ML20117N935

Application for Amend to License DPR-35,consisting of Proposed Change 85-06,revising Radiological Effluent & Environ Monitoring Tech Specs.Justification Encl

ML20117N935
Person / Time
Site:	Pilgrim
Issue date:	05/14/1985
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20117N936	List: ML20117N935 ML20117N941
References
85-087, 85-87, NUDOCS 8505200282
Download: ML20117N935 (7)

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BOSTON EDISON COMPANY S00 BovLSTON ETREET SOSTON, MASSACNUSETTS O2199 wtLLIAM O. HARS6NSTON May 14, 1985 BECo 85-087 Proposed Change 85-06 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 License DPR-35 Docket 50-293 1

Subject:

Radiological Effluent and Environmental Monitoring Technical Specifications (RETS)

Dear Str:

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 Operating License. This submittal replaces and volds proposals contained in Boston Edison letters dated February 21, 1979, July 2, 1979 and April 15, 1983.

Proposed Change ,

Reference is made to Operating License No. OPR-35 and the Technical Specifications contained in Appendix A. The proposed changes are contained in the pages of Attachment B of this svimittal, and whose disposition is described below:

Replace pages in kind:

Table of Contents: 11, til Definitions: 5a Other: 43, 44, 56, 64, 72, 76, 77, 177, 178, 179, 180, 181, 182, 183, 184, 185, 186, 187, 188, 189, 190, 191, 192, 193, 223, 223a Remove and do not replace:

179a, 179b, 183a, 183b, 183c, 183d, 185a, 185b, 185c, 185d, 187a, 187b, 187c, 187d, 191a, 191b, 223b e50520gegQ c f y ,jp

g, ef BOSTON EDISON COMPANY Mr. Domenic B. Vassallo, Chief May 14, 1985 Page 2 Add new pages:

Definitions: Sb Other: 193a, 193b, 193c, 193d, 193e, 193f, 229 thru 249 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 8 July 11, 1978 and November 15, 1978. He initially responded by submitting a proposed change February 21, 1979.

Subsequent discussions between Boston Edison and the NRC resulted in a variety of changes which were incorporated into an April 15, 1983 submittal.

A review meeting of the April 15, 1983 submittal was held at Pilgrim Station starting on-June 7, 1984. The attached submittal again revises BECo's proposed changes and is the result of the June '84 meeting with the NRC. This submittal supersedes in its entirety that of April 15, 1983.

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).

Safety Hazards Consideration The Commission has provided guidance for the application of the standards for determining whether a significant hazards consideration exists by providing examples of amendments that are considered not likely to involve significant hazards considerations (48 FR 14870). One such amendment involves a change to-make a license conform to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

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BOSTON EDISON COMPANY -

Mr. Domenic B. Vassallo, Chief May 14, 1985 Page 3 The change proposed by BECo is intended to implement 10 CFR 50.34(A); 10 CFR 50.36 (A); 10 CFR 20; 10 CFR 50, Appendix A, General Design Criteria 60 and 64, and 40 CFR 190. This amendment, therefore, reflects changes to make the Pilgrim license conform to changes in the regulations. Since BECo is presently obligated by these regulations to control and limit offsite releases of radioactive materials to levels which are as low as is reasonably achievable, this license change will only result in very minor changes to facility operations which are clearly in keeping with the regulations.

Therefore, since the application for amendment involves proposed changes that are similar to the examples for which no significant hazards consideration exists, BECo has made a proposed determination that the appilcation for amendment involves no significant hazards consideration.

Schedule of Change He request that these changes become effective 180 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.

Fee Determination 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 specifications. 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 170.12(c).

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

(2) He have implemented a new section of technical 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

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p.4, ~' BOSTON EDIS0N COMPANY

.Mr. Domenic B. Vassallo, Chief

.May 14, 1985 Page 4 be outside the intent of this definition. Thus by placing them into the operational objective section we have preserved the regulatory aspect of the technical specification yet lessened the potential impact on operations.

Very truly yours, GGW/ns N Attachment A: Justifications for Revisions from STS not addressed

-Attachment 8: Proposed Radiological Effluent and Environmental Monitoring Technical 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 the 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 the Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My Commission expires: p,xm4m o, n ey /J 7L . < /#/y/c/#) @X Notary 'Public

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., ATTACHMENT "A" JUSTIFICATION'FOR PNPS REVISED RETS NOT ADDRESSING CERTAIN ITEMS IN STANDARD TECHNICAL SPECIFICATIONS (STS) FOR BWRs

-BWR-STS ITEMS

'NOT ADDRESSED JUSTIFICATION-I. 1.0 DEFINITIONS A. 1.30 Process Control Program (p. 1-2). PNPS does not have a Process Control Program (PCP) as defined in Standard Technical Specifications. The methods used to accomplish the processing and packaging of solid radioactive waste material are procedurally addressed. These procedures are required by T.S. Section 6.8 and are reviewed and approved by the ORC per T.S.

