ML20236X713

Forwards Info in Support of Proposed TS Amend Re EDG Allowed Outage Time in Ltr Dtd 960425.Ltr Commits to Implementing Appropriate Administrative Controls & Minimize Risk of Loss of off-site Power by Ensuring Weather Conditions

ML20236X713
Person / Time
Site:	Pilgrim
Issue date:	07/31/1998
From:	Alexander J BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236X715	List: ML20236X713 ML20236X719
References
LTR-2.98.103, TAC-M95277, NUDOCS 9808100207
Download: ML20236X713 (3)

Text

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l. 10 CFR 50.90 l 0 i sosronsosson Pilgrim Nuclear Power Station 600 Rocky Hill Road l Plymouth, Massachusetts 02360 l July 31,1998 BECo Ltr. 2.98.103 US Nuclear Regulatory Commission i Attention: Document Control Desk l Washington, DC 20555 l Docket No. 50-293 l

License No. DPR-35 l

Supplement to Emergency Diesel Generator Allowed Outaae Time Technical Specification Amendment (TAC No. M95277) l Boston Edison Company (BECo) is providing the attached information in support of the proposed technical specification (TS) amendment related to the emergency diesel generator allowed outage time (reference BECo Letter No.96-040, dated April 25, 1996). This letter commits to implementing appropriate administrative controls that minimize the risk of a loss of off-site power by ensuring weather conditions are evaluated prior to removing the EDG or SBO-DG from service.

Should you have any questions regarding this letter, please contact Walter Lobo at (508) 830-7940.

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! edg1. doc V l Attachment A: BECo Response to NRC Request for Additional Information Attachment B: Revised T.S. Page 3/4.0-5 l cc: Mr. Alan B. Wang, Project Manager Mr. Robert Hallisey Project Directorate I-3 Radiation Control Program Office of Nuclear Reactor Regulation Center for Communicable Diseases ]

Mail Stop: OWFN 14B2 Mass. Dept. of Public Health J 1 White Flint North 305 South Street 11555 Rockville Pike Jamaica Plain, MA 02130 .

Rockville, MD 20852 1

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U.S. Nuclear Regulatory Commission Mr. Peter LaPorte, Director Region i 475 Allendale Road King of Prussia, PA 19406 Mass. Energy Management Agency 400 Worcester Road P.O. Box 1496

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Framingham, MA 01701-0313 Senior Resident inspector Pilgrim Nuclear Power Station gOl n

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9808100207 980731 PDR ADOCK 05000293 P PDR j

1 8 ATTACHMENT A BECo Response to NRC Reauest for Additional Information EDG AOT Technical Specification Amendment (TAC No. M95277) l References j

1. Boston Edison Company Letter No.96-040, " Proposed Technical Specification Changes," dated April 25,1996.

2. Boston Edison Company Letter No.96-080, " Response to Request For Additional  ;

Information Regarding Emergency Diesel Generator Allowed Outage Time  ;

Technical Specification Change (TAC No. M95277)", dated September 5,1996.

3. Boston Edison Company Letter No.97-082, " Supplement to Emergency Diesel Generator Allowed Outage Time Technical Specification Change (TAC No.

M95277)", dated August 8,1997.

4. Boston Edison Company Letter No.98-030, " Supplement to Emergency Diesel Generator Attowed Outage Time Technical Specification Change (TAC No. ,

M95277)", dated March 26,1998. l Backaround BSCo filed a request (Ref.1) for a TS amendment to extend the current emergency diesel generator (EDG) allowed outage time (AOT) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. Subsequently, three 4 otner letters (Refs. 2, 3 and 4) were submitted in response to NRC requests for additional ,

information. This letter addresses the following issues raised by the NRC staff during the April 13,1998, telephone call with our staff:

• (Ref. 2, page A3) NRC question 2.f: Component testing or maintenance that increases the likelihood of a plant transient should be avoided; plant operation should be stable during the EDG PM.

The BECo response is revised to state, "This policy is implemented by procedure 1.2.2,

" Administrative Ops Requirements, Attachment 11, item (4) (Discussion section). This attachment provides guidance vor oo-line LCO maintenance and directs that 'other maintenance or testing that increases the likelihood of a plant transient should be avoided.'

Also, procedure 1.2.2 requires the NWE to assess the impact of concurrent activities on plant performance prior to removing equipment from service. This provides assurance plant operation will be stable while EDG PMs are performed."

• (Ref. 2, page A9) NRC question 7.a: Discuss the impact of severe weather on switchyard condition and off-site power at your facility and how this was addressed in the PRA. Are you committed to any of the severe weather shutdown requirements and procedures of NUMARC 87-00? What requirements do you plan in order to avoid entering the 14 day AOTif severe weatheris anticipated? What is the contribution of severe weather to SBO induced core damage?

The BECo response is revised only to add the following clarification. " Contingency actions in anticipation of, and in response to, severe weather conditions are contained in PNPS procedure 1.2.2, " Administrative Ops Requirements". The appropriate attachment will be revised (probably Attachment 9, " Electric Power") to ensure weather conditions are evaluated to minimize the risk associated with a loss of off-site power prior to removing the EDG or SBO-DG from service."

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. (Ref. 4, Attachment C, TS page 3/4.9-5) The LCO associated with proposed TS 3.9.B.4.a (i.e., one EDG and the shutdown transformer are inoperable) is revised to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, instead of the initially proposed 72-hours, provided the startup transfomier and both offsite 345 kV transmission lines are available and capable of automatically supplying auxiliary power to the emergency 4160 volt buses. This change is more restrictive and, therefore, does not affect the determination of no significant hazards evaluation. The revised TS page 3/4.9-5 is attached.

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