ML20011E948

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Safety Evaluation Supporting Amend 128 to License DPR-35
ML20011E948
Person / Time
Site: Pilgrim
Issue date: 02/12/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20011E944 List:
References
NUDOCS 9002230173
Download: ML20011E948 (3)


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UNITED STATES NUOLCAR REGULATORY COMMISSION I

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.128 TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

By letter dated Decwhar 7, '0P9, the Bostne Fdison Company (the l'rrnsee) proposed changes to the technical specifications (TS) for the Pilgrim Nuclear Power Station. The proposed chances will change the definition of surveillance frequency which limits the combined time interval for three consecutive surveillances to less than 3.25 times the specified interval. Guidance on this proposed change to the TS was provided to all power reactor licensees ano applicarts by Generic Letter 89 14 dated August 21, 1989.

The proposed change will elso move the definition of an operating cycle from the definition of surveillance frequency to the oefinition of surveillerce interval. This change places it une r the proper heading.

P.0 EVALUATION The defilotion of surveillarte Trequency includes the provision that allows a surveillarce interval to be extended by 25 percent of the specified time interval. This extension provides flexibility for scheouling the performance of surveillances and to permit consideration of plent operating conditiors that may not be suitable for conducting a surveillance at the specified time interval. Such operating conditions include transient plant creration er ongoing surveillerce or maintenance activities. The current definition of surveillance frequency further limits the allowance for extending surveillance intervals by requiring that the combined time interval for any three consecutive surveillances not exceed 3.25 times the specified time interval. The purpose of this provision is to assure that surveillances are not extended repeatedly as an operational convenience resultine in an overall increase in the surveillance interval.

Experience has shown that the 18-month surveillance interval, with the provision to extend it by 25 percent, is usually sufficient to acconnodate normal variationr. in the length of a fuel cycle. However, the NRC staff has routinely eranted requests for ere-time exceptions to the 3.25 limit on extending refueling surveillances because the risk to safety is low in contrut to the alternative of a forced shutdown to perform these surveil-lances. Therefore, the 3.25 limitation on extending surveillances has nct been a practical liniit cr the use of the 25-percent allower.ce for extending surveillances that are performed on a refueling outage basis.

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Extending surveillance intervals durirg plant operation can also result in a benefit to safety when a scheduled surveillarice is due at a time that is not tuitable for conducting the surveillance. This may occur when transiert plant operating conditions exist or when safety systems are out of service for maintenance or other surveillance activities.

In such cases, the benefit to safety of extending a surveillance interval would exceed any safety benefit derived by limiting the use of the 25-percent allowance to extend a surveillance. Furthermore, there is the administrative burden associated with tracking the use of the 25-percent allowance to ensure compliance with the 3.25 limit.

In view of these firdings, the staff concluded that the 3.25 limit for all surveillances should be removed because its removal will have an overall positive effect on safety. The guidance provided in Generic letter 84-1 A reenmanded a chango thet remnves the 3.75 limit on three consecutive surveillances. The definition was also updated in note that, it is not the intent of the allowance for extendina surveillence intervals oe used repeatedly merely es an operational convenience to extend surveillance intervals beyond thet specified.

Moving the definition of operatirg cycle from surveillarte frequency to surveillance interval placed the definition under the proper heading.

This proposed charige also adds to the clarity of the definition of surveil-lance frequency.

The litersee's proposed changes to the definition of surveillance frequency is consisteht with the guidance provided in Generic L.etter 09-14, as noted above, and moving the definition of operating cycle adds clarity and placed i+ under tbc proper heading. On the basis of its revin of thit utter, the 5tcff finds that the abnyc changes to the pilgrin Technical Specificetions are acceptable.

3.0 Et4VIRONMEt4TAl. CONSIDERATION This amendment involves changes in requirements with respect to the use of fecility corponents located within the restricted aree as defined in 10 CFR Part 20 and surveillance requirements. The Staff has determir.ed that the amendment involves no significant increese in the amounts and no significant changes in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational exposure. The staff has determined that the amendment involves no signficant-hazards consideration and there has been no public comment on such finding.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), to environmental impact statement or environmental assessment need be prepared in connectier with the issuance of this amendment.

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4.0 CONCLUSION

The Commission's determination that the anendment involves no significant hazards consideration was published in the Federal Resister (55 FR 929

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on January 10, 1990. No public comments were receivec, and the Commonwealth of Massachusetts did not have any comments.

On the basis of the considerations discussed above, the staff concludes 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 Connission's regulations, and (3) the issuance of this amendment will not be inimical to the conmon defense and security or to the health and safety of the public.

principal Contributors: T. Dunning D. Mcdonald Dated: February 12, 1990 e

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