ML20012D447

Application for Amend to License DPR-35,changing Tech Spec 3/4.5, Core & Containment Cooling Sys to Reduce Unnecessary Wear Imposed by Excessive Surveillances on Operable Sys Components & Out of Svc Time to 72 H

ML20012D447
Person / Time
Site:	Pilgrim
Issue date:	03/15/1990
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012D448	List: ML20012D447 ML20012D449
References
BECO-90-041, BECO-90-41, NUDOCS 9003270338
Download: ML20012D447 (7)

Text

m

,  ;. y h*' .

10CFR50.90 p

0 8057MHMSM Pilgrim Nuclear Power Station

. Rocky Hill Road

]4 Plymouth, Mass:chusetts 02360 Ralph G. Bird -

Senior Vice President - Nuclear BECo 90 041 March 15 1990 U.S. Nuclear Regulatory Counission

' Document Control' Desk ,

Hashington, DC 20555 License DPR-35' Docket 50-293 PROPOSED CHANGE T0 TECHNICAL SPECIFICATIQH

!?

7

'SECTION 3/4.5; -CORE AND CONTAINMENT COOLING SYSTEMS l Boston Edison Company (BECo)1 proposes the attached changes to Appendix A of ,

Operating License-No. DPR-35 in accordance:with 10CFR50.90. The changes remove-

<the need to conduct surveillances on redundant Core and Containment Cooling 1 Systems when a system is found or made~ inoperable, and are. proposed to reduce unnecessary wear; imposed by-excessive surveillances-on operable system

. components. The change also-reduces the allowed out-of-service period from 7

-days to 72_ hours for the Containment Cooling System and the Diesel-Generators,

'and eliminates:the 30 day out-of-service' time for the inoperability of one Low Pressure Cooling Injection (LPCI) pump,

These changes are consistent with the surveillances ard allowed out-of-service times of Standard Technical Specifications (STS), and in the " Improved BHR' Technical Specifications for BHR/4's."

PMK/amm/3564 l Attachments: (A) Description of' Proposed Change (B)- Amended Technical. Specification Pages

- h.

(C) Marked-up pages' from Current Technical Specification K' M 1 signed original and 37 copies

+ A.  :

pM k 38' cc:-~See next page  ;

oo 80 Commonwealth of Massachusetts) h\\\ I

]

w ' County of Suffolk) -

1 mo l d 680 JThenpersonallyappearedbeforeme,RalphG. Bird,who,beingdulysworn,did j M' state that he is Senior Vice President - Nuclear of Boston Edison Company and gg :that.he-is duly authorized to execute and file the submittal contained herein co- 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. nd belief. /

I LMy: commission expires: MeM -de v/ d' /9 E DATE- f As M NOTARY PUB IC led l l

'l

.w F .- BOSTON EDISON COMPANY p March 15, 1990- _

I U. S. Nuclear Regulatory Commission l

,. Page-Two' L, J cc:- Mr. M.~.Fairtile.- Project Manager ,

Division of Reactor Projects - I/II 1 Office of Nuclear Reactor Regulation Mail Stop: 1401 U. S. Nuclear Regulatory Commission i 1 White Flint. North '

11555 Rockville Pike Rockville, MD 02852 l

~

U. S.-Nuclear _ Regulatory Commission '

Region I 475 Allendale Road King of Prussia, PA' 19406 Senior NRC Resident Inspector Pilgrim Nuclear; Power Station Mr. Robert M. Hallisey, Director

-Radiation Control Program Massachusetts Department of Public Health ,

150 Tremont Street, 2nd Floor Boston, MA 02111

s- ,

ATTACHMENT A l

Proposed Chance Changes are proposed to Pilgrim Operating License No. DPR-35, Sections 3/4.5.A. i B, C, D, E, F. H Section-3/4.9 and their related Bases. i The proposed change removes the requirement for "immediate and daily j thereafter" surveillances of redundant equipment when Core and Containment Cooling System components are made or found inoperable. The changes also i reduce the allowed out w eservice (00S) time allowed for the Containment.

Cooling System and M s Dit :ini Generators and removes a footnote granting conditional relitf tut hat expired. Reference to I. H. Jacob's" APED-5736:

Guidelines for Deindning Safe Test N trvals and Repair Times for Engineered-Safeguards (General Electric Company, Apru , 1959) is also deleted from the Bases. The word " subsystem" is being replaced with " system" throughout this section of technical specifications.

The specific changes are identified by change bars in the margins of the -

affected pages in attachment B and the marked-up current Technical Specification pages in attachment C. The changes allowed the reformatting of existing text onto different pages to aid in textual flow and to keep related subsections on the same page, when possible. This shifting of subsections is most clearly identified in attachment C.