Section 6.5.A.6.

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

C. 1.34 Ventilation Exhaust Treatment Not applicable to PNPS as a system during System (p. 1-3). 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 obtained providing automatic termination of and analyzed on a weekly basis.

release, plus ACTION 112 (p. 3/4 3-75).

2. 3.3.7.11, Table 3.3.7.11-1, #5 - PNPS does not have any temporary tanks Tank Level Indicating Devices (for outside of plant buildings. The only tanks outside plant buildings) outside tanks are Condensate Storage Tanks (p. 3/4 3-74). and Fire Water Storage Tanks. This item is not meant to address the CSTs or Fire Water Storage.

3. 3.3.7.11, Table 4.3.7.11-1 #1 - The instruments that provide this Gross Radioactivity Monitoring monitoring which have been in use at PNPS Providing Alarm and Automatic since startup (1972) do not have built-in Termination of Release (pg 3/4 source checks. Therefore, this 3-76). surveillance does not apply (NA).

4. 3.3.7.11, Table 4.3.7.11-1, #2 - PNPS does not have these monitors.

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

providing automatic termination of release (p. 3/4 3-76).

5. 3.3.7.11, Table 4.3.7.11-1, #5 - PNPS does not have any tanks outside the Tank Level Indicating Devices (for buildings other than the Condensate Storage tanks outside the building) Tanks and Fire Water Storage.

l' (p. 3/4 3-77).

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BWR-STS ITEMS NOT ADDRESSED JUSTIFICATION B. GASEOUS EFFLUENTS - INSTRUMENTATION  :

1. 3.3.7.12 Table 3.3.7.12-1, #1 - ThissystemistiedintbtheMainStack 2A & 28 - Main Condenser Offgas effluent pathway.

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

2. 3.3.7.12, Table 4.3.7.12-1, #6 - These building ventilation monitoring Auxiliary Building Ventilation systems are not applicable to PNPS.

Monitoring System, and #7, Fuel Storage Area Ventilation Monitoring System (p. 3/4 3-67).

3. 3.3.7.12, Table 4.3.7.12-1, #8 - The Radwaste Area is tied into the Reactor Radwaste Area Ventilation Building Vent, and Turbine Gland Seal fionitoring System, and #9 - Condenser ventilation is tied into the Main Turbine Gland Seal Condenser Vent Stack effluent Pathway.

and Mechanical Vacuum Pump Exhaust 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 outside of the plant.

D. GASE0US EFFLUENTS - DOSE RATE

1. 3.11.2.1, Table 4.11-2, A - Haste Haste Gas Storage Tank and Containment Gas Storage Tank, and B - Purge are not applicable to PNPS.

Containment Purge (p. 3/4 11-9).

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

Notation, #e (p. 3/4 11-9).

E. GASEOUS RADWASTE TREATMENT

1. 3.11.2.5, Ventilation Exhaust Ventilation Exhaust Treatment is not Treatment (p. 3/4 11-15). appilcable to PNPS as a system during normal operations.

2. 3.11.2.6, Explosive Gas Mixture This system is not applicable to PNPS.

(Systems designed to withstand a hydrogen explosion) (p. 3/4 11-16).

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

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

F. SOLID RADI0 ACTIVE WASTE

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

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BWR-STS ITEMS NOT ADDRESSED 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 Containment Thl: ltem is optional.

(Optional)

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

IV. ADMINISTRATIVE CONTROLS A. 6.5.1.6.1 ORC Review PNPS does not have a Process Control Program. Audits of the radiological 6.5.2.8.K-n NSRAC Review v monitoring program and Reg. Guide 4.1 are encompassed under existing specification 6.13 Process Control Program 6.5.8.8.5. The 00CM will be included as a reference in the audit scope of the radiological monitoring 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 preoperational environmental study results for PNPS are too general for a meaningful comparison to current environmental program results.

VI. RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.3 Interlaboratory Comparison PNPS does not analyze environmental media.

Program. Analysis of PNPS environmental media is conducted by the Yankee Atomic Environmental Laboratory (YAEL). YAEL participates in an interlaboratory comparison program with the EPA, and this information is available to the NRC upon inspection.

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