ML030920558
| ML030920558 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/19/2003 |
| From: | Ronald Bellamy Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.03.011 | |
| Download: ML030920558 (7) | |
Text
1'En tergy Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mike Bellamy Site Vice President March 19, 2003 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001
SUBJECT:
Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Proposed License Amendment to Eliminate the Requirements for the Post Accident Sampling System (PASS)
Usina the Consolidated Line Item Improvement Process
REFERENCES:
- 1. NEDO-32991 -A, Regulatory Relaxation for BWR Post Accident Sampling Stations (PASS)
- 2. Technical Specification Change Traveler, TSTF-413, "Elimination of Requirements for a Post Accident Sampfing System (PASS)," dated August 2001
- 3. Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Topical Report NEDO-32991, "Regulatory Relaxation for B'NR Post Accident Sampling Stations (PASS)," BWR Owners Group Project No. 691 LETTER NUMBER: 2.03.011
Dear Sir or Madam:
In accordance with the provisions of 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) is-submitting a request for an amendment to the Technical Specifications (TS) for the Pilgrim Nuclear Power Station (PNPS).
The proposed license amendment would delete TS 5.5.3, "Post Accident Sampling," and thereby eliminate the requirements to have and maintain the post accident sampling system (PASS) at PNPS. The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-413, "Elimination of Requirements for a Post Accident Sampling System (PASS)" dated August 2001. The availability of this TS improvement was announced in the Federal Register on March 20, 2002, as part of the consolidated line item improvement process (CLIIP).
ENO requests approval of the proposed license amendment by March 30, 2004, with the amendment being implemented within sixty days following approval.
If you should have any questions regarding this submittal, please contact Mr. Bryan Ford at (508) 830-8403.
20I 203011
Entergy Nuclear Operations, Inc.
Letter Number: 2.03.011 Pilgrim Nuclear Power Station Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the
/5 day of eK4 4*
2003.
Sincerely, 6?
nA R.M. Bellamy REB/dd Attachments: 1. Description and Evaluation - 2 pages
- 2. Proposed Technical Specification Changes (Mark-up) - 1 page
- 3. Regulatory Commitments - 1 page -
cc:
Regional Administrator, Region I
-U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Travis Tate, Project Manager Project Directorate 1-2 Office of Nuclear Reactor Regulation Mail Stop: O-8B-1A One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Senior Resident Inspector Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mr. Robert Walker Radiation Control Program Mass. Dept. of Public Health 174 Portland St. 5th Floor Boston, MA 02114 203011
ATTACHMENT 1 Page 1 of 2 Description and Evaluation of Proposed Amendment to Technical Specifications
1.0 DESCRIPTION
The proposed License amendment deletes the program requirements of Technical Specification (TS) 5.5.3, "Post Accident Sampling." The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-413, "Elimination of Requirements for a Post Accident Sampling System (PASS)" dated August 2001. The availability of this TS improvement was announced in the Federal Register on March 20, 2002 as part of the consolidated line item improvement process (CLIIP).
2.0 EVALUATION 2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (ENO) has reviewed the safety evaluation published on December 27, 2001 (66 FR 66949) as part of the CLIIP. This verification included a review of the NRC staff's evaluation (as modified slightly by the notice of availability dated March 20, 2002) as well as the supporting information provided to support TSTF-413 (i.e., NEDO-32991, Regulatory Relaxation for BWR Post Accident Sampling Stations (PASS)," submitted November 30, 2000, and the associated NRC safety evaluation dated June 12, 2001). ENO has concluded that the justifications presented in the TSTF and the safety evaluation prepared by the NRC staff are applicable to the Pilgrim Nuclear Power Station (PNPS) and justify this amendment for the incorporation of the changes to the PNPS TS.
2.2 Optional Changes and Variations ENO is not proposing any variations or deviations from the technical specification changes described in TSTF-413 or the NRC staff's model safety evaluation published on December 27, 2001 (as modified slightly by the notice of availability dated March 20, 2002).
