ML20012F363
| ML20012F363 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/30/1990 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 90-046, 90-46, NUDOCS 9004110256 | |
| Download: ML20012F363 (3) | |
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helph G. Mrd senior Vict he$ident - Nuclea' BECo Ltr.90-046 March 30, 1990
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8l U.S. Nuclear Regulatory Commission Document Control Desk l
Washington, DC 20555 l
License DPR-35 Docket 50-293
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Request for Relief from Technical Specification Table 3.2.C-1. APRM Unscale Rod Block in Startuo and Refuel Modes i
l Boston Edison hereby requests a temporary waiver of compliance from the requirements of Pilgrim Nuclear Power Station (PNPS) Technical Specification i
Table 3.2.C-1 for the APRM upscale control rod block function in startup and r
i refuel modes. This temporary relief is requested as soon as possible and until i
NRC approval of the proposed exigent technical specification change request submitted to the NRC under separate cover.
Plant operation with the approval of this relief request would not create a significant hazard to the public t
l health and safety and is justified on technical merit.
BACKGROUND During an investigation of related issues, Boston Edison determined that i
Technical Specification Table 3.2.C-1 incorrectly requires a flow biased i
setpoint for the APRM upscale control rod block during startup and refuel modes.
The flow biased setpoint is valid for the run mode of operation, but is
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bypassed to a setdown value when the mode switch is moved to the startup or l
refuel positions. A proposed exigent technical specification change will be submitted under separate cover to add the setdown feature of this setpoint to l
Technical Specifications for startup and refuel modes, I
i PNPS is currently shutdown for mid-cycle maintenance and surveillance with the f
mode switch in the shutdown position.
In the shutdown mode, the APRM upscale control rod block is not required to be operable. Compliance with the current f
operating license requirement in Technical Specification Table 3.2.C-1 for a flow biased setpoint in the startup and refuel modes is not possible by plant design.
For this reason, temporary relief from Technical Specification Table i
3.2.C-1 is requested to allow required surveillances to be conducted with the Reactor Mode switch in the startup and refuel modes without the flow biased setpoint currently required for the APRM upscale control rod block function.
Approval of this temporary relief is requested in order to perform certain f
surveillances scheduled to begin March 31, 1990.
This relief is also needed to allow restart of PNPS, which is currently scheduled for April 15, 1990.
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CIRCUMSTANCES REOUIRING A WAIVER OF COMPLI ANCE l
P11 grim Station is presently shut down for a scheduled maintenance outage.
In f
order to perform certain required surveillance tests, it is necessary to move the mode switch out of " shutdown".
The present outage schedule requires this testing begin on March 31, 1990 or the scheduled restart date at the end of the outage will be delayed.
Approval of this request is needed to begin the l
- testing, t
The impact of this problem on outage surveillances was not identified until March 29, 1990 while reviewing a related question, therefore BEco could not have foreseta the need for the exigent Technical Specifications change request j
or this request for waiver of compliance.
JUSTIFICATION AND SIGNIFICANT HAZARDS ANALYSIS The APRM Rod Block trip function is not a safety function.
Rather, it acts to block rod withdrawal to prevent an inadvertent scram.
The APRM rod block function is not part of any safety analysis in the FSAR.
Since the APRM rod block trip function is not a safety funrtion, and since the design of the APRM rod block is not being changed, this request for waiver of t
compliance:
(a) does not involve a significant increase in the probability or consequences of an accident previously evaluated; (b) does not create the possibility of a new or differeat kind of accident from any accident previously evaluated; and, (c) does not involve a reduction in a margin of safety.
Therefore, this request does not involve a significant hazards consideration.
In addition, because the function of APRM upscale rod block function is not affected by this request and is not a safety function, no compensatory actions e
are necessary. There are also no environmental consequences as a result of this request because the design of the plant is not affected.
CONCLUSION i
f BECo is preparing an exigent Technical Specification change request per 10CFR50.91(a)(6) for submittal by April 2, 1990.
The requested waiver of compliance is needed until the NRC completes its review and approval of our i
change request to avoid unnecessarily delaying critical path surveillance testing and subsequent restart from our present outage.
Pilgrim is presently scheduled to conduct survelliance tests requiring mode switch manipulation on l
March 31, 1990 and to restart on or about April 15, 1990. He therefore request i
the waiver of compliance be granted until such time as the NRC can complete its review and approve our Technical Specification change request.
This request has been reviewed and concurred with by the Operations Review Committee.
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.Please C) not hesitate to contact me if you have any questions Cr comments J
regarding this request.
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i cc:
Mr. Thomas T. Martin i
Regional Administrator i
V.S. Nuclear Regulatory Commission 475 Allendale Road King of Prushia, PA 19406 Mr. H, fairtile. Project Manager Director of NRR/USNRC e
Mail Stop: PI-137 Hashington, D.C. 20555 Senior NRC Resident Inspector - Pilgrim Nuclear Power Station t
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