BECO-85-079, Application to Amend License DPR-35,consisting of Rev 1 to 840324 Proposed Change 84-01,changing Tech Specs to Remove Details of ASME Section XI Inservice Insp Program

Application to Amend License DPR-35,consisting of Rev 1 to 840324 Proposed Change 84-01,changing Tech Specs to Remove Details of ASME Section XI Inservice Insp Program

ML20115J812
Person / Time
Site:	Pilgrim
Issue date:	04/17/1985
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20115J815	List: BECO-85-079, Application to Amend License DPR-35,consisting of Rev 1 to 840324 Proposed Change 84-01,changing Tech Specs to Remove Details of ASME Section XI Inservice Insp Program ML20115J824
References
BECO-85-079, BECO-85-79, NUDOCS 8504240118
Download: ML20115J812 (5)

Text

r

, BOSTON EDISON COMPANY B00 SovLaTON STREET BOSTON. massachusetts 02199 WILLIAM D. HARRINGTON I assssom vses passesses, cretsan April 17, 1985 BECo 85-079 Proposed Change 84-01 Rev. 1 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 License DPR-35 Docket 50-293 Revised Pilgrim Station Proposed Technical Specification Change

References:

(a) Boston Edison Company Letter (W. D. Harrington) to NRC (D. B. Vassallo) dated March 20, 1984 (b) USNRC Generic Letter 84-13, " Technical Specification for Snubbers," dated May 3, 1984

Dear Sir:

In Reference (a) Boston Edison Company (BECo) submitted a proposed technical specification change which affected the implementation of ASME Boller and Pressure Vessel (B&PV) Code;Section XI Inservice Inspection program and snubber testing requirements. Subsequent to that submittal, and in the course of your review, you recommended further changes to our submittal. In addition, Reference (b) concludes that the inclusion of any snubber listings within the technical specifications is not needed. We have reviewed your recommendations and hereby submit revised Pilgrim Station proposed Technical Specifications. These revisions supersede the proposed changes described in Reference (a).

Proposed Change This proposed technical specification change removes the details of the Section XI Inservice Inspection (ISI) Program. The requirement to implement the ISI Program at the required intervals is not removed. The details of the ISI Program are administratively handled as a controlled document. Snubber inspection requirements are left in the Technical Specifications but the tables listing snubbers on safety related systems are maintained in PNPS Procedures, bk3 a 0

7

.e BOSTON EDISON COMPANY Mr. Domenic 8. Vassallo, Chief April'17, 1985 Page 2 Reference is made to the following Pilgrim Nuclear Power Station Technical Specification Sections, Tables, and Bases:

Section 3.6.G " Structural Integrity" Section 4.6.G " Structural Integrity" Section 3.6.H "High Energy Piping (Outside Containment)"

Section 4.6.H "High Energy Piping (Outside Containment)"

Table 4.6.l' " Inservice Inspection Requirements for Pilgrim Nuclear Power Station" Table 4.6.2 " Inservice Inspection Requirements for High Energy Lines Outside Containment"

-Section 3.6.I " Shock Suppressors (Snubbers)"

Section 4.6.I " Shock Suppressors (Snubbers)"

Table 3.6.I(a) " Safety Related Hydraulic Shock Suppressors (Snubbers)"

Table 3.6.I(b) " Safety Related Mechanical Shock Suppressors (Snubbers)"

Bases 3.6.G & 4.6.G " Structural Integrity" Bases 3.6.H & 4.6.H "High Energy Piping Outside of Containment" Summary of Changes Section 3.6.G The reference to the ASME Boller and Pressure Vessel Code has been changed from the 1974 Edition to the Edition specified in 10CFR50.55 a(g). The remainder of this section has been deleted.

Section 4.6.G The reference to Table 4.6.1 has been changed to PNPS Inservice Inspection Program. Conforming changes have been made to reflect the ten year interval requirements.

Section 3.6.H.3 A clarification of the area where leakage is a concern.

Change "... a break ..." to "... the pressure retalning boundary ..."

Section 4.6.H The reference to the ASME Boller and Pressure Vessel Code has been changed from the 1974 Edition to the 1980 Edition, Winter 1980 Addenda, Subarticle IWA-5240.

BOSTON EDISON COMPANY

- Mr. Domenic~B._Vas'sallo, Chief April .17, 1985 Page 3 Table 4.6.1 This table has been deleted.

Table 4.6.2 Title change. Page is renumbered.

