In addition. TS 3/4.5.B is revised to provide specifications for containment cooling subsystems: residual heat removal (RHR) suppression pool cooling and containment spray, reactor building closed cooling water (RBCCW), and salt service water (SSW) systems Accordingly, Specification 3/4.5.8 is l

completely revised The existing specifications for containment cooling subsystems are revisea l

by adding specifications for the individual subsystems. The current Spc:sfications 3.5.B.

' Containment Cooling Systeia,"is replaced by adding new specifications for the containment cooling subsystems as follows:

New 3.5 B.1 - Residual Heat Removal (RHR) Suppression Pool Cooling New 3.5.8 2 Residual Heat Removal (RHR) Containment Spray New 3.5.8 3 - Reactor Building Closed Cooling Water (RBCCW) System New 3 5.B 4 Salt Service Water (SSW) System and Ultimate Heat Sink (UHS) 9807310212 980728 PDR ADOCK 05000293 P

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2 The proposed specifications 3/4.5.B.1,2,3, and 4 collectively provide specifications for containment cooling systems, subsystems, support systems, and the UHS. The proposed specifications improve the existing specifications, and overall, are more restrictive, by providing clarity, LCOs, actions, completion times, and surveillance. In addition to incorporating the UHS temperature of 75' F, as required by Amendment No.173, the proposed changes result in technical specifications that are more readable and understandable to plant operators and more accurately reflect the plant design. Below is a discussion of the changes.

6DENISTRATIVE OR EDITORIAL CHANGES Section 3.5 These proposed changes include reformatting (font and style changes) and repagination only. No technical changes (either actual or interpretational) to the TS were made. The staff has reviewed these changes and agrees that they are editorialin nature and the proposed TS changes are acceptable.

Section 3.5.A.4 This change proposes to delete...? containment cooling system (including 2 LPCI pumps) and'.. from Specification 3.5.A.4. The originalintent of specifying containment cooling requirements within the LPCI specification was to ensure that sufficient LPCI pumps (which are also the RHR pumps that are used for containment cooling) remained available to provide the suppression pool cooling 4fety function of the RHR system. The proposed, new specifications 3/4.5.B.1 "RHR Suppreuion Pool Cooling System" and 3/4.5.B.2 RHR Containment Spray System will more clearty define the requirements for the containment cooling functions of the RHR system. Therefore, the new TG maintains the current requirements of a train of containment cooling (suppression pool cooling and containment spray) operable when in this LCO. The staff concludes that the current licensing requirement has been maintained and that this proposed TS change is acceptable.

Section 3.5.8 The current Specification 3.5.B is replaced by adding new specifications for containment cooling i

subsystems 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 l-New 3.5.B.4 - Salt Service Water (SSW) System and Ultimate Heat Sink (UHS)

All editorial rewording (either adding or deleting), reformatting and renumbering is proposed to restructure the section to account for the additional Specifications, Actions, and Surveillance.

These proposed changes are intended to result in TS that are more readable and, therefore.

more understandable to plant operators and more accurately rsflect the actual plant design. The editorial rewording, reformatting and renumbering contain no it chnical changes (either actual or interpretational) to the TS except those that are identified and di:cu:;ed below. The staff has reviewed these changes and agrees that they are editorialin nature and represent a reformatting of the current TS to provide a clearer and more understandable TS. Therefore, the proposed TS change is accep'.able.

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L i Existing Section 4.5.B.1.c This change proposes to renumber SR 4.5.B.1.c to 4.5.B.2.2 to coincide with the proposed new Specification for Suppression Pool /Drywell Spray. No technical changes (either actual or interpretational) to the requirements were made. This proposed TS change is editorialin nature and therefore is acceptable.

New Sections 3.5.B.3 and B.4 These changes propose to reword the operability statement of Specification 3.5.B, *both containment cooling system loops shall be operable *, to specifically address new Specifications 3/4.5.B.3 " Reactor Building Closed Cooling Water System

  • and 3/4.5.B.4 " Salt Service Water System and Ultimate Heat Sink". These proposed changes will result in no technical change (either actual orinterpretational) to the TS. The staff has reviewed these changes and agrees that they are editorialin nature and represent a reformatting of the current TS to provide a clearer and more understandable TS. Therefore, the proposed TS changes are acceptable.

New Sections 3.5.B.3 and B.4 Applicability These changes propose to reformat the c,r. placability of Specification 3.5.B. "whenever irradiated fuelis in the reactor vessel and reactor coolant temperature is greater than 212 'F, and prior to Startup from a Cold Condition" for new Specifications. 3/4.5.B.3 and 3/4.5.B.4. These proposed changes will result in no technical change (either actual or interpretational) to the TS. The staff has reviewed these changes and agrees that they are editorialin nature and represent a reformatting of the current TS to provide a clearer and more understandable TS by providing new specifications for individual subsystems. Therefore, the proposed TS changes are acceptable.