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination ENO has reviewed the proposed no significant hazards consideration determination published on December 27, 2001 (66 FR 66949) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to PNPS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
ATTACHMENT 1 Page 2 of 2 Description and Evaluation of Proposed Amendment to Technical Specifications 3.2 Verification and Commitments As discussed in the model SE published in the Federal Register on December 27, 2001 (as modified slightly by the notice of availability dated March 20, 2002) for this TS improvement, plant-specific verifications and commitments were performed as follows:
- 1. ENO is making a regulatory commitment to develop and maintain contingency plans for obtaining and analyzing highly radioactive samples from the Reactor Coolant System, Suppression Pool, and containment atmosphere. The contingency plans will be contained in plant procedures and implementation will be completed within 6 months after the implementation of the License amendment. Establishment and maintenance of contingency plans is considered a regulatory commitment.
- 2. The capability for classifying fuel damage events at the Alert level threshold will be established and maintained for PNPS at radioactivity levels of 200 microcuries/ml total iodine. This capability will be described in plant procedures and implementation will be completed within 6 months after the implementation of the License amendment. The capability for classifying fuel damage events is considered a regulatory commitment.
- 3. ENO is making a regulatory commitment to develop and maintain an 1-131 site survey detection capability, including an ability to assess radioactive iodines released to offsite environs, by using effluent monitoring systems or portable sampling equipment. The capability for monitoring iodines will be maintained within plant procedures.
Implementation of this commitment will be completed within 6 months after the implementation of the License amendment. The capability to monitor radioactive iodines is considered a regulatory commitment.
4.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation published on December 27, 2001 (66 FR 66949) as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to PNPS and the evaluation is hereby incorporated by reference for this application.
ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include the Core Spray (CS), High Pressure Coolant Injection (HPCI), Residual Heat Removal (RHR), Reactor Core Isolation Cooling (RCIC), Reactor Water Cleanup (RWCU)[Let Down portion], Radwaste Collection System from Reactor Building, samplirig system (From Recirc and RWCU). and Standby Gas Treatment (SGTS). The program shall include the following:
- a.
Preventive maintenance; and
- b.
Periodic visual inspection to identify and estimate leakage.
5.5.3 12s wad3migf This p ram provides control that ensure the cap Ility to obtaind analyze reactor ant, radioactive gas, and particulates in lant gaseous luents d contain nt atmosphere sam es under accident ditions. The pr m shall in ude the following:
- a.
ining of p onnel;
- b.
Proc es for sa ng and analysis; a
- c.
Provisionsfmaintenan of sampling and lysis equipment.
5.5.4 Radioactive Effluent Controls Proaram This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:
- a.
Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; (continued)
PNPS 5.0-7 Amendment No. `
l
ATTACHMENT 3
SUMMARY
OF REGULATORY COMMITMENTS The following table identifies those actions committed to by ENO in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Bryan Ford at (508) 830-8403.
Commitment ID Description RC Item Due Number Date RC-03.201 1.10 Develop and maintain contingency plans for 9/15/03 obtaining and analyzing highly radioactive samples from the Reactor Coolant System, Suppression Pool, and containment atmosphere. The contingency plans will be contained in plant procedures and implementation will be completed within 6 months after the implementation of the License amendment.
RC-03.2011.20 The capability for classifying fuel damage events at 9/15/03 the Alert level threshold will be established and maintained for PNPS at radioactivity levels of 200 microcuries/ml total iodine. This capability will be described in plant procedures and implementation will be completed within 6 months after the implementation of the License amendment.
RC-03.2011.30 Develop and maintain an 1-131 site survey detection 9/15/03 capability, including an ability to assess radioactive iodines released to offsite environs, by using effluent monitoring systems or portable sampling equipment. The capability for monitoring iodines will be maintained within plant procedures.
Implementation of this commitment will be completed within 6 months after the implementation of the License amendment.