View source for BECO-87-069, Application for Amend to License DPR-35,consisting of Proposed Change 87-02,revising Tech Specs to Remove Need to Conduct Surveillances on Redundant ECCS When Sys Found or Made Inoperable

{{Adams
| number = ML20215J351
| issue date = 04/30/1987
| title = Application for Amend to License DPR-35,consisting of Proposed Change 87-02,revising Tech Specs to Remove Need to Conduct Surveillances on Redundant ECCS When Sys Found or Made Inoperable
| author name = Bird R
| author affiliation = BOSTON EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000293
| license number = 
| contact person = 
| document report number = BECO-87-069, BECO-87-69, NUDOCS 8705070374
| package number = ML20215J354
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 5
| project = 
| stage = Request
}}

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  ..                                                          p                            10CFR50.90 t/
sosnwswsont Executive Offices 800 Boylston street Boston, Massachusetts 02199 April.30, 1987 BECo 87-069 Ralph G. Bird                                                                    Proposed Change 87-02 senior Vice President - Nuclear U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 License DPR-35 Docket 50-293 EEgoosed Chanae to Technical Soecification Section 3/4.5:          Emeraency Core Coolina Systems (ECCS)

==Dear Sir:==

Pursuant to 10CFR50.90, Boston Edison Company (BECo) proposes the attached modification to Appendix A of Operating License No. DPR-35. This modification removes the need to conduct surveillances on redundant ECC systems when a system is found or made inoperable. The changes are proposed to reduce unnecessary wear imposed by excessive surveillances on active system components.
The 10CFR170.12(c) required $150.00 application fee will be electronically mailed to the NRC.
E di R. G. Bird PMK/ns Attachments:           (A) Description of Proposed Change (B) Amended Technical Specification Pages 1 signed original and 37 copies cc: See next page 0
Commonwealth of Massachusetts)                                                                      .{ 0 .\g County of Suffolk                           )                                                            \
Then personally appeared before me, Ralph G. Bird, who, being duly sworn,,di t state that he  that is he dulyis authorized Senior VicetoPresident execute and  - Nuclear file theofsubmittal Boston Edison   Comp,any contained  herdin gnp?!. .
in the name and on behalf of Boston Edison Company and that the statemeQ's%f" ,'
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DATE'                            NOTh    PUBLIC T:%.% h 8705070374 870430                                                                             ~+  '
PDR      ADOCK 05000293
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y-BOSTON EDISON COMPANY                                  <
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* April 30, 1987 U.S. Nuclear Regulatory Commission Page 2                                                           .
cc:   U.S. Nuclear Regulatory Comission Region I 631 Park Avenue King of Prussia, PA 19406                  ,
Senior NRC Resident Inspector                          l' i
Pilgrim Nuclear Power Station Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Dept. of Public Health 150 Tremont Street F-7
            ' Boston, MA 02111
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                   ~ Propose'd Changt        f d
: 4.            Reference is made to Pilgrim Operating License No. OPR-35, Sections 3/4.5.A, i             B, C,O, E, and F.                                       t
: h:
T~            The proposed change removes the req'uirement for "immediate and daily thereafter" burveillances of redundant equipment when Emergency Core Cooling System (ECCS) components are made or found inoperable. The specific changes                             :
                   -are identified by change bars in the margins of the affected pages attached to this submittal.                                                   ,
The following Sections and pages are affected by this change:                           ,
L Section                  Eagg                                                                       I
(                            3/4.5.A                  104, 105, 114, 122                                                 -[
3/4.5.B                 107, 115, 122                                                        A 3/4.5.C                  108, 122 3/4/5.0                  109, 117, 122
  .                                 3/4.5.E                  110, 118, 122
!                                 J 3/4.5.F                  110, 122 Reason for Chance V
Currently, PNPS technical specifications for ECCS require the immediate surveillances of back-up equipment when a train or a system is made or.found inoperable. This requirement can result in excessive surveillance testing and corresponding equipment wear and tear. The additional tastirig provides no more demonstrable assurance than previous, normally scheduled equipment" surveillances. Regularly scheduled surveillance tests are adequate to
,                  . determine operability, and provide assurance that the eauipment will be available during the interim period between surveillances.                                                ,
The proposed change will bring PNPS technical specifications into conforman:o with Staridard Technical Specifications. The revised technical specification will avoid placing redundant systems in their test line-ups during periods when they'are most needed, reduce potential system failures due to Improper system alignment after testing and eliminate wear on components caused by the l                   additional surveillance testing. Therefore, this change will most'likely l                   contribute to improved system. availability.                                        ;
p                                                                                 ,.
Safety Enhttion ard Determination of No Sianificant Hazards Considerations The proposed amendment removes the requirement for immediate and daily surveillance testing of redundant ECC systems (ECCS).
l                   The Code of Federal Reaulations, 10CFR50.91 requires that at the time a l                   licensee requests an amendment, it must provide to the Commission its analysis, using the standards in 10CFR50.92, about the issue of no significant
!                   hazards consideration. Therefore, in accordance with 10CFR50.91 and l
10CFR50.92 the following analysis has been performed.
: 1. The operation of Pilgrim Station in accordance with the proposed amendment
;                         will not involve a significant increase in the probability or consequences
(                        .of an accident previously evaluated.
I i
                       ._      ___ i_________                  . _ -     .,   . _ , _ . - _ , _ _ _ .              _~           _ , _
l