New Sections 3.5.B.3.B and 3.5.B.4.A j

These changes propose to reformat the actions required for one inoperable subsystem of the reactor building closed cooling water or salt service water systems. The conditions, required actions and completion times to restore the inoperable subsystem remain the same as in the current TS with an allowable outage time (AOT) of 3 days. No technical changes (either actual orinterpretational) to the TS will result from the proposed changes. The staff has reviewed these changes and agrees that they are editorialin nature and represent a reformatting of the current TS to provide a clearer and more understandable TS by providing new specifications for individual subsystems. Therefore, the proposed TS changes are acceptable.

New Sections SR 4.5.B.3.1 and 4.5.B.4.3 This proposed change adds a note to SR 4.5.B.3.1 and SR 4.5.B.4.3 to c!srify that a RBCCW/SSW subsystem need not be considered inoperable when flow to individual components serviced by the RBCCW/SSW system is isolated. As such, when all necessary pumps, valves, heat exchangers, and piping necessary to support the safety functions are operable, the RBCCW/SSW subsystems are considered operable. This note is consistent with what constitutes an OPERABLE system as described in the Bases and tne STS, therefore, this is considered an administrative change. The staff has reviewed this note and agrees with the licensee that it is consistent with the Bases and the NUREG 1433 and therefore, the proposed change is acceptable.

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l TECHNICAL CHANGES-MORE RESTRICTIVE As a result of providing a specific definition of the components for each system, a significant change has resulted. The proposed change has revised TS 3.5.8 to separate the primary and secondary sides of the RHR heat exchanger. Thereford, in the proposed TS 3.5.B. the secondary side, or rejection side is not included in the list of primary side components The rejection side of the heat exchangers is represented by the proposed new specifications (3.5.B.3 and 3 5.B.4) for the suppori systems (RBCCW and SSW systems). The existing TS implied the containment cooling systems included both sides of the heat exchanger except for the LPCI pumps (see Section 3.5.A.4). For example, the RHR suppression pool cooling system had (by implication) included the RBCCW system as well as the SSW system. These secondary side systems also provide cooling water to other safety related equipment including emergency core cooling system (ECCS) components, and components required for a safe plant shutdown.

Therefore, the most limiting case for containment cooling was RBCCW and/or SSW inoperabikty which resulted in an AOT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or 3 days. With the redefinition of the containment cooling systems which separated the primary and secondary sides of the heat exchangers, the new specific LCOs (3 3.B.1 and 3.5.B.2) addressing the containment cooling components only, do not require a 72-hour AOT; and as proposed would have a 7-day AOT. The secondary side components' AOTs (for RBCCW and SSW) would remain unchanged at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for one inoperable subsystem or trein. Both of these AOTs,3 days and 7 days, are also consistent with NUREG 1433.

As discussed eartier in this evaluation, the proposed change resulted in separate LCOs for RHR suppression pool cooling (TS 3.5.B.1), RHR containment spray (TS 3.5.B.2), the RBCCW system (T5 3.5.B.3), and the SSW system and UHS (TS 3.5.B,4). The only changes that are considered less restrictive are the AOTs for 'he new TS Sections 3.5.B.1 and 2. Following is me staff's evaluation for each of those new TS sections.

Section 3.5.B.1 TS 3.5.B.1 is a new requirement and requires two RHR suppression pool cooling subsystems to be operable. While it appears, based solely on the title of the current TS 3.5.B, that the current TS requees containment cocling, no specific suppression pool cooling requirements, ACTIONS or surveillance requirements (SRs) currently exist. The existing SRs ensure operability of the RBCCW and SSW pumps and valves and drywell and suppression pool spray headers. The RHR suppression pool cooling system is being added since it is a function assumed in transient and accident analyses. Appropriate AMTIONS and SRs are also included. The only change made by the licensee, as part of the ovecit more restrictive change, that the staff considers less restrictive is that a 7 day completion time was chosen instead of 3 days. By Amendment 135. TS 3.5.B.1 and 3.5.F.1 were amended to reduce the AOT from 7 days to 3 days for the containment cooling system and the emergency diesel generators, respectively. The reason for the change at the time was to make the TS more consistent with the STS, and since the plarit TS for containment cooling also included J.a RBCCW and SSW systems, a 3-day AOT was necessary to be consistent with the then current STS. The licensee has proposed to retum the containment cooiing AOT to the originallicensed AOT of 7 days which a also consistent with NUREG 1433 This change is acceptable because (i)it is consistent with other AOTs for systems required to mitigate a loss of coolant accident (LOCA) (i e, core spray and low pressure coolant injection systems), the redundant RHR suppression pool cooling / spray capabilities affcrded by the OPERABLE subsystem, and the low probabihty of a DBA or transient occumng dunng this penod that would require this function. (n)it is also consistent with the current TS 3.5 A 4 which specifies a 7-day AOT for the LPCI system provided the containment cooling system with two LPCI pumps is operable, and (ni) the same pumps are used for both LPCI and containment coo:ing modes of operation -

5-Section 3.5.B.2 TS 3.5.B.2 is a new requirement and requires two RHR containment spray subsystems to be operable. While it appears, based solely on the title of the current TS 3.5.B. that current TS requires containment cooling, no specific suppression pool spray requirements, or ACTIONS currently exist.

