ML20128N881
| ML20128N881 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/04/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20128N863 | List: |
| References | |
| NUDOCS 9610170059 | |
| Download: ML20128N881 (4) | |
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.....,o SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR RFGULATION RELATED TO AMENDMENT N0.167 TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDIS0N COMPANY PILGRIM NUCLEAR POWER STATION DOCKET N0. 50-293
1.0 INTRODUCTION
On September 12, 1995, the U.S. Nuclear Regulatory Commission (NRC) approved issuance of a revision to 10 CFR Part 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," which was subsequently published in the Federal Reaister on September 26, 1995, and became effective on October 26, 1995.
The NRC added Option B, " Performance-Based Requirements," to allow licensees to voluntarily replace the prescriptive testing requirements of 10 CFR Part 50, Appendix J, with testing requirements based on both overall leakage rate performance and the performance of individual components.
By application dated May 1, 1996, Boston Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for Pilgrim Nuclear i
Power Station. The revised TS references Regulatory Guide (RG) 1.163,
" Performance-Based Containment Leakage Test Program," which specifies a method acceptable to the NRC for complying with Option B dated September 1995.
The proposed changes would permit implementation of 10 CFR Part 50, Appendix J, Option B at the Pilgrim Plant by adopting the definitions and acceptance criteria proposed by the staff for implementation of Option B.
2.0 BACKGROUND
Compliance with 10 CFR Part 50, Appendix J, provides assurance that the primary containment, including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate specified in the TS and Bases.
The allowable leakage rate is determined so that the leakage assumed in the safety analyses is not exceeded.
On February 4, 1992, the NRC published a notice in the Federal Reaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety which impose a significant regulatory burden.
Appendix J of 10 CFR Part 50 was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous performance history of domestic containments and examined the effect on risk of a revision to the requirements of Appendix J.
The results of this study are reported in NUREG-1493, " Performance-Based Containment Leak-Test Program."
l 9610170059 961004 DR ADOCK 0500 3
. Based on the results of this study, the staff developed a performance-based approach to containment leakage rate testing. On September 12, 1995, the NRC approved issuance of this revision to 10 CFR Part 50, Appendix J, which was subsequently published in the Federal Reaister on September 26, 1995 (60 FR 49495), and became effective on October 26, 1995.
The revision added Option B, " Performance-Based Requirements" to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements baseo on both overall and individual component leakage rate performance.
RG 1.163 was developed as a method acceptable to the NRC staff for implementing Option B.
This RG states that the Nuclear Energy Institute (NEI) guidance document NEI 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J" provides methods acceptable to the NRC staff for complying with Option B with four exceptions which are described therein.
Option B requires that the RG or other implementation document used by a licensee to develop a performance-based leakage rate testing program must be included, by general reference, in the plant TSs.
The licensee has referenced RG 1.163 in the Pilgrim TSs.
RG 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests.
Type B tests may be extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.
By letter dated October 20, 1995, NEI proposed TS to implement Option B.
After some discussion, the staff and NEI agreed on final TS which were attached to a letter from C. Grimes (NRC) to D. Modeen (NEI) dated November 2, 1995.
These TS are to serve as a model for licensees to develop plant specific TS in preparing amendment requests to implement Option B.
For a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must be established. The administrative limit is selected to be indicative of the potential onset of component degradation. Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements.
Failure to meet an administrative limit requires the licensee to return to the minimum value of the test inttrval.
Option B requires that the licensee maintain records to show that the criteria for Type A, B, and C tests have been met.
In addition, the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate.
These records are subject to NRC inspection.
. 3.0 EVALUATION The licensee's May 1,1996, letter to the NRC proposes to revise the TSs to reflect the implementation of 10 CFR Part 50, Appendix J, Option B at the Pilgrim Station.
The amendment changes the TSs to implement 10 CFR Part 50, Appendix J, Option B, by referring to RG 1.1.63, " Performance-Based Containment Leakage-Rate Testing Program." RG 1.163 references NEI 94-01 and ANSI /ANS-56.8-1994 as described above.
The revised TSs will reference RG 1.163, which specifies a method acceptable to the NRC for complying with Option B.
This requires a change to existing TS 4.7, " Primary Containment Integrity." Corresponding bases were also modified.
Option 8 permits a licensee to choose Type A; or Type B and C; or Type A, B, and C; testing to be done on a performance basis.
The licensee has elected to perform Type A, B, and C testing on a performance basis.
j The licensee has proposed changes to surveillance requirement TS 4.7.A.2 to reference 10 CFR Part 50, Appendix J, Option B, and RG 1.163, " Performance-Based Containment Leakage-Rate Testing Program." The licensee has also redefined P L
and the leakage rate acceptance criteria to be consistent withthemobelI,SprovidedtofiElbyletterdatedNovember2,1995.
The staff did note that the licensee did not adopt all the acceptance criteria of the NEI document for the primary containment.
By conference call on June 27, 1996, the staff discussed this with the licensee and the licensee agreed that the NEI wording was applicable to Pilgrim. The licensee supplemented its application by modifying the proposed TS to add the following to the primary containment criteria as proposed in the NEI document: "During the first unit startup following testing in accordance with the Containment Leakage Rate Testing Program, the leakage rate acceptance criteria are < 0.6 L, for the Type B and Type C tests and < 0.75 L for the Type A tests." This modificationiswithinthescopeoftheoriginalnoticeoftheapplication.
In addition, consistent with the model the licensee has noted that definition 1.U (test interval extension) is not applicable to the Leak Rate Test as Option B already includes a 25% extension of the test interval.
Previous exemptions approved by the staff and exceptions noted in the TSs were maintained.
The staff has reviewed these proposed changes and concluded that, despite the different format of the licensee's current TSs, all the important elements of the guidance regarding Type A, B, and C testing provided in the NRC letter to NEI are included in the TS proposed by the licensee and the proposed changes are in compliance with the requirements of Option B and consistent with the guidance of RG 1.163, and the generic TS of the November 2,1995, letter and are, therefore, acceptable to the staff.
4.0 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.
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5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a j
facility component located within the restricted area as defined in 10 CFR j
Part 20 and changes surveillance requirements.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no i
significant change in the types, of any effluents that may be released i
offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a j
proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (61 FR 28606). 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) no environmental impact statement or environmental assessment need be i
prepared in connection with the issuance of the amendment.
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6.0 CONCLUSION
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The Commission has concluded, based on the considerations discussed above, i
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 l
activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common j
defense and security or to the health and safety of the public.
l Principal Contributor:
A. Wang i
Date:
October 4, 1996 l
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