The existing technical specifications requiring immediate and daily surveillances of redundant ECCS equipment is based on the assumption that increased equipment testing always provides additional assurance that equipment will be available should it be needed.
Industry experience indicates that too much surveillance testing puts unnecessary demands and wear on plant systems without providing substantial additional confidence in availability.
The normal surveillance frequencies are established to provide assurance that the system, once demonstrated operable, will remain operable during
                    .the period between surveillance tests. There is, therefore, nor reason to
:                    physically re-demonstrate operability due to-the inoperability of a redundant system.
I Since increasing the surveillance frequency when another system is determined to be inoperable does not provide additional assurance of system availability, and since increased surveillance frequency can
:                    prematurely wear active system components, removal of the increased
;s                 ~ surveillance requirements is beneficial and will not result in a significant increase in the probability or consequences of an accident previously evaluated.
: 2.        The operation of Pilgrim Station in accordance with the proposed amendment                                          i
 .                   will not create the possibility of a new or different kind of accident F                    from any accident previously evaluated.
The proposed amendment keeps redundant systems in a state identical to that assumed to exist in the Pilgrim Station accident analysis during normal operations; hence, operating Pilgrim in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any previously analyzed.
: 3.        The operation of Pilgrim Station in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.
Our current technical specifications require an increased surveillance frequency to demonstrate operability. The additional testing was thought t
to enhance confidence that the system will function when called upon.
However, normal test frequencies are established to provide assurance
,                    that the system, once demonstrated operable, .will remain operable during the period between surveillance tests. As discussed under (1) above, L                    there is no reason to physically demonstrate operability due to the inoperability of a redundant system. " Demonstrate Operability," under the l                    proposed amendment will be consistent with Standard Technical Soecificctions. Adequate assurance that redundant equipment is operable
;                    is implicit if the equipment is within the period between its normally required surveillances. The revised requirements provide assurance of
                   -operability without the potential of increased risk associated with placing systems in their test line-ups. Therefore, the proposed amendment will not :hange risk from that assumed for systems during normal operations; hence, the proposed amendment does not involve a significant
;_                  reduction in the margin of safety.
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This change has been reviewed and approved by the Operations Review Comittee and reviewed by the Nuclear Safety Review and Audit Comittee.
 !         Schedule of Changt
 !         This change will be implemented within 30 days following BECo's receipt of its approval by the Comission.
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