.The following Sections and pages are affected by this change:

Section- Eagg 3/4.5.A 103, 104, 105, 113, 114, 122 3/4.5.B 106, 107, 115, 122 3/4.5.C 107, 108, 116, 122 3/4.5.D 108, 109, 117, 122 3/4.5.E 109, 110, 118, 122 3/4.5.F 110, 122 3/4.5.H 111, 112, 121 3/4.9 201 The following Sections are being deleted:

Section Eagg L 4.5.A.2 104 L 4.5.A.4 105 '

3.5 A.4 105 4.5.A.5 105 4.5.B.2 107 l' 4.5.C.2 108 i 4.5.D.2 109 l-4.5.E.2 110 4.5.F.1 110 Reason for Chance PNPS technical specifications for Core and Containment Cooling Systems currently require the immediate and daily thereafter demonstration of backup equipment operability when a train or a system is made or found inoperable.

1 of 5

.I

~

This requirement can result in repetitive surveillance testing and corresponding equipment wear and tear. Increased equipment wear and tear and .

the potential = for increased unavailability of equipment due to human error -

during testing tend to offset the added assurance of operability.that the "immediate and daily'thereafter testing" provides. Regularly scheduled -

surveillance tests adequately' determine operability and provide assurance equipment will be available during the interim period between regularly scheduled surveillances, e

These proposed changes will: bring this section of the PNPS technical specifications into conformance with Standard Technical Specifications by removing the need to place redundant systems in their test line-ups during periods when such-systems are needed,-by reducing potential system failures due to improper system alignment after testing, and by eliminating wear on components caused by the additional surveillance testing.- Therefore, this change contributes to-improved overall system availability. Reference to APED-5736 is being deleted from the Bases because it no longer forms the basis r for the 00S times and redundant testing requirements that are being changed by this proposed technical specification amendment.

Changes to the allowed 00S time are made to achieve consistency with STS and provide conservatism in support of-the other changes. Removing the expired footnote is administrative and is proposed to remove expired information from-the technical specification. The pages have been reformatted to improve '

technical specification appearance, readability and to keep.related sections on_

'the same page, when possible. Changing the term "LPCI subsystem" to "LPCI'

. system" in the text and Bases more clearly describes the single system, loop -

selection logic design.of the LPCI system. The word " subsystem" is being replaced by " system" throughout section 3/4.5 for clarity. An administrative change is made to Section 4.5.A.1.d to include a surveillance frequency of "Once/3 months" for the Core Spray pump flow rate test. This proposed administrative change restores the frequency which was inadvertently deleted by Amendment #42 to Pilgrim's technical' specifications. A review of procedures and surveillance records' indicates the Core Spray pump flow test has been performed in accordance with "once/3 months" during its unintentional absence from the text of technical _ specifications.

Another proposed administrative change removes the reference to 3.5.A.5 (in 3.5.A.3), 3.5 B.3.(in 3.5.B.1) and 3.5.C.3-(in 3.5.C.1). Currently these references are provided as " exceptions" to the operability requirements for their respective systems. However, the referenced sections actually require plant shutdown when a system is made or found to be inoperable and therefore they are not " exceptions". This proposed change is made for consistency.

Safety Evaluation and Determination of No Sianificant Hazards Considerations The Code of Federal Regulations (10CFR50.91) requires licensees requesting an amendment to provide an analysis, using the standards in 10CFR50.92, that determines whether a significant hazards consideration exists. The following analysis is provided in accordance with 10CFR50.91 and 10CFR50.92 for the proposed amendment removing the requirement for immediate and daily surveillance testing of redundant Core and Containment Cooling Systems, reducing the allowed out-of-service (00S) times for the Containment Cooling Systems and the Diesel Generators, deleting the 30-day LCO for one LPCI pump being inoperable, removing an expired footnote to Section 3.5.B, and the associated changes made to Bases.

2 of 5

g o:

~

1-. The' operation of Pilgrim Station in accordance with the proposed amendment will not involve a.significant increase in the probability or .

consequences of an accident previously evaluated. 1 This proposed change does not alter any equipment configuration or operation.~

Current Pilgrim technical specifications requiring immediate and daily 1 surveillances of redundant ECCS equipment are based on the assumption that the increased redundant equipment testing during an.LC0 provides additional assurance that equipment will be available should it be needed.

Industry experience gained after Pilgrim's technical specifications were- 3 developed indicates repetitive surveillance testing can place demands  ;

and wear on plant systems without necessarily providing additional- i confidence of. availability.

