ML20206C350

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Forwards Draft Safety Evaluation & SALP Input Re 850412 Proposed Rev to Tech Specs for Surveillance Requirements. Apparent Conflict Identified in Tech Spec Table 4.2.F & Sts. Eighteen Month Calibr Frequency Acceptable.Salp Input Encl
ML20206C350
Person / Time
Site: Pilgrim
Issue date: 11/04/1985
From: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Thompson H
Office of Nuclear Reactor Regulation
Shared Package
ML20206C347 List:
References
FOIA-88-198 TAC-57510, NUDOCS 8811160239
Download: ML20206C350 (7)
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NUCLEAR REGULATORY COMMi$$10N A

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4 NOV 195 Oocket No. 50-291 ..

MEMORANDUM FOR: Hugh L. Thompson, Jr. , Director Olvision of Licensing, NRR I FROM: Richard W. Starosteckt, Director  !

Olvision of Reactor Projects, RI

SUBJECT:

LICENSING ACTION REVIEW FOR PILGRIM - PROPOSED REVISIONS TO TECHNICAL SPECIFICATIONS OF SURVEILLANCE INSTRUMENTATION (TAC #57510)

Region I has reviewed the Boston Edison Company's request dated April 12,.1985, I to change the calibration frequency for the reactor level, reactor pressure and i drywell pressure surveillance instrument channels in Technical Specification l Table 4.2.F from once per six months to each refueling outage. The licensee  !

provided information to extend ihe frequency to once each 18 months.

Technical Specifications define refueling outage, for the purpose of surveillance inter-vals is a regularly scheduled outage unless the regularly scheduled outage i occurs within eight months of completion of a plant refueling outage. This definition as well as the schedules indicated in the Long Term Program issued ,

as Amendment 75 to the facility license, which defines the regularly scheduled '

outages, can exceed 18 months. The SE was written as agreed by the Project Manager, Paul Leech, based upon an 18 month calibration frequency in lieu of i the licensee's proposal for a refueling outage frequency. Therefore, the l licensee will need to modify their request for change in the calibration fre-  ;

quency from once each refueling outage to once each 18 months. Enclosed is a -

modified technical specification page which describes the type of changes ,

needed to satisfy the SE. The Project Manager also agreed to obtain the  :

licensee submittals to reflect the SE. As stated in the enclosed safety ,

evaluation, an 18 month calibration frequency change was found to be accept- '

able. The SALP input for TAC 57510 is enclosed.

This review also identified an apparent conflict in Table 4.2.F and the Standard Technical Specifications (STS). Specifically, the STS require an 18 month calibration frequency for the safety / relief valve position indicators, tcrus water level, and primary containment pressure; whereas, the Pilgrim 1 Technical Specifications specify each refueling outage. For the sama reasons c as stated above, each refueling outage can exceed 18 months. These sensors i provide similar surveillance information to those requested in TAC 57510. This l fact is provided for your information. l

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I CONTACT: Donald R. Haverkamp, RI (FTS 488-1236) [,

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! 8811160239 001010 I PDR FOIA '

JOHNSONOO-190 PDR l Hll l

i Memorandua for Hugh L. Thompson, Jr. 2 This review supersedes our prior licensing action review for Pilgrim forwarded I by letter Starosteckt to Thompson dated June 24, 1985 and completes the i requested Region ! a.ction for TAC 57510. The principal technical reviewers for  :

this licensing action were Donald J. Florek and Ernesto C. Vanterpool, DRS.

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Richard W. tarostec\i, Director

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Division of Reactor Projects }

Enclosures:

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1. Safety Evt..uation Report .
2. SALP Input
3. Modified Technical Specification cc w/encis: I G. Lainas, AD/OR, NRR I J. Carter, TA, AD/OR, NRR l D. Vassallo, Chief, ORB-2, NRR l P. Leech, FM, ORB-2, NRR l

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ENCLOSURE 1

.. SAFETY EVALVATION SUPPORTING AMENOMENT NO. TO FACILITY OPERATING LICENSE NO. OPR-35 BOSTON EDISON COMPANY e PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 Introduction and Background By letter dated April 12, 1985, (Reference 1), and letter dated ,

(Reference 2) Boston Edison Company (the licensee) proposed to amend its opera-ting license, OPR-35 by modifying the Ptigrim Nuclear Power Station Technical Specifications.

The proposal would change the calibration frequency for the reactor level, reactor pressure and drywell pressure surveillance instrument channels in Technical Specification Table 4.2.F from once every six months to once each 18 months.

