ML20073K408

Application to Amend License DPR-35 Consisting of Proposed Change 83-4 to App a of Ets,In Response to NRC 780711 & 1115 Requests to Implement 10CFR50.34a(a),10CFR50.36a,10CFR20,50, App A,Gdc 60 & 64 & 40CFR190

ML20073K408
Person / Time
Site:	Pilgrim
Issue date:	04/15/1983
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20073K411	List: ML20073K408 ML20073K413
References
83-93, NUDOCS 8304200247
Download: ML20073K408 (4)

Text

-

y .

i GOsTON EDICON COMPANY f 800 BOYLETON STREET E057DN MABBACH6J5ETTE O2199 WILLIAM D. HARRINGTON

. . ... .. ........a April 15,1983 a= = =

BECo Letter No. 83-93 Proposed Change #83-4 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing <

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l License No. DPR-35 Docket No. 50-293

Subject:

Radiological Effluent and Environmental Monitoring Technical Specifi-cations (RETS)

Dear Sir:

Pursuant to Section 50.90 of the Commission's Rules and Regulations, Boston Edison Company hereby proposes the following modifications to Appendix A of the Operat-ing License.- This submittal replaces and voids a proposal contained in a Boston Edison letter dated February 21, 1979, which was subsequently modified by a Boston Edison letter dated July 2,1979.

Proposed Change Reference is made to Operating License No. DPR-35 and the Technical Specifica-tions ::entained in Appendix A. The proposed changes are contained in the pages of Attachment B of this submittal, and whose disposition is described below:

Replace pages in kind:

Table of Contents: 11, iii l

l Definitions: Sa i

! Other: 177, 178, 179, 179a, 180, 181, 182, 183, 184, 185, 186, 187, 188, 189, 190, 191, 192, 193, 213, 215, 222, 223, 223a Remove and do not replace:

179b , 183a , 183b , 183c , 183d , 185a , 185b , 185c , 185d , 187a , 187b , 187c , 187d ,

-191a, 191b, 223b Add new pages:

Definitions: Sb, Sc LC0: 178a , 178b , 178c , 178d , 181 a , 181b , 181c , 181d , 181e , 181 f , 182a , 182b ,

213a, 215a l

D OS

, 8304200247 830415 PDR ADOCK 05000293 6 g P PDR

[

'Ac; TON E! CON COM18ANY i JMr. Domenic B. Vassallo, Chief April 15,1983

.Page 2 l

. Operational Objectives: 229, 229a, 229b, 229c, 229d, 229e, 229e, 229f, 229g, i 229h, 2291, 2293, 229k, 2291, 229m, 229n, 2290,_

229p, 229q, 229r, 230, 231, 232, 233, 233a, 234,

. 235, 236, 237, 238,-239 Reason for Change The proposed changes respond to NRC requests that Boston Edison amend Pilgrim Station's Operating License. These requests were contained in letters dated July 11, 1978 and November 15, 1978. We initially responded by submitting a proposed change February 21, 1979.

Subsequent discussion between Boston Edison and the NRC resulted in a variety of changes which have been incorporated into the present submittal. This submittal supersedes in it's entirety, that of February 21, 1979.

Safety Considerations The proposed technical specifications are ' intended to implement the following Federal Regulations; 10CFR50.34a(a), 10CFR50.36a, 10CFR20, 10CFR50, Appendix A, General Design Criteria 60 and 64, and 40CFR190.

These changes have been reviewed by the Nuclear Safety Review and Audit Committee (NSRAC) and reviewed and approved by the Operations Review Committee (ORC).

Schedule of Change We request that these changes become effective 120 days after receipt of NRC approval. This is to allow adequate time to modify affected procedures and to provide operator training, thereby ensuring proper implementation.

1 Fee Detennination The major portion of the proposed change is an extension of the 10CFR Part 50, Appendix I design study _ submitted to the USNRC on June 2,1976, and constitutes completion of the requirements of Appendix I for the submittal of technical spe-cifications. Since fees were not applicable when the requirements put forth by Appendix ~ I to 10CFR Part 50 became effective,'and since the submittal of this has been delayed to' allow the receipt and assimilation of guidance from the NRC, we believe that this amendment is exempt from any fees defined in 10CFR Part 170.121

.(c).

Additional Information (1) We have provided justification for our revisions concerning items of Standard RETS not applicable to Pilgrim. These items are contained in Attachment A.

CCCTON EDt2DN COMPANY

. Mr. Domenic B. Vassallo, Chief Ar.ril 15, 1983 Page.3 (2) We have implemented a new section of techt.ical' specifications (Section 7),

titled " Operational Objectives." The technical specifications selected for insertion into this section were carefully reviewed against our definition of Limiting Condition of Operation (LCO) and determined to be outside the intent of this definition. Thus by placing them into the operational objec-tive section we have preserved the regulatory aspect of the technical speci-fication yet lessened the potential impact on operations.

(3) We intend to provide NRC with our proposed Offsite Dose Calculation Manual (0DCM) ir. approximately four weeks. This will allow approval by the ORC and review by NSRAC.

Very truly yours, Attachments A: Justifications for Revisions from STS B: Proposed Radiological Effluent and Environmental Monitoring Tech-nical Specifications (RETS)

Commonwealth of Massachusetts)

County of Suffolk )

Then personally appeared before me W.D. Harrington, who, being duly sworn, did state that he is Senior Vice President - Nuclear of 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 Boston Edison Company and that the statements in said submittal are true to the best of his knowledg and belief.

