BECO-85-210, Application for Amend to License DPR-35,changing Tech Spec Surveillance Requirement for Scram Insertion Time to Require Only 10% of CRDs Be Tested on Rotating Basis at Least Once Per 120 Days of Operation.Fee Paid

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Application for Amend to License DPR-35,changing Tech Spec Surveillance Requirement for Scram Insertion Time to Require Only 10% of CRDs Be Tested on Rotating Basis at Least Once Per 120 Days of Operation.Fee Paid
ML20136H694
Person / Time
Site: Pilgrim
Issue date: 11/19/1985
From: Harrington W
BOSTON EDISON CO.
To: Vassallo D
Office of Nuclear Reactor Regulation
Shared Package
ML20136H698 List:
References
BECO-85-210, NUDOCS 8511250179
Download: ML20136H694 (3)


Text

.4 EOSTON EOl5DN COMPANY B00 EDVLaTON STREET WasTON, MAESACHUBETTs 02199 WILLIAM O. HARRINGTON esmesevees PASG898NT

.6.

November 19, 1985 BECo 85-210 Proposed Change 85-13 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 Proposed Technical Specification Change Scram Insertion Time

Dear Sir:

Pursuant to the provisions of 10CFR50.90, the Boston Edison Company hereby proposes the attached modifications to Appendix A of Operating License DPR-35.

This proposed modification to the surveillance testing of control rod drives conforms to the present Standard Technical Specification frequency.

Very truly yours, f

ERM/ns 3 signed originals and 40 copies Commonwealth of Massachusetts)

County of Suffolk

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Then personally appeared before me H. 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: th. d;////

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= o o Proposed Amendment to Technical Specifications Scram Insertion Time A.

Narrative The present Technl' cal Specification surveillance requirement for Scram Insertion Time for control rods requires that 50% of the control rod drives'shall be tested each 16 weeks.

This results in the complete testing of all control rods every 32 weeks.

This' commitment is more stringent than the Standard, and results in more wear to the control rod system.

The Standard Technical Specification only requires that 10% of the control rods be tested, on a rotating basis, at least once per 120 days of operation.

B.

Reason for Change The recommended Technical Specification is based on the Standard Technical Specification and is consistent with current industry practice for BWRs.

Pilgrim Station currently tests for scram speed deterioration at a surveillance rate 5 times greater than that recommended in the Standard TecMical Specifications.

The surveillance level of testing a minimum of 10 percent of the control rods, on a rotating basis, every 120 days of operation, provides adequate assurance that the rods are operating, but is not so frequent as to cause excessive wear on the components.

C.

Safety Considerations These changes do not present an unreviewed safety question as defined in 10CFR50.59.

They have been reviewed and approved by the Operations Review Committee, and reviewed by the Nuclear Safety Review and Audit Committee.

D.

Significant Hazards Consideration The NRC has provided guidance concerning the application of standards for determining whether license amendments involve significant hazards considerations by providing certain examples (48FR14870).

The change of the Technical Specification survelliance to lessen the frequency of testing for control rods constitutes:

(vi) A change which either may i

l result in some increase to the probability or consequences of-a previously analyzed accident or may reduce in some way a safety margin, but where the l

results of the changes are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan; for example, a change resulting from the application of a small refinement of a previously used calculational model or design method.

It is our conclusion, based on safety analysis, that a scram testing surveillance which tests a minimum of 10 percent of the control rods every

'f

o 120 days of operation, on a rotating basis, would not (1) involve a significant increase in the probability or consequence of an accident previously evaluated because reducing the surveillance level will reduce wear on control rod components; (2) create the possibility of a new or different kind of accident from any accident previously evaluated because the surveillance frequency, although reduced, conforms to the acceptance criteria of the Standard Review Plan for functional design of control rod

^

drive systems; or (3) involve a significant reduction in a margin of

.g safety because the testing period has been determined to be adequate to ensure safety margins.

This reduction in scram testing frequency provides continued assurance that proper performance is being maintained.

This conclusion is based on (1) historical evaluation of the performance of the control rod scram capability at Pilgrim; (2) other control rod surveillance requirements.

The other requirements which provide assurance of the integrity of the control rod system are, (1) weekly control rod exercise', and (2) scram time speed measurements made prior to full power operation af t$r refueling.

E.

Schedule of Change This amendment will be effective 30 days after receipt of approval by the NRC/

F.

Application Fee Pursuant to 10CFR170.12(c), Boston Edison classifies this change as a Class III amendment. On 7/30/85, Boston Edison check #913949 was issued i

and forwarded to NRC as an application fee for our EQ extension letter.

This was inadvertently forwarded as a duplicate application fee for the same subject for which NRC had received our check #895937.

In order to properly balance our account, please apply BECo check #913949 as the

-application fee for this Proposed Technical Specification Amendment submittal.

I