The existing SRs ensure operability of the RBCCW and SSW pumps and valves and drywell and suppression pool spray headers. The RHR containment spray system is being added since it is a i

containment cooling function assumed in transient and accident analyses. Appropriate ACTIONS and SRs are also included. The only change made by the licensee, as part of the overall more l

restrictive change, that the staff considers less restrictive is that a 7-day completion time was chosen in lieu of 3 days. The proposed changes are essentially the same as described above for Section 3.5.B.1 and are acceptable on the same basis.

Surveillance 4.5.B.3.1 and 4.5.B.4.3 These changes propose to add a new Surveillance (4.5.B.3.1, and 4.5.B.4.3) to periodically venty the correct valve position is maintained to ensure the subsystems remain capable of providing the overall cooling requirement. The addition of requirements is a more restrictive change. The staff agrees that this is a new requirement that will provide additional assurance of system operability and the proposed change is acceptable.

Surveillance 4.5.B.4.1 This change proposes to add a surveillance requirement (4.5.8.4.1) to venfy the water levelin each SSW pump well. This change adds additional requirements to the TS which constitutes a more restrictive change. The staff agrees that this is a new requirement that will provide additional assurance of system operability and the proposed change is acceptable.

Survei!Iance 4.5.B.4.2 This change proposes to add a surveillance requirement (4.5.B.4.2) to verify average sea water temperature to assure operability of the Ultimate Heat Sink. -The staff has been assured that the temperature averaging is not over time but location. This change adds additional requirements to the TS which constitutes a more restrictive change. The licensee had committed to incorporate an ultimate heat sink temperature in Amendment 173. This proposed change meets that commitment. The staff agrees that this is a new requirement that will provide additional assurance of system oratrability and the proposed change is acceptable Surveillance 4.5.B.4.4 This change proposes to add a surveillance requirement (4.5.B.4.4) to venfy each SSW subsystem actuates on an actual or simulated initiation signal. This change adds additional requirements to the TS which constitutes a more restnctive change. The staff agrees that this is a new requirement that will provide additional assurance of system operability and the proposed change is acceptable, TECHNICAL CHANGES - RELOCATIONS l

Surveillance 4.5.8.1.a and b This change proposes to relocate the pump and motor operated valve testing requirements (4.5.B.1.a and 4.5.8.1.b) to the PNPS IST program (Specification 314.13) and the procedures implementing the IST program. Any changes to this testing provisio. will be adequately controlled by 10 CFR 50.55a The staff has concluded that this change is administrative l

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\\ i in nature as the IST program is required by and maintained by the TS. Therefore, the proposeu change to the TS is acceptable.

TECHNICAL CHANGES - LESS RESTRICTIVE Gection 3.5.B.3.A.1 This change proposes a new action and completion time of 7 days for one required RBCCW pump inoperable. The AOT for one inoperable train of RBCCW or SSW remains at 3 days. With one required RBCCW pump inoperable, the remaining pump in the affected loop is sufficsent to handle the normal operation heat loads, and the remaining OPEReBLE loop is sufficient to meet the requirements to support specifications 3/4.5.B.1, *RHR Suppression Pool Cooling System" and 3/4.5 B.2 *RHR Containment Spray System *, The 7-day completion time was proposed as it is consistent with the completion times for one inoperable loop of the suppression pool cooling system or the containment spray subsystem and the low probability of an event occurring dunng this period that would require RBCCW to support the containment and core cooling functions.

The staff agrees with the licensee that the AOT of 7 days is consistent with the current TS and therefore, the proposed TS change is acceptable.

The staff noted that TS 3.5.B.3.8 is in conflict with 3.5.B.3.A. The licensee agreed with this comment and the staff has modified TS 3.5.B.3.B to read:

The staff concludes that this change is consistent with the proposed TS and the proposed TS change is acceptable.

3.0 BASES SECTION The licensee has revised the associated Bases sections related to the above TS changes. The proposed changes reflect the changes due to relocation, adoption of standard TS wording, and modification of certain TS. As noted above, the proposed TS changes are consistent with NUREG-1433 and the Bases sections have been changed to reflect the revised TS.

4.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Massachusetts State Official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component i

located within the restricted area as defined in 10 CFR Part 20 and changes surveillance I

requirements. The NRC staff has determined that the amendment involves no significant l

increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (63 FR 17221) Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) Pursuant to 10 CFR 5122(b) no environmentalimpact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

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6.0 CONCLUSION

The Commission has 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 manner, (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 the common defense and security or to the health and safety of the public.

Principal Contributor-A. Wang Date: July 28, 1998 l

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