My Commission expires: OdMg/> jg M;M[ ' C

{ Notary 17uplic

/ M.f..W y.9 ns.. '

la!!E. % :

w. -

4.

l c,

O O

ATTACHMENT A 1

l t.

l. . . . - . . - . . . . _ _ _ . . . . _ _ . . _ _ _ . . _ . _ _ . _ _ . . . . . _ - . . _ . , . . . . , . . _ _ _ _ . _ . . . . . _ , _ . . _ . . _ . _ . , _ _ . _ _ . _ _ . , _ _ _ _ . . . _ . _ . . . . _ .

e

~

a JUSTIFICATION FOR PNPS REVISED RETS NOT ADDRESSING CERTAIN ITEMS IN STANDARD TECHNICAL SPECIFICATIONS (STS) FOR BWRs ITEMS MISSING FROM STS BWRs JUSTIFICATION I. 1.0 DEFINITIONS A. 1.30 Process Control Program (p. 1-2). PNPS does not have a Process Control Program.

B. 1.31 Solidification (p. 1-3). This definition applies to the Pro-cess Control Program which PNPS does not have.

C. 1.34 Ventilation Exhaust Treatment Not applicable to PNPS as a system System (p.1-3), during normal operations.

II.

3/4.11 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS A. LIQUID EFFLUENTS - INSTRUMENTATION

1. 3.3.7.11, Table 3.3.7.11-1, #2 - PNPS does not have these monitors.

Gross Radioactivity Monitors not Therefore, grab samples will be providing automatic termination obtained and analyzed on a weekly of release, plus ACTION 112 basis.

(p. 3/4 3-75).

2. 3.3.7.11, Table 3.3.7.11-1, #5 - PNPS does not have any temporary Tank Level Indicating Devices tanks outside of plant buildings.

(for tanks outside plant build- The only outside tanks are Conden-ings) (p. 3/4 3-74). sate Storage Tanks and this item is not meant to address the CSTs.

3. 3. 3. 7.11, Tabl e 4. 3. 7.11-1, #2 - PNPS does not have these monitors.

Gross Beta or Gamma Radioactivity Therefore, a grab sample will be l Monitors Providing Alarm but not obtained and analyzed on a weekly 1 providing automatic termination basis.

of release (p. 3/4 3-76).

4. 3.3.7.11, Table 4.3.7.11-1, #5 - PNPS does not have any tanks outside i

Tank Level Indicating Devices the buildings other than the Conden-(for tanks outside the butiding) sate Storage Tanks.

(p. 3/4 3-77).

B. GASEOUS EFFLUENTS - INSTRUMENTATION

1. 3.3.7.12, Table 3.3.7.12<1, #1 - This system is tied into the Main 2A & 28 - Main Condenser Offgas Stack effluent pathway.

Treatment System (p. 3/4 3-60).

O ITEMS MISSING FRDM STS BWRs JUSTIFICATION

6. 3. 3. 7.12, Tabl e 4. 3. 7.12-1, #6 - These building ventilation monitor-Auxila.y Building Ventilation ing systems are not applicable to Monitoring System, and #7, Fuel this BWR.

Storage Aroa Ventilation Moni-toring System (p. 3/4 3-67).

9. 3.3.7.12, Table 4.3.7.12-1, #8 - The Radwaste Area is tied into the Radwaste Area Ventilation Moni- Reactor Building Vent, and Turbine toring System, and #9 - Turbine Gland Seal Condenser ventilation is Gland Seal Condenser Vent and tied into the Main Stack effluent Mechanical Vacuum Pump Exhaust Pathway.

Monitoring System (p. 3/4 3-67).

C. LIQUID WASTE TREATMENT

1. 3.11.1.4, Liquid Holdup Tanks. PNPS currently does not have, nor expects to have, temporary liquid holdup tanks cutside of the plant.

, D. GASf0VS EFFLUENTS - DOSE RATE

1. 3.11.2.1, Table 4.11-2, A - Waste Gas Storage Tank and Contain-Waste Gas Storage Tank, and ment Purge are not cpplicable to B - Containment Purge PNPS.

(p. 3/4 11-9).

2. 3.11.2.1, Table 4.11-2, Table Not applicable to PNPS.

Notation #e (p. 3/411-9).

E. GASE0US RADWASTE TREATMENT

1. 3.11.2.5, Ventilation Exhaust Ventilation Exhaust Treatment is not

Treatment (p. 3/411-15). applicable to PNPS as a system during normal operations.

2. 3.11.2.6, Explosive Gas Mixture This system is not applicable to (Systems designed to withstand PNPS.

l a hydrogen explosion) l (p. 3/4 11-16).

i

3. 3.11.2.8, Mark I or II Contain- This item is optional.

ment (Optional) (p. 3/4 11-19).

F. SOLID RADIO?.CTIVE WASTE

1. 3.11.3, Process Control Program PNPS does not have a Process Control (p. 3/4 11-21). Program.

O ITEMS MISSING FROM STS BWRs JUSTIFICATION III. BASES A. 3/4.11.1.4 Liquid Holdup Tanks PNPS does not have, nor expects to have, temporary liquid holdup tanks outside of the plant.

B. 3/4.11.28 Mark I or II Contain- This item is optional ment (Optional)

C. 3/4.11.3 Solid Radioactive Waste PNPS does not have a Process Control Program.

IV. ADMINISTRATIVE CONTROLS A. 6.13 Process Control Program. PNPS does not have a Process Control Program.

V. REPORTING REQUIREMENTS B. 6.9.C.2 Annual Radiological The Annual Radiological Environmental Environmental Monitoring Monitoring Report will not include Report. comparisons to the preoperational studies. Unfortunately, the pre-operaticnal environmental study results for PNPS are too general for a meaningful comparison to current environmental program results.

l

2 Cl -

i ATTACHMENT B

.