The licensee, during a recent refueling cutage, replaced the existing GEMAC transmitters with Rosemount transmitters, Model Numbers 11520P and 1152GP.

This replacement was made because the GEMAC transmitters are obsolete and replacement parts are unavailable.

A Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on May 21,1985 (50 FR 20970) for hearing and no pubite comments were received.

Evaluation The reactor level, reactor pressure and drywell pressure surveillance instru-l ment channels provide indication of plant status. The subject instruments do not provide any automatic actuation of safety systems, and therefore, the change does not affect any engineered safeguards actuation system (ESAS).

The surveillance requirements (SR) for the reactor level, reactor pressure, and drywell pressure surveillance instrument channels also include an instrument l check each shift, as specified by Technical Specification (TS) Table 4.2.F.

The instrument checks for the above surveillance instrument channels will remain unchanged by this amendment.

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Enclosure 1 2 The licensee's request for a decrease in the calibration frequency from 6 months to 18 months for the Rosemount transmitters is supported by the General Electric Licensing. Topical Report NEDO-21617-A, Class I dated December, 1978, "Analog Transmitter / Trip Unit System For Engineering Safeguard Sensor Trip Inputs". By letter dated June 27, 1978, the Commission reviewed and found the report acceptable for reference in license applications.

The NEDO-21617-A recommended frequency of calibration for these type transmit-ters is 12 to 18 months.

Based upon the al.ve, the staff finds that the proposed change to the subject technical specification calibration frequencies will not involve any pnysical change to the plant safety related systems, components or structures, will not increase the likelihooo of a malfunction of sTfety related equipment, will not increase the consequences of an accident prtviously analyzed, nor create the possibility of a malfunction different from those previously evaluated. The staff therefore finds the licensee's requestec change of calibration frequen-cies for the reactor level, reactor pressure aad drywell pressure instrument channels from once every 6 months to once each 18 months to be acceptable.

Environmental Consideration This amendment involves changes in the installation or use of a facility com-ponent located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements. The amendment also relates to a change in recordkeeping, reporting and administrative requirements. We have deter-mined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released of f-site, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a pro-posed finding that this amendment involves no significant hazards consideration and there has been no public comment on such findings. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Conclusion We 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 endangered by operation in the proposed manner; and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

l Enclosure 1 3 m

I Referecces (1) Boston Edison Company letter W. D. Harrington to D. B. Vassallo, "Proposed i Technical Specification Change Calibration Frequency for Certain Rosemont ,

Transmitters". April 12, 1985.

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Principal Contributors: Donald J. Florek and Ernesto C. Vanterpool, r,1 vision I of Reactor Safety , i 0

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h Enclosure 2 '

SALP INPUT ON TAC #57510 Factitty: Pilgrim t Licensee: Boston Edison Company Docket: 50-293 l Request: Memorandurt Thompson to Starosteckt dated 4/12/85 g Functional Area: Licensing Activities  ;

f Reviewer: D. Florek and E. Vanterpool The Itcensee was very responsive to requests for clarification of their pro-posal. Based on their request and clarifying information, it allowed prompt and efficient evaluation of the proposed change. Had the clarifying infor- l mation been included with the original proposal, no additional information t would have been required to evaluate the change.

Overall Conclusion - Category 1 s

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FNFS TAalz 4.2.F MINDRM 1T.ST AMD CALIBRATION FREQUENCY FOR SURVEILLANCE INSTRIDENT{0_N Calibration Frequency Instrument Check Instrument Chaemel (B

1) Reactor Imvel Once s taaethe or kc d h4 Each Shift
2) anactor Pressure Once months .< Once < yed gc d Each Shift
3) Drywell Pressure Once/9Caonths .r dge Io{td C4ckt Each Shift Once/6 months Each Shift
4) Drywell Temperature once/6 asethe Each Shife
5) Suppression O. amber Temperature Scypression Osamber Water Lawel Once/6 monthe Each Shift
6) ,

MA Each Shift

7) Control mod Position

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Neutros Moeitering (2) Each ShifC ,

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Once/6 monthe Each Shift k 9) Drywell/ Terms Differential Freneure E.

d Drywell Pressure Once/6 months Each Shift M g 10) (,g"Torue Pressure Once/6 monthe

,, U x D o Once each day Each refueling O

11) Safety / Relief Valve Fooition Indicator outaga [

(Primary / Secondary) e Once cach day 0

8' 12) Safety Valve Fooition Each refueling Indicator (Primary /

Secondary) outage as la~uns AMa s' M ies Mht 7td c

% N< ' 'N T.

M n k nt No. 48

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