ML20073D044

Safety Evaluation Supporting Amend 136 to License DPR-35

ML20073D044
Person / Time
Site:	Pilgrim
Issue date:	03/21/1991
From:	Office of Nuclear Reactor Regulation
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ML20073D041	List: ML20073D044
References
NUDOCS 9104260132
Download: ML20073D044 (4)

Text

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WAsHINoToN. D C Aus g '.v....f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.136 TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

By letter dated February 6,19M, Boston Edison Company (TS) appended to (thelicensee) requested an amendment to the Technical Specifications Facility Operating License No. OpR-35 for the Pilgrim Nuclear power Station.

Theamendmentwould(1)deletethereferencetoasoecificdatefor10CFRPar 50, Appendix J. Section 4.7. A.2.a. (2) delete Table 3.7-1, " primary Containment and Reactor Vessel isolation Valves," and the references thereto, and (3) clarify sections 4.7. A.2.b.1.a and 4.7.A.2.b.1.b by adding the words " primary containment." This amendment would permit the updated Final Safety Analysis Report and plant procedures to serve as the primary reference for identifica-tion of primary containment isolation valves and their associated closure time limits, normal position and group assignments.

A discussion of the proposed changes and the NRC staff's evaluation and findings relative to each are addressed in Section 2 of this Safety Evaluation Report.

2.0 EVALUATION The request to remove the date from the TS and associated bases of 10 CFR 50 Appendix J, is administrative. As currently written, Pilgrim's Appendix J requirements are restricted to the dated amendment and therefore must be changed for each new amendment to remain current, if so desired. This is an unnecessary burden for the licensee and the staff.

By deleting the date, the licensee is able to remain current with Appendix J changes without submitting TS changes.

The Comission's defense-in-depth policy for public safety requires that containment integrity be available in the event of an accident.

In the event of an accident involving the loss of integrity of the fuel cladding and reactor coolant system, the primary cor.tainment would be the final line of defense serving to limit the release of radioactive material.

Since operability of open isolation valves is necessary for containment integrity, the staff rewires that the facility TS contain appropriate limiting conditions for operation (LCOs) and surveillance requirements (SRs) for containment isolation

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a The Pilgrim TS presently contain such LCO's and SRs.

Also, the valves to which the TS requirements apply are individually identified in a " primary Containment Isolation" table in the FSAR.

Under the terms of current regulations, any time the f acility is to be modified in such a way as to involve the Primary Contain.

ment isolation Table, (i.e. addition of a new system that requires isolation valves, change of name of a valve's nomenclature, deletion of a deactivated system, or change of valve closure rate to conform to a reanalysis) the table must be amended via the 10 CFR 50.90 procest even though the actual f acility change may have been previously approved by the Commission, involves no unresolved safety issue, and is clearly within the intended scope of changes permissible via the 10 CFR 50.59 process, wherein prior NRC approval is not required.

However, in addition to the above process for updating the table of containment isolation valves in the FSAR, the licensee has to prepare a license amendment request to update the list of containment isolation valves in Table 3.7 1 of the TS.

The preparation, review, and issuance of such amendments presents an unnecessary administrative burden to the licensee and staff.

The Commission's Interim Policy Statement on TS improvements recognited the advantages of simplified and improved TS and endorstd the recommendations of the nuclear industry and NRC staff for a progom to develop improvements in facility TS. The proposed pilgrim change hts been implemented in the TS for recently issued facilities and is consistent with guidance provided by Generic Letter 84 13 regarding removal of snubber lists.

Finally, the addition of the words " primary containment" are being added to section 4.7.A.2.b.1.a and 4.7.A.2.b.1.b for clarty only.

The staff finds that the proposed change will retain the LCOs and SRs in the TS to ensure containment integrity, and also implement on acceptable line-item improvement of the Technical Specifications Improvement program. The staff, therefore, concludes that the proposed amendment is acceptable.

3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment.

The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to installation or use of a f acility component located within the restricted area as defined in 10 CFR part

20. The changes, in part, are also administrative in nature. The NRC staff has determined that the amendment involves no significant increase in the amounts, and.no significant change in the types, of any effluents that may be released offsite and that there is no si occupatIonalradiationexposure.ghificantincreaseinindividualorcumulative The Commission has previously issued a proposed finding-that the amendment involves no significant hazards consideration and there 1

has been no public comment on such finding (56 FR 9374). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9)and(10).

Pursuantto10CFR$1.22(b),noenvironmental impact statement or environmental assessment need ba prepared in connection with the issuance of the amendment.

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5.0 -CONCLUSION.

LWe have concluded. based on the considerations discussed above, that (1) there

- is reasonable assurance that the health and safety of the public will not be-endangeredbyoperation-intheproposedmanner,and(2)such-activitieswillbe

- conducted in compliance with the Comission's regulations, (3) and the issuance of:this amendment will not be inimical to the comon defense and security or to the health-and safety of the public.

Principal Contributor:. R. Eaton f

Dated: March 21, 1991.

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' AMENDMENT 110,136 TO DPR-35 PILGRIM NUCLEAR POWER STATION DATED April 22, 1991 DISTRIBUTION:

EcEI~TW50-293 *4 NRC PDR Local PDR PDl-3 Reading S. Varga C. Grimes J. Calvo M. Rushbrook R. Eaton R. Wessman 0GC - 15 B18 Dennis Hagan - MNBB 3206 E. Jordan - MNBB 3701 B, Grimes - 9 A2 G. Hill (3) - P1-37 Wanda Jones - MHBB 7103 K. Brockman ACRS(10)-P-315 GPA/PA - 2 G5 0C/LFMB - MNBD 11104 J. Rogge, Region I

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