Section 3.6.I.1 The reference to " Table 3.6.I(a) and Table 3.6.I(b)" has been replaced with "PNPS Procedures".

Section 3.6.I.4 Reporting requirements are changed to be in accordance with 10CFR50.59.

Section 4.6.I The references to " Table 3.6.I(a) and Table 3.6.I(b)" has been replaced with "PNPS Procedures".

Table 3.6.I(a) This table has been deleted.

Table 3.6.I(b) This table has been deleted.

Bases 3.6.G & Refer to the attached pages for extent of changes. Replace 4.6.G present bases with attached bases.

Bases 3.6.H & Modified to reference the ASME B&PV Code,Section XI, 1980 4.6.H Edition, Hinter 1980 Addenda.

Remove the following pages from the Technical Specifications: pages 127, 127A, 1278, 129 through 137, 137a, 137b, 137d through 1371, 138A, 149, 150, 151 Insert the following new pages in the Technical Specifications: pages 127, 127A, 1278, 137, 137a, 137b, 137d, 150, 151 Reason for Change This proposed Technical Specification permits ISI changes to Code Class systems without a subsequent Technical Specification Change but does not-remove the commitment to perform ISI per ASME B&PV Code,Section XI. The details of the ISI Program will be kept as a controlled document so ASME B&PV Code,Section XI modifications, repairs, or replacements can be accurately captured in the program.

l This approach is similar to the BWR Standard Technical Specifications in the area of ISI on Code Class 1, 2, and 3 components. The Standard Technical Specifications do not require a detailed table outlining the entire ISI

program by system, weld, pump, etc.

l This proposed Technical Specification also permits removal or addition of snubbers to safety-related systems without a subsequent Technical

! Specification Change but does not remove the commitment to test safety-related i

snubber at the required Intervals.

i-L

BOSTON EDISON COMPANY Mr. Domenic B. Vassallo, Chief April 17, 1985 Page 4 NRC Generic Letter 84-13 " Technical Specification for Snubbers", concludes that the inclusion of snubber listing within the technical specifications are not necessary provided the appilcable snubber technical specification is modified to specify which snubbers are required to be operable. We have modified our technical specification accordingly.

Safety Considerations This change does not present an unreviewed safety question as defined in 10CFR 50.59. It has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Significant Hazards Considerations It has been determined that this amendment request involves no significant hazards consideration. Under the NRC's regulations in 10CFR 50.92, this means that operation of the Pilgrim Nuclear Power Station in accordance with the proposed amendments would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

The NRC has provided guidance concerning the application of standards for determining whether license amendments involve significant hazards considerations by providing certain examples (48 FR 14870). One example of an amendment that is considered not likely to involve a significant hazards considerations is "...(vil) A change to make a license conform to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations."

Changes to the ASME Boller and Pressure Vessel Code, which is incorporated by reference in 10CFR 50.55a, have necessitated changes to the Pilgrim Station Inservice Inspection Program, as implemented in the Pilgrim Station Technical Specifications. Therefore, this proposed Technical Specification incorporates these changes. Facility operations are not impacted because the ISI requirements are still satisfied. The methodology for implementation of the ISI requirements is satisfactory in that it conforms with the BHR Standard Technical Specifications. Similarly, the removal of snubber listings from the technical specifications conforms with the recent guidance of NRC Generic Letter 84-13. Facility operations w111 be impacted only by the change in procedure for implementing operability and surveillance requirements for safety-related snubbers. This is considered a very minor change to the operation of Pilgrim Station.

Schedule of Change This change will become effective 30 days after receipt of NRC approval.

- BOSTON EDIS0N COMPANI

- Mr. Domenic B. Vassallo, Chief

, April 17, 1985 Page 5 Fee Determination

. The sum of $4,000 has been previously submitted wl_th'our Reference (a) submittal and should be applied to this revision. No further fees are necessary.

Should you have any questions concerning this submittal, please do not hesitate to contact us.

Very truly yours, Attachment 3 signed originals and 37 copies Commonwealth of Massachusetts)

County of Suffolk )

Then personally appeared before me W. D. Harrington, who, being duly sworn, did state that he is Senior Vice President - Nuclear of the Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of the Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My Commission expires: (/ v pef ht.uem '4.

s+v>

j Notary Public /

t 4

, ,, -. - , . e-r- ---.r,, .-e,-,--ewi---.e-*~- - . , s w.---wzw---.-y,-e--,.---,,,3w-t--w,w.w-e.-,.--r-- e e- 53**,w- -*e--+'-