The normal technical specification required surveillance frequencies are established to provide assurance that the tested system, once demonstrated operable, can be expected to remain operable during the.

period between surveillance tests. Therefore, physically-redemonstrating operability due to the inoperability of a redundant system provides little in the way of additional assurance, i Since increasing the surveillance frequency when another system is U determined to be inoperable does not provide significant-additional

-assurance of system availability, and since increased surveillance frequency can prematurely wear active system components, removal of the increased surveillance requirements benefits plant equipment without resulting in a significant increase in the probability that. redundant core or containment cooling systems will be available when required to perform their safety function. Since detailed probabilistic analyses- ,

have not been performed for PNPS to quantify the overall impacts on. core F and containment cooling system availabilities, the allowed 00S times for

- HPCI, RCIC and ADS will remain at seven days, as compared to the less restrictive 14 day frequency in Standard Technical Specifications '

(STS). Also, core and containment cooling pump and valve normal surveillance testing will remain at a one month frequency, compared to the less restrictive three month frequency specified in STS. These factors further ensure that this proposed change does not involve a i significant increase in the probability or consequences of an accident previously evaluated.  ;

Reducing the allowed 00S period from 7 days to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the Containment Cooling System and Diesel Generators, and eliminating the 30 day 00S period for a single LPC1 pump does not increase the probability or consequences of an accident previously evaluated because these changes reduce the time safety equipment is allowed to be inoperable during power operation. These reductions improve overall availability of these systems because, on average, they will be inoperable for shorter time periods. Changing the term "LPCI subsystem" to "LPCI system" in the text and Bases is made to reflect the single system, four pump LPCI design. These changes are inherently conservative.

3 of 5

< J Removing the footnote and the associated asterisk granting conditional _

relief from the requirements of section 3.5.B does not increase the l probability or consequences of an accident previously evaluated because

-the footnote has expired and therefore its removal has no impact on section 3.5.B.

Reference to APED-5736 is deleted because it no longer forms the basis for the 00S times or redundant testing requirements. APED-5736 does not

)

.)

address equipment wear and tear due to constant testing nor does it  !

reflect the increased potential for human errors leaving a system inoperable after testing. Its impact on safety is not significant l because.the proposed amendment reflects STS requirements that are l supported by industry experience at nuclear power plants using STS.-

Reformatting the text and the other administrative changes do not change or impact the meaning of the technical specifications. Hence, these changes do not affect the probability or consequences of an accident previously analyzed. 3

2. - The operation of Pilgrim Station in accordance with the proposed "

amendment will not. create the possibility of a new or different kind of accident from any accident previously evaluated. ,

The proposed amendment keeps redundant systems in a state identical to <

that assumed to exist in the Pilgrim Station accident analysis during normal operations; hence, operating Pilgrim in accordance with the proposed amendment will not create the possibility of a new or different

' kind of accident from any previously analyzed. .

Removing the footnote and the associated asterisk granting conditional relief to the requirements of section 3.5.B does not create the possibility of a new or different kind of accident from any previously analyzed because the footnote grants conditional relief and no longer has any impact on technical specification 3.5.B.

' Reformatting the text and the other administrative changes do not change

-technical specification requirements; therefore these changes do not create the possibility of a new or different kind of accident from any

. accident previously analyzed. ,

Reducing the 00S for the Containment Cooling System, the Diesel ,

Generators, and eliminating the 30 day 00S for the inoperability of a single LPCI pump are inherently conservative changes that do not create the possibility of a new or different kind of accident from any accident previously analyzed.

3. The operation of Pilgrim Station in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.

'The current technical specifications require an increased surveillance frequency to demonstrate operability. The original intent of requiring the additional testing was to enhance confidence the system would function when called upon. However, normal test frequencies are established to provide assurance a system, once demonstrated operable, will remain operable during the period between surveillance tests. As 4 of 5

6

l 'i. 4' j l

.I h discussed under (1) above, normal test frequencies provide adequate- l L assurance'of system operability. The proposed change provides assurance 1 of operability without the potential increase in risk caused by the j system possibly being made-inoperable-by being misaligned after the test 1

, is' completed. Therefore, the proposed amendment will not-significantly- 1 F 1 change risk from.that assumed for systems during-normal operations;; j

'hence, the proposed amendment does not involve a significant~ reduction '

-in~the margin of safety.

Removing'the footnote associated with Section-3.5.B does not involve a significant reduction in the margin of safety because the footnote has expired-and no longer has.any impact on 3.5.B requirements.

Reformatting the text and-the other administrative changes do not change-the technical specification requirements; therefore these changes do not a involve a significant _ reduction .in the margin of safety.

Reducing the 00S for the Containment Cooling System and the Diesel Generators, and. eliminating the 30 day 00S for the inoperability of a

' single LPCI pump reduces the time allowed to operate in a Limiting '

Condition of Operation (LCO), and are therefore conservative changes that do not involve a significant reduction in the margin of safety. -

This change has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee. -

' Schedule of Chanae This change will be implemented within 60 days following BECo's receipt of its approval by the Commission. ,

L i

4 L

I L 1 1 ,

l L 1 5 of 5 s

_