BECO-86-068, Application for Amend to License DPR-35,consisting of Proposed Change 86-07,deleting Tech Spec Sections 3.6.H & 4.6.H,Table 4.6.2 & Bases 3.6.H & 4.6.H,due to Completion of Mods Described in 730827 FSAR Suppl 34.Fee Paid

Application for Amend to License DPR-35,consisting of Proposed Change 86-07,deleting Tech Spec Sections 3.6.H & 4.6.H,Table 4.6.2 & Bases 3.6.H & 4.6.H,due to Completion of Mods Described in 730827 FSAR Suppl 34.Fee Paid

ML20195C201
Person / Time
Site:	Pilgrim
Issue date:	05/23/1986
From:	Harrington W BOSTON EDISON CO.
To:	Zwolinski J Office of Nuclear Reactor Regulation
Shared Package
ML20195C204	List: BECO-86-068, Application for Amend to License DPR-35,consisting of Proposed Change 86-07,deleting Tech Spec Sections 3.6.H & 4.6.H,Table 4.6.2 & Bases 3.6.H & 4.6.H,due to Completion of Mods Described in 730827 FSAR Suppl 34.Fee Paid ML20195C218
References
BECO-86-068, BECO-86-68, NUDOCS 8605300167
Download: ML20195C201 (5)

Text

e BOSTON EDISON COMPANY B00 BOYLSTON STREET B OSTON, M AaBACHUSETTs 02199 WILLIAM D. HARRINGTON

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BECo 86- 068 Proposed Change 86- 07 May 23, 1986 Mr. John A. Zwolinski, Director BWR Project Directorate #1 01 vision of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 License DPR-35 Docket 50-293 Pilgrim Station Proposed Technical Specification Change -

High Energy Piping

Dear Sir:

Pursuant to 10 CFR 50.90, Boston Edison Company hereby proposes modifications to Facility Operating License No. DPR-35 as described in the Attachment to this letter. In accordance with 10 CFR 170 a check in the amount of $150.00 is enclosed with this submittal.

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

Very truly yours, 8605300167 860523 DR ADOCK0500g3 TFF/ns Commonwealth of Massachusetts)

County of Suffolk )

Then personally appeared before me H. 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 sutimittal are true to the best of his knowledge and belief.

My Commission expires: My commission Expir. Apr; 3,j992 Notary Public 0

cc: See next page ,

BOSTON EDISON COMPANY Mr. John A. Zwolinski, Director Page 2 cc: Mr. Robert M. Hallisey, Director Radiation Control Program Mass. Dept. of Public Health 150 Tremont Street F-7 Boston, MA 02111 t

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Attachment High Energy Piping Proposed Technical Specification Change Proposed Change This proposed Technical Specification change deletes Sections 3.6.H and 4.6.H.

Table 4.6.2, and Bases 3.6.H and 4.6.H. These sections stipulate monthly visual inspections of the high energy piping outside primary containment while the station is operating. Removal of these sections, bases, and the table will remove the requirements to perform the monthly visual inspections.

Specific instructions for page revisions follow:

Remove existing pages: Replace with attached pages:

127B No replacement page 137 137 150 150 Reason for Change Technical Specifications 3.6.H. 4.6.H and Table 4.6.2 were initially implemented by Technical Specification Amendment No. 7, dated December 20, 1974. Amendment No. 7 added interim surveillance requirements to the Technical Specifications pending the completion and acceptance of certain modifications to Pilgrim Station to assure that it would withstand the consequences of postulated ruptures in the high energy fluid piping outside the primary containment. The scope of modifications are described in FSAR Supplement No. 34, dated August'27, 1973.

Technical Specification Section 3.6.H.4 states that when the modifications described in FSAR Supplement No. 34 are completed, Technical Specifications 3.6.H and 4.6.H will no longer be required. With one exception, all modification commitments have been completed and incorporated into Boston Edison Company design documents. The exception was a proposed modification to install backup RBCCH manual isolation valves for the equipment area cooling units located within the RCIC pump compartment. A detailed re-evaluation (Bechtel letter to BECo BLE-234) showed that this modification was not required. The re-evaluation determined that an adequate ficor does separate the cooling lines from any potentially generated missiles.

Since the requirements of Technical Specification 3.6.H.4 have been met, Technical Specifications 3.6.H, 4.6.H, and by reference, Table 4.6.2 are not applicable. Boston Edison Company therefore proposes to remove these inapplicable sections from the Technical Specifications.

Safety Considerations This change does not present an unreviewed safety question as defined in 10 CFR 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 He have determined that this amendment request does not involve a significant hazards consideration. In making this determination we have addressed each of the three standards listed in 10CFR50.92(c). A discussion of the standards is provided.

10CFR50.92(c)(1) states that the proposed amendment should not "... Include a significant increase in the probability or consequences of an accident previously evaluated ..."

The present operating requirement is to perform monthly visual inspections of the high energy piping outside of primary containment while the station is operating. This requirement was imposed by the NRC through Amendment No. 7 to our Facility Operating License No. DPR-35. An NRC Safety Evaluation titled

" Analysis of the Consequences of High Energy Piping Failures Outside Containment", dated December 20, 1974, was written in support of Amendment No.

7. This Safety Evaluation contains the results of Boston Edison Company and NRC reviews of the consequences of high energy piping failures outside primary containment. The Safety Evaluation also established the criteria to be applied should we request permanent relief from the requirement to perform these monthly visual inspections. This criteria specified that certain modifications must be completed at Pilgrim Station before the operating restriction would be removed. There should not be a significant increase in the probability or consequences of any of the previously evaluated accidents if the criteria are met. We have verified that all but one of the modifications discussed in the above mentioned Safety Evaluation have been completed and are incorporated into design documents. The verification report is available for your review. The one exception was a modification to install backup RBCCH valves for the equipment area cooling units located within the RCIC pump compartment. A documented reevaluation concluded that this modification was not necessary because an adequate floor separates the cooling lines from any potentially generated missiles.

10CFR50.92(c)(2) states that the proposed amendment should not "... Create the possibility of a new or different kind of accident previously evaluated ..."

As mentioned above, the present operating requirement is to perform monthly visual inspections. The conditions by which these requirements would no i longer be applicable have been specified in detail in the NRC Safety Evaluation. The imposed operating restriction is considered to be a temporary measure until the modifications discussed in the Safety Evaluation are completed. The completion of the modifications will increase the safety margins in the event of a high energy line break outside primary containment.

He have completed the necessary modifications, therefore, the possibility of a l

new or different kind of accident will not be created, f-10CFR50.92(c)(3) states that the proposed amendment should not "... Involve a significant reduction in a margin of safety."

The completed modifications described in FSAR Supplement No. 34 increase the margins of safety in the event of a high energy line break outside primary l

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containment. Even with this proposed amendment to delete the monthly visual inspections there will not be a significant reduction in a margin of safety.

The Safety Evaluation established compensatory measures in the form of periodic visual inspections until permanent modifications could be made. The modifications listed in the Safety Evaluation have been met. As a result the safety margins cannot be' compromised and there will not be an increase in the safety margins.

In conclusion, the conditions stipulated in a prior NRC Safety Evaluation have been. met. As a consequence, the Safety Evaluation states that these temporary operating restrictions are no longer required.

Schedule of Change This change will be put into effect in 30 days after receipt of approval from NRC. He are requesting NRC approval of this proposed change approximately six months from the date of this submittal.

Application _ Fee The application fee in the sum of $150.00, Boston Edison Check # 950778, is attached.

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